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DETSI Comment
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Report
Accordingly, and per the 'Major and Minor Amendments Guideline, 1 the 'existing area' to be considered by the Department when assessing the EA amendment application against criterion (f) is the combined surface area previously disturbed or authorised to be disturbed by mining activities in the mining tenements which are now subject to the EA Number 8 Dam has never been referred to as “the clean water dam” in any existing documentation. Dam 8 is used by Heritage Minerals as a source of construction and processing water. There is no water quality data available to determine if Dam 8 is “clean”. As seen in Figure 14, portions of the waste rock dump are exposed and may be providing a source of contamination into the ephemeral pond at the base of the Upper Mundic Gully catchment. This pond then flows, via the tunnel, into Number 8 Dam. The statement “ensuring clean water does not become contaminated within the tunnel and to dam 8” is highly speculative and not based on data. Nevertheless the risk assessment has been updated to include this as a possible scenario. A tunnel management strategy was included in the WSP design report. The engineering controls involve plugging the tunnel with concrete. For clarity, this information has been summarised and included in new Section 4.3.7. Details of conversations between Heritage Minerals and the DNRMMRRD are typically not summarised in application documents. DNRMMRRD are briefed by Heritage Minerals prior to significant engagements with DETSI. As with other EP Act applications Heritage Minerals have made, during the assessment period it is assumed that DETSI engage with DNRMMRRD.
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The clean water dam (Number 8 Dam) tunnel is proposed to be filled. No detail is provided regarding if the Department of Natural Resources and Mines, Manufacturing and Regional and Rural Development has been advised on this exclusion or management of clean water through the tunnel. Further no detail is provided ensuring clean water does not become contaminated within the tunnel and to dam 8
Section 4.3.7 Table 45
1 See, in particular, Example 16 in the Guideline.
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