annuall audit comp i iance report form - der.wa.gov.au · wodgina lithium ore project | aacr &...

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Wodgina Lithium Ore Project | AACR & AER 2017 2018 - Annual Audit Compliance Report / Annual Environmental Report Wodgina Lithium Pty Ltd Wodgina Lithium Project - ISSUED OCTOBER 2018 Page | 49 m lntemaoonal Government of Western Austra lia Department of Water and Envlronmental Regulation Annua ll Audit Comp I iance Report Form En vironmental Protection Act 1986, Part V Licence holder: Wodgrna Lilhium Pty Ltd Trading as: Same as Above ACN: 611488 932 1 Sleat Rd Register ed address: APPLECROSS WA 6153 Reporting period: 01/07/2017 to 30/06/2018 Section B - Statement of Compliance with Licence Conditions Did you comply with all of your li cence conditions during the reporting period? (please tick the appropriate box) - pfease complete: section C; section D if required; an.d si~n the declaration rn Section F. ili11 No - please complet e: section C; section D if required; section E; and sign the declaration at Section F. Section C- Statement of Actual Production Provide the actual production quantity for this reportinQ period. SupportinQ documentation is to be attached. Prescribed Premises Category Actual Production Quantity Category ;;5 - Processing or beneficiation of 4,029,239 t metall ic or non-metallic ore Category ;;54 - Sewage Facility 105m 3 /day Category ;;89 - Putrescible Landfill Site 1,927 t .,- 1':!:v2..0

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Wodgina Lithium Ore Project | AACR & AER

2017 – 2018 - Annual Audit Compliance Report / Annual Environmental Report Wodgina Lithium Pty Ltd – Wodgina Lithium Project - ISSUED OCTOBER 2018

Page | 49

u~~ m lntemaoonal

Government of Western Australia Department of Water and Envlronmental Regulation

Annuall Audit Comp I iance Report Form Environmental Protection Act 1986, Part V

Licence holder: Wodgrna Lilhium Pty Ltd

Trading as: Same as Above

ACN: 611488 932

1 Sleat Rd Registered address: APPLECROSS WA 6153

Reporting period: 01/07/2017 to 30/06/2018

Section B - Statement of Compliance with Licence Conditions

Did you comply with all of your licence conditions during the reporting period? (please tick the appropriate box)

□Yes - pfease complete: • section C; • section D if required; an.d • si~n the declaration rn Section F.

ili11 No - please complete: • section C; • section D if required; • section E; and • sign the declaration at Section F.

Section C- Statement of Actual Production

Provide the actual production quantity for this reportinQ period. SupportinQ documentation is to be attached.

Prescribed Premises Category Actual Production Quantity

Category ;;5 - Processing or beneficiation of 4,029,239 t metall ic or non-metallic ore

Category ;;54 - Sewage Facility 105 m3/day

Category ;;89 - Putrescible Landfill Site 1,927 t

.,- 1':!:v2..0

Wodgina Lithium Ore Project | AACR & AER

2017 – 2018 - Annual Audit Compliance Report / Annual Environmental Report Wodgina Lithium Pty Ltd – Wodgina Lithium Project - ISSUED OCTOBER 2018

Page | 50

u~~ m lntemaoonal

Department of Water and Environmental Regulation

Section D - Statement of Actual Part 2 Waste Discharge Quantity

Provide the actual Part 2 waste discharqe quantity for this reportinq period. Supportinq documentation is to be attached.

Prescribed Premises Category Actual Part 2 Waste Discharge Quant fty

Waste Type Units Di~ ge

Biologjcal Oxygen Demand (BOD) kg/day 2.922

Category ;;54 - Sewage Facility To tal Suspended So lids (TSS) kg/day 8.997

To tal N'it rogen (TN) kg/day L467

Pl105phorus kg/day 0.740

E.Coli Bacteria M1/day 0.644

2

Annual Audit Compliance Report Fann

Wodgina Lithium Ore Project | AACR & AER

2017 – 2018 - Annual Audit Compliance Report / Annual Environmental Report Wodgina Lithium Pty Ltd – Wodgina Lithium Project - ISSUED OCTOBER 2018

Page | 51

u~~ m lntemaoonal

Department of Water and Environmental Regulation

Section E - Details of Non-Compliance with Licence Condition

Please use a separate pa!'.le for each condition with which the licence holder was non-compliant at a time during the reporting period.

Condilion no: I 1.3.6 I Date(s) of non-

comvliance: I H/0612018

Details of non-complianoe:

Facultative Ponds: A minimum top embankment freeboard of 350mm was believed to not be maintained at all times folloVlling Environmental Field Report 06608

What was the actual (or suspected) environmental impact of the non-compliance?

NOTE - please attach maps or diagrams to provide insight into the precise location of w1lere the non-compliance took place.

At the time of reporting through a Section 72 - Waste discharge to Land, it was considered at the time that the potential for ham1 to the surrounding environment due to the transfer of treated waste water was 'NIL' to 'negligible'.

Cause (or suspected cause) of non-compliance:

Following heavy ra infall (85mm/48hrs) at Wodgina over the 6th and 7th June 2018, the WWTF ponds approached maximum freeboard.

Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the non-compliance: In order to ensure the pond freeboard was not exoeeded, excess treated waste water (1,803mJ)

was transferred via water cart to the Dra!'.lon Pit between 9-2 1 June 2018. Draqon Pit is not a prescribed premise under licence L4328I1989/ 10 at the time of the event

The evaporation ponds have been scarified, and the eroded windrows repaired to promote infi ltration and ensure a free board of 200mm is maintained (compliance against condition 1.3.6) even at maximum capacity. In an attempt to promote increas-ed digestion and water quality, WLPL also began aeratingi the 6 facultative ponds.

Was this non-compliance previously reported to DW ER?

[81 Yes, and

[8J Reported to DWER verba[ly Date: 810612018

[81 Reported to DWER in wriling Date: 26 / 06, / 2018

3

Annual Audit Compliance Report Fonn

Wodgina Lithium Ore Project | AACR & AER

2017 – 2018 - Annual Audit Compliance Report / Annual Environmental Report Wodgina Lithium Pty Ltd – Wodgina Lithium Project - ISSUED OCTOBER 2018

Page | 52

u~~ m lntemaoonal

Department of Water and Envtmnmental Regulation

Section E - Details of No,n-Compliance with Licence Condi1ion

Please use a separate paqe for each condition with which the licence holder was non-compliant at a time during the reporting period.

Condition no: I 1.3.7 (f) I Date(s) of non-

comoliance: I 8/06/2018

Details of non-compliance:

As the result of a rainfall event that did not constitute an 'extreme rainfall event' (greater than 1 in 10 year event of 72 hours duration) , discharge from the ,evaporation ponds was transferred via water cart to 1he Draqon Pit (672966.126mE / 7654482.583mN) between 9-21 June 2018. Draqon Pit is not a prescribed premise under licence L4328/1989/10. A lthouqh 1he discharqe was not ified to DWER under a Section 72, inspectors noted durinq Environmental Field Report 06608, that this was in contravention to the licence.

What was the actual (or suspected) environmental impact of the non-compliance?

NOTE - please attach maps or diagrams to provide insight into the precise location of where the non-compliance took place.

At the t ime of reporting through a Section 72 - Waste discharge to Land, it was considered at the time that 1he potential for harm to the sunroundinq environment due to the transfer of treated waste water was 'NIL' to 'negligible'.

Cause (or suspected cause) of non-compliance:

Following heavy ra infall (85mm/48hrs) at Wodgina over the 6th and 7th June 2018

Action taken to mitiqate any adverse effects of non-compliance and prevent recurrence of the non-comoliance: In order to minimise the effects of the recent rainfall event, WLPL used multip le licenced

contractors to remove approximately 800m3 of raw sewaqe from the facultative ponds to be processed off site by a licenced contra.ctor. This was carried out to further minimise discharqe relatinq to cond ition 1.3.7, in addition to also achievinq condition 1.3.6.

Upqrade of tile existinq system to fu ll evaporation (no infiltration) based on the enqineerinq v,rorks completed by Aerison

a. This will involve the construction of 2 additional facultative ponds, (FAC #7 & 8), and 2 additional Evaporation ponds (Evap #5 and 6) which will botil be lined. By carrying out this work, W LPL will ensure adequate capacity of the system is achieved and maintained, and that the required freeboard is met. Related to conditions 1.3.6, whilst also ensurinq the treatment p lant can maintain and comply with condition 1.3.7.

b. Wrll involve 1he sequential draininq, dryinq and lininq of existinq evaporation ponds 1 throuqh

4

Annual Audit Comp'liance Report Form

Wodgina Lithium Ore Project | AACR & AER

2017 – 2018 - Annual Audit Compliance Report / Annual Environmental Report Wodgina Lithium Pty Ltd – Wodgina Lithium Project - ISSUED OCTOBER 2018

Page | 53

u~~ m lntemaoonal

Department of Water a11d Environmenta l Regu lation

Was this non-compliance previously reported to DWER?

l8l Yes, and

!SJ Reported to DW ER verbally Date: 8 / 06 / 2018

!SJ Reported to DW ER in writing Date: 26/06/2018

5

Annual Audit Compliance Report Form

Wodgina Lithium Ore Project | AACR & AER

2017 – 2018 - Annual Audit Compliance Report / Annual Environmental Report Wodgina Lithium Pty Ltd – Wodgina Lithium Project - ISSUED OCTOBER 2018

Page | 54

u~~ m lntemaoonal

Department of Water and Envrmnmenta Regulation

Section E - Details of Non-Compliance with Licence Condition

Please use a separate paqe for each condition with which the licence holder was non-compliant at a time during the reporting period.

Condition no: I 1.3.9 I Date(s) ofnon-comoliance: I 13 / (lfi / 2018

De-tails of non-compliance:

Failure to undertake inspections as detailed in Table1 .3.4; Daily

What was the actual (or suspected) environmental impact of the non-compliance?

NOTE - please attach maps or diagrams to provide insight into the precise location of where the nan-compliance took place

The failure to comply with condition 1.3.9 may have led to the events fol!owinq, which required a section 72 rmtification, however this cannot be confirmed. Thus, environmental impact is believed to be 'NIL' to 'negligib le'

Cause (or suspected cause) of non-compliance:

Failure in maintenance records and communication of licence conditions

Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the non-compliance: Daily inspection sheets have been qenerated for the WWTF and are currently in use as per

licence condition 1.3.9.

Was this non-compliance previously reported to DWER?

l8l Yes, and

□ Reported to DW ER verbally Date: I I

l8l Reported to DW ER in wrrung Date: 4 /07 /2018

5

Annual Audit Compl iance Report Fann

Wodgina Lithium Ore Project | AACR & AER

2017 – 2018 - Annual Audit Compliance Report / Annual Environmental Report Wodgina Lithium Pty Ltd – Wodgina Lithium Project - ISSUED OCTOBER 2018

Page | 55

u~~ m lntemaoonal

Department of Water and Environmental Regulation

Section F - Declaration

INVe declare that the infom1ation in this Annual Audit Compliance Report is true and correct and is not false or misleadinq in a material particular1

• I/We consent to the Annual Audit Compliance Report beinq published on the Department of Water and Environmental Requlation's (DWER) website.

Signature2:

Name: (printed)

Position:

Date:

Seal (if siqninq under seal):

SIMON PIG'oZZO

ENVIRONMENT AL ADVISOR

26 / 1012018

Signature:

Name: (printed)

Position:

Date:

1 It is an offence under section 112 of the Enwro.nmenta/Ptotecoon Act 1986 for a person to ,giYe in·onnation on this fOflTl that

to their knowledge is false or mis lead ing, in a materi prulicular.

'AACRs can only be signed by the licence holder o r an author,sed person with the leg"I authority to sig on beha of the licence holder.

Annual Audit Compliance Report Form 7