Springvale Water Treatment Facility

Mining and Industry Projects
NSW Department of Planning and Environment GPO Box 39 Sydney NSW 2001

Dear Sir/Madam,

Submission on the Springvale Water Treatment proposal (SSD 16_7592)

The Springvale water treatment proposal must be greatly improved if it is to adequately protect the Coxs River catchment, the Greater Blue Mountains World Heritage Area and Sydney's drinking water resources. Mine water must not be simply treated to a minimum standard then released into the catchment.

Wangcol Creek is already contaminated. Discharges from the proposed treatment plant would worsen this situation and send a plume of salt down the Coxs River that is part of Sydney's drinking water catchment.

The treatment proposal must maximise mine water use by storing it for future periods of high demand by the Mt Piper Power Plant. Water treatment must be decoupled from the power plant's coal consumption to prevent an outcome where a reduction in coal-fired electricity generation would cause an increase in mine water pollution.

The water treatment plant must not be built for discharge into the environment. It can be designed as a closed system with treated mine water stored in Thompsons Creek Reservoir which has sufficient capacity to accommodate mine water from both Springvale and Clarence mines for future power plant use.

To take advantage of future mine water transfer upgrades, the proposed pipeline from Springvale to Mt Piper power plant should have sufficient capacity to accommodate mine water from Clarence Colliery.

Runoff from the Springvale Coal Services and fly ash emplacement areas also must be collected and treated for use in the power plant.

Any additional pipeline construction on Newnes Plateau for the mine water transfers must follow the existing pipeline alignment to minimise further damage to endangered ecological communities and pagoda landscapes.

David ---
1-3 Reid Road
Winmalee New South Wales 2777
Monday, October 24, 2016 - 11:02

Mining and Industry Projects
NSW Department of Planning and Environment GPO Box 39 Sydney NSW 2001

Dear Sir/Madam,

Submission on the Springvale Water Treatment proposal (SSD 16_7592)

The Springvale water treatment proposal must be greatly improved if it is to adequately protect the Coxs River catchment, the Greater Blue Mountains World Heritage Area and Sydney's drinking water resources. Mine water must not be simply treated to a minimum standard then released into the catchment.

Wangcol Creek is already contaminated. Discharges from the proposed treatment plant would worsen this situation and send a plume of salt down the Coxs River that is part of Sydney's drinking water catchment.

The treatment proposal must maximise mine water use by storing it for future periods of high demand by the Mt Piper Power Plant. Water treatment must be decoupled from the power plant's coal consumption to prevent an outcome where a reduction in coal-fired electricity generation would cause an increase in mine water pollution.

The water treatment plant must not be built for discharge into the environment. It can be designed as a closed system with treated mine water stored in Thompsons Creek Reservoir which has sufficient capacity to accommodate mine water from both Springvale and Clarence mines for future power plant use.

To take advantage of future mine water transfer upgrades, the proposed pipeline from Springvale to Mt Piper power plant should have sufficient capacity to accommodate mine water from Clarence Colliery.

Runoff from the Springvale Coal Services and fly ash emplacement areas also must be collected and treated for use in the power plant.

Any additional pipeline construction on Newnes Plateau for the mine water transfers must follow the existing pipeline alignment to minimise further damage to endangered ecological communities and pagoda landscapes.

Jasmyn Ellis
127 Hope Street
b New South Wales 2795
Monday, October 24, 2016 - 10:50

Please find attached for your information the Division's response to your request for comments on the above project.

Please see attached a submission on behalf of the Lithgow Environment Group Inc on the Springvale Water Transfer and Treatment Project SSD 16_7592.

Please see attached OEH's comments on the Springvale Water Treatment Project Environmental Assessment.

Please find attached comments in relation to the Springvale Water Treatment EIS.

Please see attached formal DPI response for the above matter.

Please find attached the official BMCS submission.

Please accept our submission, attached.

see attached PDF.

see attached PDF.

see attached PDF.

see attached PDF.

Dear Sir/Madam,

Please find attached two submissions to SSD 16_7592

The Colong Foundation submission on letterhead is the Foundation's considered submission seeking significant improvements and objecting to this proposal due to unnecessary discharges to the Coxs River.

The other submission is a report, poster and XL spreadsheet by University of Sydney advanced engineering students into options for augmenting mine water transfers in the Coxs River catchment.

The authors of this second submission are Paula Van der Ghote, Tim Warner, Zhang Yik Tian, Ken Yoong Tong, Chris Georgiou, Anh Ho and Max Weston of the University of Sydney who have agreed to make this contribution available for this review of development application SSD 16_7592. It is not a submission as an objection or in support of any proposal. Rather this considered submission identifies constructive ways of augmenting the current proposal that will assist your Department with its assessment report of the adequacy of the SSD 16_7592 proposal.

This submission also addresses Condition 13 of Schedule 4 of the September 2015 consent for the Springvale mine expansion, SSD 5594 that requires all mine water discharges in the Coxs River catchment, including LDP006 from the Springvale Coal Processing Plant, to be considered.

It is surprising then that the applicants for SSD 16_7592 did not adequately consider other mine water LDPs, other than Springvale LDP009.

Condition 13 requires an Upper Coxs River Action Plan to address all sources of mine water pollution, and not just the one source as currently proposed for treatment and reuse in the Mt Piper Power Plant.

This Upper Coxs River Action Plan is an important legal requirement of SSD 5594, as the Coxs River flows forms a key part of Sydney's main drinking water storage, Lake Burragorang. There have been blue-green algae blooms downstream in Lake Wallace and Lake Lyell in recent years that may be associated with the ammonia in mine water, and the river seems to be reaching an ecological threshold.

The students determined the power plant's average and full capacity water demand. They found that the currently proposed mine water transfer and reuse scheme was significantly undersized. The joint Centennial Coal/EnergyAustralia proposal could not meet the plant's average daily water demand requirements of 40ML/day and had no capacity for demand growth. The current proposal misses opportunities to maximise removal of mine water from the Coxs River through reuse in the power plant.

The students identified five options for capacity expansion of the mine water scheme, including options for the treatment of Clarence mine water discharge; the Springvale Coal Services Area discharge; and other Springvale discharges. The sensitivity of each identified option to respond to range of environmental and economic criteria determined that treatment of mine water runoff from the Coal Services Area was the highest environmental priority for treatment.

[The Colong Foundation would add that to make best advantage of any of the students' options, treated mine water storage is required.]

The coal services area runoff was the best environmental option as it is by far the most saline and requires the shortest pipeline to divert it for treatment and reuse.

The students examined the total dissolved solids from each discharge point and found the coal services area discharged up to 125 tonnes of dissolved salts a day, and this was over five times greater than the salt load discharged from Springvale mine. Even though this analysis assumes a worst case scenario of maximum licence discharge for each discharge point and not actual discharge volumes, they have discovered that the coal services area discharge is indeed a missing `elephant in the room'.

Centennial Coal's mine water discharges have caused extensive damage over decades. In the 1990s the mine water poisoned Narrow and Sunnyside Swamps and these swamps have never recovered. Some years later this mine water destroyed a condenser at the Wallerawang power plant, and mine water is current killing aquatic life in the Coxs and Wollangambe Rivers.

The Colong Foundation appreciates that the students assessment is not the only set of priorities for further treatment of toxic mine water discharges into the Coxs River but it is a considered set of priorities where none were provided by this proposal. It has identified a mine water `elephant in the room' - LDP006, and for that Sydney's water consumers and the Department of Planning and Environment should be grateful.

Thank you for considering these submissions.

--
Keith Muir
Director
The Colong Foundation for Wilderness Ltd
Level 2, 332 Pitt St, Sydney, NSW, 2000
Ph 9261 2400; Mob 0412 791 404
www.colongwilderness.org.au
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