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Risk of leakage
Key concerns:
Treatment of contaminants in the tailings dam is not presented in the EIS.
The dam is planned to be constructed on a fault. 1.6 ML/day of dam leakage is planned without considering the fault risk.
The planned monitoring places few controls on compliance with the design and there is no contingency plan to remediate leakage.
No peer review of contamination risks has been presented.
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Tailings dam leachate
Key concerns:
The native groundwater flow direction from the tailings dam is misreported.
Existing groundwater contouring is not well explained, and while evidence of leachate migrating from the dam is presented, the fate of leachate if it reaches the water table has not been demonstrated.
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Acid forming waste rock and acid forming tailings
Key concerns:
Bowdens’ groundwater assessment considers groundwater availability around the site, but no peer review has been conducted on groundwater contamination risks.
The hazardous nature of substances in the waste rock dump and tailings dam merit a local and detailed model of hydrogeological processes to adequately manage the proposed activity.
There is significant risk of tailings dam leachate bypassing the seepage collection ponds and entering the groundwater system.
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Risk of cyanide contamination
Key concerns:
Different assumptions regarding the volume of cyanide used, the presence of faults under the tailings dam, and the lack of contingency plan in case of a leak raises concerns about Bowdens ability to contain cyanide.