amendment notice 3...daily inspections of the pipeline route during dewatering operations will be...

Licence: L7404/1999/9

IR-T08 Amendment Notice (Major) template v2.0 (July 2017) 1

Licence Number L7404/1999/9

Licence Holder Australian Nickel Investments Pty Ltd

ACN 119 599 323

File Number: DER2015/002781

Premises Cosmos Nickel Operations Goldfields Highway SIR SAMUEL WA 6437

Legal description – Mining Lease M36/127 and M36/371 and part of M36/180 and M36/349

Date of Amendment 13 September 2018

Amendment

The Chief Executive Officer (CEO) of the Department of Water and Environmental Regulation (DWER) has amended the above Licence in accordance with section 59 of the Environmental Protection Act 1986 as set out in this Amendment Notice. This Amendment Notice constitutes written notice of the amendment in accordance with section 59B(9) of the EP Act and follows.

Date signed: 13 September 2018

Tim Gentle

MANAGER RESOURCE INDUSTRIES

REGULATORY SERVICES

an officer delegated under section 20 of the Environmental Protection Act 1986 (WA)

Amendment Notice 3

Licence: L7404/1999/9


Definitions and interpretation

Definitions

In this Amendment Notice, the terms in Table 1 have the meanings defined.

Table 1: Definitions

Term Definition

ACN Australian Company Number

AHD Australian Height Datum

ANI Australian Nickel Investments Pty Ltd

Application refers to the documents and information submitted by the Licence Holder, as described and listed in Table 2 of this Notice

Category/Cat categories of Prescribed Premises as set out in Schedule 1 of the EP Regulations

CEO Chief Executive Officer

CEO for the purposes of notification means:

Director General Department Administering the Environmental Protection Act 1986 Locked Bag 33 Cloisters Square PERTH WA 6850 [email protected]

Delegated Officer an officer under section 20 of the EP Act

DWER Department of Water and Environmental Regulation

EP Act Environmental Protection Act 1986 (WA)

EP Regulations Environmental Protection Regulations 1987 (WA)

Existing Licence the Licence issued under Part V, Division 3 of the EP Act and in force prior to this Notice

Licence Holder as specified at the front of this Notice

mbgl metres below ground level, with “ground level” referring to the original (undisturbed) ground level at the particular location

Mtpa million tonnes per annum

Notice refers to this document

Prescribed Premises has the same meaning given to that term under the EP Act

Premises refers to the premises to which this Decision Report applies, as specified at the front of this Decision Report

Risk Event as described in Guidance Statement: Risk Assessment

TDS Total Dissolved Solids

WMP Water Management Pond

mailto:[email protected]

Licence: L7404/1999/9


Amendment Notice

This amendment is made pursuant to section 59 of the Environmental Protection Act 1986 (EP Act) to amend the Licence issued under the EP Act for a prescribed premises as set out below. This notice of amendment is given under section 59B(9) of the EP Act.

This notice is limited to Australian Nickel Investments Pty Ltd (ANI) constructing a new 3 kilometre dewatering pipeline between Cosmos and Orleans open pits and the removal of MB02 as a compliance monitoring bore at the Cosmos Nickel Project. When ANI acquired the premises, a suitable agreement was unable to be reached to utilise the existing dewatering pipeline located on alternate tenements therefore a new dewatering pipeline is required. No changes to the approved dewatering rate (3 Mtpa) of the existing Licence has been requested by ANI with respects to the dewatering operations between Cosmos and Orleans open pits.

The following guidance statements have informed the decision made on this amendment:

Guidance Statement: Regulatory Principles (July 2015)

Guidance Statement: Decision Making (February 2017)

Guidance Statement: Risk Assessment (February 2017)

Amendment description

The Licence Holder proposes to construct a new dewatering pipeline as part of works to reopen the Cosmos underground mine. A Licence amendment application to construct the pipeline was submitted by the Licence Holder on 25 May 2018. A subsequent email dated 12 June 2018 requested the removal of MB02 as a compliance monitoring bore on grounds of it suitability for this purpose.

Table 2 lists the documents submitted during the assessment process.

Table 2: Documents and information submitted during the assessment process

Document/information description Author Date/version

Cosmos Nickel Project – construction of 3km dewatering pipeline including maps and supplementary Attachment 2, 3A, 5, 6A and pipeline design plans.

Australian Nickel Investments

25 May 2018

Cosmos Nickel Project – email request to remove MB02 as a compliance monitoring bore from Licence.

Australian Nickel Investments

12 June 2018

Background

Cosmos is a former nickel mining and processing venture located near Leinster, approximately 370 km northwest of Kalgoorlie. The project was placed into care and maintenance in 2012 by the previous operator, where the underground operation and lower levels of the Cosmos pit were allowed to flood.

ANI acquired the project in September 2015 and is now preparing to resume underground mining. In June 2017, DWER amended the Licence to enable dewatering of the flooded mine and underground, and construction of new water management ponds (WMP). Draining of the flooded mine was based on a tight timeframe, with an expected completion date of November 2018.

DWER has previously assessed the acceptability of the proposed dewatering strategy for the Premises, including water balance calculations and hydrogeological modelling referenced in the decision report for the existing Licence, dated June 2017.

Proposed Works

The Licence Holder proposes to commence open pit dewatering, which will involve discharging mine water to WMP 6 & 7. This will enable the Licence Holder to observe how the

Licence: L7404/1999/9


aquifer will respond to dewatering and make adjustments to the dewatering schedule, accordingly.

New dewatering pipeline from Cosmos to Orleans pit

The new dewatering pipeline from Cosmos to Orleans pit will be constructed over a 3.0 km distance between pits and laid alongside an existing track to allow visual monitoring for pipeline leaks and ruptures. The route will be within tenement M36/127 & M36/371 as shown in schedule 1 of this Licence amendment and will involve the clearing of 2.5 Ha of vegetation.

The pipeline will be constructed using 280 mm diameter Polyethylene high density pipe which is butt welded and then laid in a trench that will be 600 mm wide and 900 mm deep and will include mounding of approximately 500 to 600 mm. Section of pipeline laid under road crossings, floodway and dry creek crossings are shown below.

The pipeline will be hydro-tested prior to commissioning to ensure the pipelines integrity and will be fitted with a telemetry-based leak detection system in the form of a flow meter and transmitter at each end of the pipeline. Any discrepancy between the flow meters will cause the pump to cease operating and trigger an alarm. Daily inspections of the pipeline route during dewatering operations will be undertaken. Dewatering is estimated at a rate of approximately 40 L/s to be discharged to the WMP’s.

Monitoring bore MB02

A reduced groundwater monitoring schedule has focused on 7 bores (MB02, MB09, MB10, MB11, MB13, MB14 and MB16) in the immediate vicinity of WMPs 6 & 7. WMP 8 and 9 are currently under construction including new monitoring wells MB21, MB22, MB23 and MB24. As MB02 is located in a disturbed corridor sandwiched between the tailing storage facility (TSF) and WMP 6 & 7 it is no longer serving the purpose of monitoring groundwater levels to protect vegetation to the north of the TSF. The map below indicates the location of MB02 and identifies the location of the new bores (MB21, MB22, MB23 and MB24) to be constructed.

Licence: L7404/1999/9


Other approvals

The Licence Holder has provided the following information relating to other approvals as outlined in Table 3.

Table 3: Relevant approvals

Legislation Number Approval

Mining Act 1978 (WA) Registration ID: 74187

A Mining proposal for a new pipeline corridor and haul road has been approved by DMIRS.

Licence: L7404/1999/9


Rights in Water and Irrigation Act 1914 (WA)

GWL110790(6) Licensed allocation 3,000,000 kL/yr from the Goldfields Groundwater Area (Lake Carey sub-area), Fractured Rock West aquifer, for the purposes of dust suppression, dewatering and mineral ore processing.

Environmental Protection (Clearing of Native Vegetation) Regulations 2004 (WA)1

Exempt Application for a clearing permit is not required as the total area of 2.5 Ha is exempt.

Note 1: Delegated to Department of Mines, Industry Regulation and Safety

Location and receptors

The Premises is located in the north-eastern Goldfields, on the Norseman-Wiluna Greenstone Belt. The local area is a major mineral province with several operating gold and nickel mines, and numerous prospects for uranium, rare earths and base metals.

The climate is considered arid to semi-arid, with the area characterized by undulating areas of sandplain and granite outcrop, and by ephemeral creeks which drain into large salt lakes. Groundwater is saline-to-hypersaline and occurs in the bedrock, paleo-channels and in overlying alluvial, colluvium and calcrete deposits. There is no fresh groundwater in the region; limited areas of brackish groundwater occur in the upper reaches of some catchments.

Table 3 below lists the relevant sensitive land uses and specified ecosystems in the vicinity of the Prescribed Premises, which may be receptors relevant to the proposed amendment.

Table 3: Sensitive land uses and environmental receptors

Sensitive land use Distance from Prescribed Premises

Residential premises

Yakabindie Pastoral Station (homestead) – approx. 6.5 km NW of the Cosmos open pit

Industry

BHP Leinster Nickel Mine – approx. 24 km SSE of the Cosmos open pit

Town site

Town of Leinster (population ~ 1,100) – approx. 42 km SSE of the Cosmos open pit

Specified ecosystems Distance from Prescribed Premises

Important Wetlands – WA Lake Miranda – approx. 6 km south of the Premises

Lands managed by the Department of Biodiversity Conservation and Attractions

Wanjarri Nature Reserve – approx. 12 km NE of the Cosmos open pit

Threatened Ecological Communities and Priority Ecological Communities

Priority 1 (P1) – Lake Miranda East Calcrete (potentially high stygofauna conservation values). Premises is located within and adjacent to the PEC buffer. The mapped boundary of the PEC is located approx. 6 km from the Cosmos open pit

P1 – Violet Calcrete (potentially high stygofauna conservation values). Premises is located within and adjacent to the PEC buffer. The mapped boundary of the PEC is located approx. 4 km from the Cosmos open pit

P1 – Lake Miranda West Calcrete (potentially high stygofauna conservation values). The mapped boundary of the PEC is located approx. 11 km from the Cosmos open pit

P1 – Yakabindie Calcrete (potentially high stygofauna conservation

Licence: L7404/1999/9


values). The mapped boundary of the PEC is located approx. 6 km from the Cosmos open pit

Biological component Distance from Prescribed Premises

Threatened/Priority Flora No rare or priority flora species have been recorded within the Premises

Threatened/Priority Fauna Lake Miranda, approx. 6 km south of the Cosmos open pit, may provide suitable habitat for a number of migratory bird species listed under international conventions

The distance to groundwater and water sources as shown in Table 4.

Table 4: Relevant approvals

Surface water

Distance from the Premises Environmental value

Freshwater Creek

Flows north-south adjacent to the eastern flank of the Cosmos open pit pipeline

Several smaller drainage lines around key site infrastructure are diverted to this creek

Enters Lake Miranda approx. 7 km south of the Cosmos open pit

The low annual rainfall is highly episodic and has contributed to unique surface hydrological sequences supporting flora and faunal communities within the riparian zone

Water is not suitable as potable water or for industrial use

Lake Miranda Approx. 6 km south of the Cosmos open pit Historically influenced by mining dewatering discharge

Ephemeral waterbody that provides an important refuge for aquatic biota and may support a diverse range or organisms during flooding

Groundwater Distance from the Premises Environmental value

Groundwater Pre-mining groundwater level in the area of the WMPs is approximately 15 mbgl.

Historical dewatering activities at the Cosmos pit and underground has resulted in a drawdown cone which extends approx. 1.4 km north of the pit, forming a capture zone around almost the entire upper catchment.

There are 5 registered bores within 3 km of the Premises. The closest is Williams Well located adjacent to WMP2 and is no longer operational. The remaining 4 are unsuccessful groundwater exploration holes that were installed in 1988 and are no longer in use.

The natural groundwater is non-potable, with salinity ranging from 900 to 3,000 mg/L total dissolved solids. Potable water is drawn from the Yakabindie borefield and treated via reverse osmosis.

The salinity of groundwater deeper in the profile is hypersaline.

Risk assessment

Table 5 below describes the Risk Events associated with the amendment consistent with the Guidance Statement: Risk Assessments. The table identifies whether the emissions present a material risk to public health or the environment, requiring regulatory controls.

Licence: L7404/1999/9


Table 5: Risk assessment during construction and operation of WMP9

Risk Events Consequence

rating Likelihood

rating Risk Reasoning

Sources/Activities Potential emissions Potential receptors Potential pathway

Potential adverse impacts

Construction of

dewatering pipeline

Civil excavation/ earthworks/ pipeline construction works/ installation, waste removal, vehicle movements on unsealed roads

Noise No residences or other sensitive receptors in proximity

Closest receptor is Yakabindie homestead 6.5 km away, next nearest in Leinster town site ~42 km south by south east.

Air / wind dispersion

Amenity and human health impacts

N/A N/A N/A No receptor present

Fugitive emissions (dust)

Vegetation, including riparian vegetation adjacent to the pond footprint

Soil contamination, suppression of photosynthetic and respiratory functions

Minor Rare Low Due to the short duration of construction works (<8 weeks), the Delegated Officer considers the material risk of dust impacting on vegetation from excavation/earthworks to be Low. Actual impacts can be regulated under the provisions of Section 49 of the EP Act

Clearing of native vegetation

Noise No receptors present (see above) Amenity and human health impacts

N/A N/A N/A No receptor present

Fugitive emissions (dust)

Vegetation (see above) Soil contamination, etc. (see above)

Minor Rare Low Dust loading on vegetation is considered Low risk (see above)

Category 6: Mine

dewatering:

Operation of dewatering

pipeline

Seepage Hypersaline water to groundwater

Groundwater and native vegetation within area of influence of seeping or ruptured pipeline

Direct discharge

Groundwater mounding Moderate Possible Moderate The predictive groundwater modelling simulation indicates that localised mounding will occur in the southern and south-eastern parts of WMP’s, however this is likely to be offset by groundwater drawdown around the Cosmos pit.

The Licence Holder has proposed to install additional monitoring/recovery bores around WMP’s to enable early detection of groundwater mounding (proposed trigger level of 6 m) and early implementation of groundwater recovery, if required. This is consistent with the existing dewatering strategy for the overall dewatering operation.

The Delegated Officer has reviewed existing regulatory controls within the existing Licence and considers these to be sufficient for mitigating the risk of groundwater mounding (with WMP’s added to the existing conditions and MB02 being removed as a compliance bore).

Groundwater contamination

Insignificant Possible Low Groundwater quality is poor (hypersaline) with no beneficial users

Dewatering pipeline Rupture of pipeline causing hypersaline discharge to land

Native vegetation adjacent to pipeline alignment

Soil contamination inhibiting vegetation growth and survival

Moderate Possible Moderate The salinity of mine water to be transferred from the mine pit and underground ranges from 90,000 to 300,000 mg/L TDS and is hypersaline. Releases of hypersaline water impact on surface vegetation, salinize soils, increase soil erosion and potentially contaminate local surface and groundwater.

Evidence of environmental impacts from hypersaline water spills have been observed at several mine sites in the Goldfields, where large scale vegetation deaths were evident.

The Licence Holder has proposed controls to prevent pipeline seepage and ruptures, including flow meters and pressure transmitters at both ends of the pipeline, alarms to indicate reduced flow / pressure, laying pipelines in trenches to contain potential spills, constructing sumps at low points and undertaking routine daily inspections.

The Delegated Officer has reviewed existing regulatory controls within the existing Licence and considers these to be sufficient for mitigating the risk of pipeline ruptures (with new dewatering pipeline added to the existing infrastructure conditions).

Licence: L7404/1999/9


Decision

The Delegated Officer has previously assessed the risk of recommencing mine dewatering operations at the Premises (refer to decision report for the existing Licence, dated June 2017) and considers the recommencement of dewatering as an addendum to that risk assessment.

The Delegated Officer considers the construction of new dewatering pipeline and the removal of MB02 will not result in a material change to the overall risk of potential emissions at the Premises, i.e. hypersaline water to groundwater (from seepage through the base of the pond) and to land (from pond overtopping or pipeline rupture), and Conditions 9 – 25 on the existing Licence are sufficient to manage the risk of such emissions.

Groundwater monitoring requirements in the Licence are applicable to the dewatering strategy for the Premises. As dewatering involves discharge to WMPs, groundwater monitoring requirements in the Licence have been removed for bore MB02 in the immediate vicinity of WMPs 6 & 7 because it no longer is suitable to monitor vegetation health and will be replaced by new monitoring bores MB21, MB22, MB23 and MB24. The full monitoring schedule for dewatering operations will be reviewed once dewatering recommences, which will require a separate amendment application.

Amendment history

Table 6 provides the amendment history for L7404/1999/9.

Table 6: Licence amendments

Instrument Issued Amendment

L7404/1999/9 26/11/2015 Licence transferred to Australian Nickel Investments Pty Ltd. Changes made to conditions to reflect the non-operational status. Tenements M36/24 and M36/25 removed from the Premises as they were not owned by ANI. Expiry extended to align with M36/371.

L7404/1999/9 30/06/2017 Licence amendment to authorise recommencement of mine dewatering operations.

L7404/1999/9 28/09/2017 Amendment Notice 1 – construction and operation of WMP9.

L7404/1999/9 21/11/2017 Amendment Notice 2 – temporary reduction in groundwater monitoring requirements during Stage 1 dewatering (this Notice).

L7404/1999/9 13/09/2018 Amendment Notice 3 – construction of new dewatering pipeline from Cosmos to Orleans open pits and removal of MB02 from monitoring requirements.

Licence Holder’s comments

The Licence Holder was provided with the draft Amendment Notice on 6 August 2018 and made no additional comments.

Licence: L7404/1999/9


Amendment 1. The existing Licence is amended by the addition of Figure 3 in Schedule 1 of this

Notice. 2. Table 3 of Condition 5 of the existing Licence is amended by the insertion of the

underlined red text in the following rows:

Table 3: Works infrastructure requirements table

Column 1 Column 2 Column 3

Infrastructure Requirements (design and construction) Site plan reference

Water Management Pond 9

To be constructed in the location shown in Figure 2 of Schedule 1 of this Notice

Pond embankment to be constructed on the surface of the ferricrete

Pond embankment material to be placed in maximum 300 mm loose lift thickness layers and compacted to minimum 95% standard maximum dry density (±2% of optimum moisture content)

Pond embankment to be formed with minimum 2% grade into the basin

Pond to be constructed according to following design criteria:

- Cell A – 275m x 410m (7.8 ha)

- Cell B – 340m x 540m (9.3 ha)

- Cell C – 250m x 480m (9.2 ha)

- Maximum embankment height – 5.6 m

- Embankment crest width – 6.0 m

- Embankment Downstream Slope – 1V:2.5H

- Embankment Upstream Slope – 1V:3H

- Internal Bund Batter Slope – 1V:2.5H

- Maximum pond depth – 5.0 m

- External pond area – 36.0 ha

Upstream face to be lined with a 1.5 mm thick geomembrane liner that is anchored into the existing ferricrete

Riprap as a flood protection measure, on the downstream slope of the embankment to a height of 0.7 m in the flood affected areas (with modelled depth >0.3 m) on the northern, eastern and western embankments

WMP9 as shown in Figure 2 in Schedule 1 of this Notice

Groundwater monitoring bores

Installed to meet the requirements of Minimum Construction Requirements for Water Bores in Australia

Sited in accordance with WQPN #30: Groundwater Monitoring Bores (“Siting of monitoring bores” section)

Surveyed to allow the ground level (to AHD) at each location to be accurately determined

Be screened to permit effective monitoring of depth to groundwater, and effective interception of seepage from the WMP (if required)

Must be installed prior to commencing discharge into

M27, M28, M29, M30, M31 and M32, as shown in Figure 2 in Schedule 1 of this Notice

Licence: L7404/1999/9


Column 1 Column 2 Column 3

Infrastructure Requirements (design and construction) Site plan reference

WMP9

Cosmos to Orleans open pit dewatering pipeline

To be constructed in the location shown in Figure 3 of Schedule 1 of this Notice.

Pipeline to be constructed using 280 mm diameter PE100 PN10 high density polyethylene pipe.

Pipe welding and installation to meet the applicable standards for polyethylene pipe in Australia. (AS/NZS

4130:2003, AS/NZS 4401:2006 and AS/NZS 5065:2005)

Installed pipeline to be hydro-tested prior to commissioning or operation.

Pipeline shown in Figure 3 in schedule 1 of this notice.

3. Table 4 of Condition 9 of the existing Licence is amended by the insertion of the

underlined red text in the following row:

Table 4: Infrastructure and equipment controls table

Column 1 Column 2

Site infrastructure and equipment

Description and operational requirements

Discharge infrastructure

1 Water Management Pond 9

A new pond to be constructed south of the existing WMPs 1 – 5

Embankments are lined with HDPE, floors are unlined to promote seepage to groundwater

A minimum Freeboard (total) of 0.5 m must be maintained at all times in the final cell (Cell C)

Must be inspected daily (whilst operating) for freeboard capacity and integrity and a written log maintained with each inspection signed off by the person who conducted the inspection

2 Cosmos to Orleans open pit dewatering pipeline

Pipeline shall be fitted with telemetry based leak detection system which triggers automatic cut-out and alarm should the pipeline leak or rupture.

Above ground portions of pipeline must be inspected daily (whilst operating) for pipeline integrity.

A written log maintained with each visual inspection signed off by the person who conducted the inspection.

Licence: L7404/1999/9


4. Table 7 of Condition 23 of the Existing Licence is amended by the deletion of the

struck through black text shown below:

Table 7: Groundwater mounding limit

Column 1 Column 2 Column 3 Column 4 Column 5

Monitoring point reference and location

Parameter Groundwater level limit

Units Averaging period

MB02, MB05, MB06, MB07, MB08, MB09, MB10, MB11, MB13, MB14, MB15, MB16, MB17, MB18, MB20, MB21, MB22, MB23, MB24, MB25, MB26, MB27, MB28, MB29, MB30, MB31, MB32

Standing Water Level

≤4 mbgl Spot sample

5. Table 6 of Condition 18 of the Existing Licence is amended by the deletion of the

struck through black text shown below:

Table 6: Groundwater monitoring

Column 1 Column 2 Column 3 Column 4 Column 5 Column 6

Monitoring point and reference location

Parameter Groundwater level action criteria

Units Averaging period

Monitoring frequency (during active dewatering)1

MB02, MB09, MB10, MB11, MB13, MB14 and MB16

Standing Water Level ≤6 mbgl In-field spot sample

Weekly

pH - - Quarterly

Electrical conductivity @ 25°C

- µS/cm Spot sample, laboratory determined

Metals and metalloids: As, Cd, Cr, Co, Cu, Hg, Pb, Ni, Se, Sb, Zn

- mg/L

Note 1: Prior to the commencement of dewatering activities on the Premises, monitoring must be undertaken at least 6-monthly.

Licence: L7404/1999/9


Appendix 1: Key documents

Document title In text ref Availability

1 Licence L7404/1999/9 – Cosmos Nickel Project

L7404/1999/9 accessed at www.dwer.wa.gov.au

2 DER, July 2017. L7404 Licence Amendment – Decision Report

L7404 Decision Report (June 2017)

3 Australian Nickel Investments Pty Ltd, July 2017. Cosmos Nickel Project – Stage 1 Operating Licence – Amendment supporting document

Existing Licence DWER record A1558112

4 Australian Nickel Investments Pty Ltd, Amendment Application dated 25 May 2018 - Cosmos to Orleans pit new dewater pipeline

Application DWER records A1680831 and A1685569

5 Australian Nickel Investments Pty Ltd, Amendment Application dated 25 May 2018 - Cosmos to Orleans pit new dewater pipeline – Amendment supporting document

Attachment 2, 3A, 5 and 6A

DWER records A1685565, A1685566, A1685567 and A1685568

6 Australian Nickel Investments Pty Ltd email dated 14 June 2018 titled Cosmos Nickel Project – Licence (L7404/1999/9) amendment application

Email dated 12 June 2018

DWER record A1700890

7 DER, July 2015. Guidance Statement: Regulatory principles. Department of Environment Regulation, Perth.

DER 2015a accessed at www.dwer.wa.gov.au

8 DER, February 2017. Guidance

Statement: Risk Assessment.

Department of Environment

Regulation, Perth.

DER 2017a

9 DER, February 2017. Guidance Statement: Decision Making. Department of Environment Regulation, Perth.

DER 2017b

http://www.dwer.wa.gov.au/

http://www.dwer.wa.gov.au/

Licence: L7404/1999/9


Schedule 1: Maps

Figure 3: Premises infrastructure

The new dewatering pipeline infrastructure referenced in Table 3 is shown by the blue line in the map below.