Gaps in risk assessment damn mine modifications

Eurobodalla Shire Council and Palerang Council commissioned consultant Mr Peter Beck of GHD Pty Ltd to provide comment on the proposed Modifications to the Dargues Gold Mine Mining Operations.

The report noted that there were significant changes to the original Environmental Assessment of 2010 and picks up on significant gaps in the risk assessment by Unity Mining with the proposed introduction of cyanide processing on site. 

The 49 page report details the background of the mine and the operational proposals, placing it in context with other cyanide processing mines around the world. 

The report says “Accidental releases of cyanide at gold mines have occurred at all stages of its use at a number of sites around the world, even over recent years. The impacts from these releases have varied from localised animal death to mass death of aquatic fauna in river systems. Some of these accidents have also resulted in fatalities in communities living near the mine or impacting the quality of the natural resources on which they rely.”

Commenting that in transportation the impact of a “catastrophic failure of a single isotainer (containing cyanide) would be significant” the report says that the transport risk assessment and emergency response measures had not yet been completed.” 

Similarly in the onsite stage stage, “no details of an emergency response procedures, or any monitoring, mitigation, clean up or validation plans had been completed” the report says. 

The report says the proposal only considered the mine life of the Tailings Storage Facility (TSF) and not after that. It also says the proposal focuses only on cyanide and not other leachate chemicals.

The report also details the significantly different type of dam structure which will “ store a significantly greater volume of tailings, has a different liner design and will present a significantly higher hazard over a longer period.”

The report notes that the proposal “does not consider the risk of catastrophic failure of the TSF dam and also under-estimates the potential for leakage of the TSF.” 

The report also notes the extra capacity to be stored saying “Modification 3 proposes co-disposal of the flotation and concentrated waste tailings leading to interlayering and mixing of the two waste streams. The consequence is that the co-disposal leads to a waste volume of 1,222,000 tonnes instead of 180,000. This is contrary to NSW EPA policy that dilution is not an acceptable solution to pollution.” 

The report also says states that the modifications are are “in breach of the mining company’s negotiated agreement with the Eurobodalla community.” 

Matt Darwon, President of the Majors Creek Catchment Guardians Incorporated has recently addressed both ESC and Palerang Council 

He said “Watching the ABC news article the Sunday night before last I heard the reporter mention that Palerang and Eurobodalla Councils were concerned, but powerless.

I found this statement baffling. How could people who lived in our area consider themselves powerless?. How could elected representatives in Local Government be powerless? 

I’ve been harping on about a two tiered approach to considering the Unity Mine modification number 3 to Dargues Mine at Majors Creek since last December.

Tier 1 is a technical review which both Eurobodalla and Palerang Councils have already begun.

Tier 2 is a Social review. ...Unity Mining Limited does not have the support of the community at Majors Creek, or the community at Araluen or Braidwood, or those people who live within the Eurobodalla Shire who rely on water that originates in areas upstream like Majors Creek.”

“Social Licence to Operate refers to the level of acceptance or approval by local communities and stakeholders of mining companies and their operations. The concept has evolved fairly recently from the broader and more established notion of Corporate Social Responsibility and is based on the idea that mining companies need not only government permission but also social permission to conduct their business.”

Palerang Council will hold an Extraordinary Council Meeting on Thursday evening at the National Theatre in Braidwood to consider the Proposal to undertake cyanide-based processing at Dargues Gold Mine, Majors Creek. 

Palerang Council also has the opportunity to make a submission on the proposal to introduce cyanide-based processing at the Dargues Gold Mine near Majors Creek.

The Business Paper Recommends that Council:

1. Note  A) the review of the Environmental Assessments prepared by Dr Peter Beck, from GHD, that documents the increased risk that would follow the introduction of cyanide-based processing; B) the community concern regarding the possible introduction of cyanide-based processing and ;

2. Lodge a submission opposing approval of Modification 3; 

3. Write to the Premier, all relevant Ministers and local members expressing the community’s opposition to any variation to the Dargues Gold Mine approval that unacceptably increases environmental and community risk.

The modifications requested from Big Island Mining Pty Ltd (BIM) are:

1. A minor increase to the total resource to be extracted and associated extension of the life of the mine.

2. Construction and use of the Eastern Waste Rock Emplacement and a vehicle crossing over Spring Creek.

3. Construction of an enlarged Tailings Storage Facility.

4. Final processing of gold concentrate on site to produce gold ore or unrefined gold bars using a conventional carbon-in-leach processing plant.

5. A range of minor adjustments to the conditions of MP10_0054 to further clarify the intent of those conditions.

The council report states “Perhaps the parts of the report most relevant to Council’s current consideration of Modification 3 are the risk comparison tables. These demonstrate that the risks to the environment and the community would be greater if CIL processing was introduced at the Dargues Gold Mine.

Palerang Council’s report says “Opposing the introduction of carbon-in-leach processing would be consistent with the application of the “precautionary principle” for the protection of the environment.”“The initial “reluctant” support of the original consent granted Big Island Mining was possibly based on a perception of a balanced “triple-bottom line” assessment – that is, the original proposal has acceptable environmental risks while potentially providing economic and social benefits.

“It is arguable that the community perceives the introduction of carbon-in-leach processing would increase the environmental risk without providing significant increases in social and economic benefits. “

Palerang’s report concludes that “While it can be argued that the destruction of cyanide post-processing, and the breakdown of cyanide in sunlight, minimises the risk of environmental damage, it is unarguable that the risk of such damage would be greater following the introduction of carbon-in-leach processing. While cyanide represents a risk, perhaps the greater long-term risk is the residual heavy-metals remaining on-site in the expanded tailings dam. While cyanide may break down over time, these heavy metals do not.”

The meeting starts at 5pm starting with statements from the public gallery which are limited to 3 minutes. 

Submissions to the NSW Dept of Planning on the proposed Modifications to the mine close Wednesday, 26 August 2015.