On the Kookaburra Gully Mining Proposal
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Kookaburra Gully Mining Lease Application Request for Response Document Letter Attachment 03 24 Public Submissions (excluding confidential public submissions) Kookaburra Gully Mining Lease Application - Public Submissions (excluding confidential submissions) Page 1 of 263 Contents Page Submission Number Public Submission Name Page Number 1 MD & SR Sheehan 3 2 Carole Wetherby 6 3 District Council of Tumby Bay 7 4 Name and Address Withheld 10 5 Name and Address Withheld 16 6 Name and Address Withheld 19 7 Name and Address Withheld 21 8 Name and Address Withheld 26 9 Caryll Cabot 30 10 Anne Daw 35 11 John & Janet Moore 46 12 Name and Address Withheld 48 13 Name and Address Withheld 53 14 Name and Address Withheld 58 15 Name and Address Withheld 60 16 Name and Address Withheld 62 17 Name and Address Withheld 67 18 Name and Address Withheld 72 19 Name and Address Withheld 77 20 Name and Address Withheld 84 21 Name and Address Withheld 90 Tumby Bay Residents and Ratepayers 22 Association Inc. 91 23 Stop Invasive Mining Group 249 24 Emie Borthwick 257 Kookaburra Gully Mining Lease Application - Public Submissions (excluding confidential submissions) Page 2 of 263 MD&SR Sheehan Box156 Cummins 5631 26th October 2015 For Attention: Business Support Officer Mining Regulation Branch Department of State Development GPO Box 320 Adelaide 5001 Dear Sir/Madam We are writing this letter as concerned primary producers who live on Lower Eyre Peninsula. We are extremely concerned about the potential for damage to be caused to the groundwater on Lower EP. If this is in any way contaminated or damaged the effect would be disastrous for all people living on Eyre Peninsula. See: GROUNDWATER (Vol 1 Section7.4) We also have grave concerns about the DUST (Vol1 Section4pp 106.7 Section 7.4) and the effect it will have on the surrounding district. We also note that the TRANSPORT ROUTE (Vol1 Section 7.9) raises serious issues for the area. We trust that these concerns will be taken seriously and acted upon as we are just two of a large number of people seriously concerned about many issues in regard to this project. Yours faithfully Mark and Sharon Sheehan Transport Route (Volume 1: Section 7.9) (a) It is noted that the transport route has been determined in the absence of consultation with the community and Elected Members of the District Council of Tumby Bay (as evidenced by discussions at the Council meeting of 13 October 2015). (b) There is no agreement with the DCTB as to the actual transport route (c) Assumptions have been made on the part of the Works Manager as to the transport route, but these are not transparent to Elected Members not the Community at large Kookaburra Gully Mining Lease Application - Public Submissions (excluding confidential submissions) Page 3 of 263 (d) The capability of the ‘determined route’ appears not to have been subjected to any formal approval process through DPTI (e) The impact upon native vegetation and EPBC listed species is not recognised in the Application (f) The application includes cost estimates from a private contractor as to upgrading the road, but no Council budget exists for this work to be undertaken and no agreement to cost sharing exists. (g) There is no economic benefit statement to the community pertaining to the proposed road upgrade, only the potential for continued maintenance and repair liabilities for the life of the mine and beyond. Dust (Volume 1:Section 4,pp106‐7: Section 7.4) An analysis of the data provided indicates the existence of a significant number of minerals within the ore body that are potentially harmful to human health and plant health. These include not only the graphite, but Chromium, Manganese, Nickel, Rare Earths, Strontium, Thorium and Uranium together with Copper, Magnesium and Zinc. These minerals are potential carcinogens and or neurotoxins in humans and growth inhibitors in plants. The nature and health impacts together with potential agricultural industry impacts of the dust emanating from mining operations are inadequately described in the application. In the absence of on‐site meteorological data, the dispersion pattern modelled from data remote from the site is of concern, given the potential nature of the contaminant within the dust and their impact upon humans and plants alike. There is no consideration given to the impact upon pastures and thence animals whom ingest these contaminants over a period of time. The application is devoid of information pertaining to the economic losses attributed to the impact of copper, magnesium and zinc (in excess of trace levels) on grain production. The application is devoid of information pertaining to the impact upon agricultural businesses within the fallout cloud of contaminated dust through contaminated grain deliveries. The application is devoid of information pertaining to the potential contamination of rain water, the main source of drinking water for the area. The application is devoid of any impact of the contaminated dust reaching the township of Tumby Bay having regard to the topography (height above sea level of the proposed mine) and the wind direction (and velocity) towards Tumby Bay. The application is devoid of information pertaining to the impact on surface water contained within the Tod River Water Protection Zone (as per the DCTB Development Plan) or the Tod River Wetland of National Significance. Groundwater (Volume 1: Section 7.4) Kookaburra Gully Mining Lease Application - Public Submissions (excluding confidential submissions) Page 4 of 263 An analysis of the data provided indicates the existence of a significant number of minerals within the ore body that are potentially harmful to human health and plant health. These include not only the graphite, but Chromium, Copper, Manganese, Nickel, Rare Earths, Strontium, Thorium and Uranium. These minerals are potential carcinogens and or neurotoxins in humans and growth inhibitors in plants. The nature of the hazardous materials emanating from mining operations inclusive of the processing operations is inadequately described in the application. The environmental impact associated with contamination of groundwater with the hazardous materials identified is not fully disclosed neither is the long term health impacts associated with contaminated ground water. It is noted that there are significant limitations with respect to the geotechnical, hydrogeology and hydrology of the site, especially in regard to the design of the TSF facility (Section 4.7.7.4 pp 198). It is significant concern that the limitations highlighted by the consultant extends beyond the TSF facility to include the known fact that no data exists for MC4372, nor does the geo‐hydrology or hydrology exists beyond the boundaries of MC4373 which may impact upon the Prescribed Wells Area to the South, the source of potable water for the lower Eyre Peninsula. Kookaburra Gully Mining Lease Application - Public Submissions (excluding confidential submissions) Page 5 of 263 Business Support Officer, Mining Regulation Branch, Dept of State Development, GPO Box 320, Adelaide SA 5001 October 23, 2015 The Australian Graphite Limited, Kookaburra Gully Graphite Mine, Mineral Lease Application will need a magical Editor to fix all the inaccuracies and deficiencies that are in this report. A committee of 5 have reviewed the entire report and I attended the meeting to observe the inconsistencies and inaccuracies that are all through the report. Following are listed a few – Transport Route (Volume 1: Section 7.9) 1. In various sections of this part of the report, the number of heavy vehicles using the road differs in a number of paragraphs. 2. There is no agreement with the District Council of Tumby Bay as to the actual transport route. Dust (Volume 1:Section 4, pp106-7: Section 7.4) 1. This report has nothing mentioned to the major impact upon agricultural businesses within the fallout cloud of contaminated dust due to constant very windy conditions that will contaminate Eyre Peninsula’s huge grain deliveries. (The mining company have said there is nothing to worry about, we breathe in graphite dust particles all the time!! What an outrageous statement to make!!) 2. One of the most outstanding missing section in the report is the potential contamination of rain water which happens to be the Eyre Peninsula’s main source of drinking water. Groundwater (Volume 1: Section 7.4) 1. The nature of the hazardous materials emanating from mining operations inclusive of the processing operations is inadequately described in the application. 2. The environmental impact associated with contamination of groundwater with the hazardous materials identified is not fully disclosed neither is the long term health impacts associated with contaminated ground water. 3. (Section 4.7.7.4 pp 198) There are significant limitations with respect to the geotechnical, hydrogeology and hydrology of the site, especially in regard to the design of the TSF facility. It is significant concern that the limitations highlighted by the consultant extends beyond the TSF facility to include the known fact that no data exists for MC4372, nor does the geo-hydrology or hydrology review exist beyond the boundaries of MC4373 which may impact upon the Prescribed Wells Area to the South, the source of potable water for the Lower Eyre Peninsula. (In view of this part of the document, the whole project needs to stop). Community members have been informed there would be limited blasting. However, the lease application document states there will be a huge amount of explosives and dangerous toxic chemicals stored on site. This is a direct conflict to what the mining company had originally informed the community. The report on the Kookaburra Graphite Mine has obviously been very carelessly put together. The report, as is, lacks a knowledgeable, educated approach and definitely a non-convincing reason to rip or blow up completely good viable farm land.