Amendment Notice 1 - der.wa.gov.au · This Amendment Notice is the result of an applicant initiated...

Licence: L8532/2011/1 IR-T08 Amendment Notice (Major) template v2.0 (July 2017) 1

Licence Number L8532/2011/1

Licence Holder Saracen Metals Pty Limited

ACN 107 154 727

File Number: DER2014/000885

Premises Kailis Mine

Mining Tenements M37/46, M37/219, M37/564, M37/902, M37/955, M37/986 and L37/221.

LEONORA WA 6438

Date of Amendment 22 August 2017

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: 22 August 2017

Tim Gentle

Manager Licensing – Resource Industries

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

Amendment Notice 1


Definitions and interpretation

Definitions

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

Table 1: Definitions

Term Definition

AACR Annual Audit Compliance Report

ACN Australian Company Number

Applicant Saracen Metals Pty Limited

Category/ Categories/ Cat.

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

CEO means Chief Executive Officer. CEO for the purposes of notification means:

Director General Department Administering Part V, Div.3 of the Environmental Protection Act 1986 Locked Bag 33 Cloisters Square PERTH WA 6850 [email protected]

DER Department of Environment Regulation (former)

(from 1 July 2017 DER is part of the Department of Water and Environmental Regulation – see https://publicsector.wa.gov.au/public-administration/machinery-government/2017-machinery-government-changes for further details)

DWER Department of Water and Environmental Regulation

As of 1 July 2017, the Department of Environment Regulation (DER), the Office of the Environmental Protection Authority (OEPA) and the Department of Water (DoW) amalgamated to form the Department of Water and Environmental Regulation (DWER). DWER was established under section 35 of the Public Sector Management Act 1994 and is responsible for the administration of the Environmental Protection Act 1986 along with other legislation.

Delegated Officer an officer under section 20 of the EP Act

EP Act Environmental Protection Act 1986 (WA)

EP Regulations Environmental Protection Regulations 1987 (WA)

mailto:[email protected]

https://publicsector.wa.gov.au/public-administration/machinery-government/2017-machinery-government-changes

https://publicsector.wa.gov.au/public-administration/machinery-government/2017-machinery-government-changes


km kilometre

Licensee Saracen Metals Pty Ltd

L/s litres per second

mg/L milligram per litre

PEC Priority Ecological Community

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

RIWI Act Rights in Water and Irrigation Act 1914

Saracen Saracen Metals Pty Ltd

TDS Total Dissolved Solids


Amendment Notice

This amendment is made pursuant to section 59 of the EP Act to amend the Licence L8532/2011/1 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 only to an amendment to the approved Category 6 production design/ capacity and addition of Harbour Lights pit for dewater discharge. Relevant Administrative Changes implemented within DER have also been included in this notice.

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

Guidance Statement: Regulatory Principles (July 2015)

Guidance Statement: Setting Conditions (October 2015)

Guidance Statement: Decision Making (February 2017)

Guidance Statement: Risk Assessment (February 2017)

Guidance Statement: Environmental Siting (November 2016)

Guidance Statement: Publication of Annual Audit Compliance Reports (May 2016)

Amendment description

This Amendment Notice is the result of an applicant initiated amendment for an increase to the approved production capacity of category 6 dewatering operations, and removal of conditions relating to the approval of construction of pipelines for dewater discharge to Harbour Lights pit.

Table 2 below outlines the proposed changes to the Licence production or design capacity.

Table 2: Proposed design or production capacity changes

Category Current approved production or design capacity

Proposed approved production or design capacity

6 900,000 tonnes per annual period 1,300,000 tonnes per annual period

Background The Kailis Project area is located approximately 6 km north of Leonora. The mine site consists of two open pits (Kailis pit and Trump pit), a backfilled pit, waste dump and associated mine infrastructure (including ROM pad and a workshop area). Dewater is pumped from the Kailis pit to the Trump pit. On 1 June 2016, the Licensee (Saracen Metals Pty Limited) applied for an amendment to the Licence L8532/2011/1 for construction of a new 4.5 km dewater pipeline from Trump pit to Harbour Lights pit, with an extension of the premises boundary to include Harbour Lights pit (which is owned by St Barbaras Limited). The location of the dewatering route is shown in Figure 1 below. On 30 June 2016, a Licence amendment with conditions requiring construction according to “Section 3.1 of Sarecen (2016) Kailis Gold Project: Kailis to Harbour Lights Dewatering Environmental Management Plan, Document SM-EN-PL-2018 V1, 25 February 2016” was issued. Construction compliance documents were received by DER on 9 December 2016. Licence L8532/2011/1 currently approves discharge of 900,000 tonnes of dewater per annum.


Saracen have applied for this amount to be increased to 1,300,000 tonnes in order to ensure activities remain under the approved Licence amount when taking groundwater seepage back into Kailis pit into account. Water quality Groundwater salinity within the aquifers supplying water accumulating in Kailis pit ranges from 2,800 to 45,000 mg/L TDS with depth (Kailis EMP, 2016). Kailis pit water has been monitored regularly since 2005. The water has been alkaline (pH 7.4 to 8.6), salinity from 16,000 to 23,000 mg/L TDS, and Arsenic from 0.04 to 0.05 mg/L (Rockwater, 2016). Sampling at Trump pit in the 2015/16 period recorded TDS of 9,780 to 14,400 mg/L and Arsenic 0.203 to 0.306 mg/L (AER, 2016). Pre-mining, groundwater salinities at Harbour Lights pit were found to increase with depth from 4,000 to 51,000mg/L TDS. In 2015, Harbour Lights pit was sampled with pH 7.94 to 7.99 and TDS 58,500 to 58,700 mg/L. TDS was almost constant throughout the profile (Rockwater, 2016). Rockwater (2016) concluded therefore that pumping water from Kailis pit to Harbour Lights pit would be expected to increase alkalinity and decrease salinity (which will gradually increase with evapoconcentration) (Rockwater, 2016). Rockwater (2016) also concluded that some water will initially flow out of the pit to partially fill the cone of depression that has formed around the pit, but the pit will continue to be a groundwater sink into the future. Consequently there will be no long-term flow from the pit to groundwater in the surrounding rocks.


Figure 1: Dewatering route K1 (Kailis pit), K2 (Trump pit) and K3 (Harbour Lights pit).


Other approvals

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

Table 3: Relevant approvals

Legislation Number Approval

RIWI Act GWL181982 Abstraction of water

Mining Act 1978 ID59686 Mining Proposal

Amendment history

Table 4 provides the amendment history for L8532/2011/1 prior to this amendment.

Table 4: Amendment history

Instrument Issued Amendment

L8532/2011/1 22/8/2011 New licence for dewatering.

L8532/2011/1 14/04/2016 Licence transfer and amendment to update licence format and premises boundary.

L8532/2011/1 30/06/2016 Licence amendment to add tenements to the Premises boundary and for construction and operation of a new dewatering pipeline from Trump Pit to Harbour Lights pit.

Location and receptors

Table 5 below lists the relevant sensitive land uses in the vicinity of the Prescribed Premises which may be receptors relevant to the proposed amendment.

Table 5: Receptors and distance from activity boundary

Residential and sensitive premises Distance from Prescribed Premises

Residents of Leonora Closest residence to the Kailis central pit mine activities is 5.5 km.

Closest residence to Trump pit is 5 km.

Closest residence to Harbour Lights is approximately 550 m.

Table 6 below lists the relevant environmental receptors in the vicinity of the Prescribed Premises which may be receptors relevant to the proposed amendment.

Table 6: Environmental receptors and distance from activity boundary

Environmental receptors Distance from Prescribed Premises

PEC Approximately 4 km south of Harbour Lights pit

P1 Public Drinking Water Source Area - Leonora Water Reserve

Approximately 5.8 km north of the dewatering pipeline

RIWI Act Goldfields Groundwater Area Premises is located on the Area.


Lake Raeside 5 km south west of the premises

Minor perennial water courses An un-named minor perennial water course intersects the premises, and another is immediately to the south of the premises.

Groundwater aquifers 10 – 20 metres below ground level


Risk assessment

Table 7 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

Table 7: Risk assessment for proposed amendments during operation

Risk Event

Consequence rating

Likelihood rating

Risk Reasoning Source/Activities

Potential emissions

Potential receptors

Potential pathway

Potential adverse impacts

Cat 6

Mine dewatering

(up to 1,300,000 tonnes per

annum)

Discharge of dewater into Harbour Lights pit.

Seepage of water with high concentration of dissolved solids from Harbour Lights pit.

Groundwater - RIWI Act Goldfields Groundwater Area Groundwater within the aquifers supplying water accumulating in Kailis pit ranges with depth from 2,800 to 45,000 mg/L TDS.

Seepage through ground.

Reduced quality of groundwater. Mounding of the water table in the vicinity of the discharge leading to inundation of the root zone of surrounding vegetation.

Minor – minimal off site impacts.

Unlikely - – the risk event will probably not occur in most circumstances given the controls in place.

Medium As outlined in Background information ‘Water quality’ above, Rockwater (2016) concluded that:

Harbour Lights pit water will increase alkalinity and decrease salinity; and

Harbour Lights pit will continue to be a groundwater sink into the future.

Consequently there will be no long-term flow from the pit to groundwater.

(A)

Transport of dewater by pipeline from Kailis pit to Harbour Lights pit.

(Abnormal operation) Release of dewater due to pipeline infrastructure failure, rupture or leak. Dewater alkaline (pH7.4

Native vegetation located on the premises and in the local vicinity where in the flow path. The closest PEC is 4 km south of the premises.

Ground – along discharge path

Contamination of surrounding soils and creeks with dissolved solids from saline water - causing vegetation stress of death with vegetation in the flow path.

Moderate – mid level on-site impacts and low level off site impacts

Unlikely – the risk event will probably not occur in most circumstances given the controls in place.

Medium Controls in place:

Dewater pipeline is bunded along the entire length apart from where it is buried under three road crossings and where it crosses a creek line.

Breather valves have


– 8.5) salinity ranging from 16,000 to 23,000 mg/L TDS, and arsenic concentration approximately 0.04 to 0.05 mg/L.

Surface water – the pipeline crosses an ephemeral creek. premises, and another creek is located immediately to the south of the premises.

been installed intermittently at high points to release air.

Telemetry is fitted on the pipeline from Deep South to the Safari pit. The telemetry master system will shut off the pump if a significant variation in flow is detected.

Daily inspections are undertaken every 12 hours.

Dewater flow rate remains the same and Saracen have confirmed bunding can contain discharge of a 24 hour period (Email, 24/06/2016).


Decision

Category 6 Approved production or design capacity

Given the risk assessment as outlined in Table 7, the Delegated Officer has determined that the risk of discharge of up to 1,300,000 tonnes dewater per annum is ‘medium’. The approved premises production or design capacity is increased to 1,300,000 tonnes per annual period.

Transport of 1,300,000 tonnes dewater per annum by pipeline to Harbour Lights pit The Licensee has confirmed that pipeline bunding to Harbour Lights pit has the capacity to contain a spill over 24 hours duration (email, 24/06/2016). The Delegated Officer considers the risk of pipeline rupture or leaks is ‘medium’ as outlined in Table 7. The Delegated Officer has considered the Licensee’s controls as outlined in Table 7 and has determined that current conditions 1.2.1 and 1.2.2 which require: telemetry and pressure sensors, automatic cutouts or secondary containment sufficient to inspection periods; and daily visual inspection of the dewater pipeline and pump stations, remain sufficient to manage the medium risk associated with of transportation of up to 1,300,000 tonnes dewater per annum by pipeline to Harbour Lights pit. Therefore conditions 1.2.1 and 1.2.2 remain unchanged. Dewater discharge points Given the conclusions of Rockwater (2016) as outlined in the Background section and Table 7, the Delegated Officer considers the risk of discharge of up to 1,300,000 tonnes dewater per annum to the additional discharge point at Harbour Lights pit is ‘medium’. The Delegated Officer has determined that Harbour Lights pit will be an approved dewater discharge point and is added to Table 2.2.1. Monitoring The Delegated Officer considers that the monitoring parameters and frequency required by Licence condition 3.2.1 can adequately verify the conclusions of Rockwater (2016) as described in the Background section and Table 7 above. Harbour Lights pit is added as a monitoring point to Table 3.2.1. Pipeline construction conditions Condition 1.2.2 requires construction of the dewater pipeline in accordance with Section 3.1 of Kailis EMP, 2016. Construction compliance documents were received by DER on 9 December 2017 as required by conditions 4.2.4 and 4.2.5. The Delegated Officer considers these conditions have been met and are removed. Administrative changes

Definitions in the Licence have been amended in accordance with administrative changes associated with the formation of DWER.

The AACR Proforma in Schedule 2 is removed in accordance with Guidance Statement: Publication of Annual Audit Compliance Reports (May 2016). AACR forms are available for download from the DWER website.

Licensee’s comments

The Licensee was provided with the draft Amendment Notice on 7 August 2017. Comments received from the Licence Holder have been considered by the Delegated Officer as shown in Appendix 2.


Amendment 1. The licence is amended by the deletion of the text shown in strikethrough below and the insertion

of the text shown in bold underline below in the Prescribed premises category table on page 1 of the Licence:

Category number

Category description Category production or design capacity

Approved Premises production or design capacity

6 Mine dewatering: premises on which water is extracted and discharged into the environment to allow mining of ore.

50 000 tonnes or more per year

900,000 1,300,000 tonnes

per annual period

2. Definitions of the Licence is amended by the deletion of the text shown in strikethrough

below. ‘CEO’ means Chief Executive Officer of the Department of Environment Regulation;

‘CEO’ for the purpose of correspondence means;

Chief Executive Officer Department Administering the Environmental Protection Act 1986 Locked Bag 33 CLOISTERS SQUARE WA 6850

Email: [email protected];

3. Definitions of the Licence is amended by the addition of the following text shown in bold

underline below:

‘CEO’ means 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]

4. Condition 2.2.1 of the Licence is amended by the deletion of the text shown shown in

strikethrough below and the insertion of the text shown in bold underline below:

2.1.1 The Licensee shall ensure that where waste is emitted to groundwater at the emission points and from the extraction sources in Table 2.1.1, as identified on the map of emission points Premises map in Schedule 1, it is done so in accordance with the conditions of this Licence.

Table 2.1.1: Emission points to surface water groundwater

Emission point reference

Emission point reference on Map of emission points

Description Extraction source including abatement

Kailis Pit K1 Open pit. Source of mine dewater

Mine dewater N/A

Trump Pit K2 Open pit. Dewater holding pit.

Mine dewater

Kailis Pit (K1)

Harbour Pit K3 Open pit. Dewater final discharge point.

Trump Pit (K2)




5. The Licence is amended by the deletion of the text in strikethrough below and the insertion

of the text shown in bold underline below:

2.2 Point source emissions to surface water groundwater.

6. Condition 3.2.1 of the Licence is amended by the deletion of the text shown in

strikethrough below and the insertion of the text shown in bold underline below:

3.2.1 The Licensee shall undertake the monitoring in Table 3.2.1 according to the specifications in that table.

Table 3.2.1: Monitoring of point source emissions to surface ground water

Emission Monitoring point reference

Parameter Units

Frequency

K1 (Kailis Pit) K2 (Trump Pit) K3 (Harbour Lights pit)

Volume kL Monthly cumulative

pH N/A

Quarterly

Total Dissolved Solids (TDS) calcium (Ca) arsenic (As) magnesium (Mg) nickel (Ni) sulphate (SO4) carbonate (CO3)

mg/L

7. The Licence is amended by the deletion of the following conditions shown in strikethrough below:

1.2.3 The Licensee shall construct the dewatering pipeline in accordance with the documentation detailed in Table 1.2.2:

Table 1.2.2: Construction Requirements1

Document Parts Date of Document

Section 3.1 of Saracen (2016) Kailis Gold Project: Kailis to Harbour Lights Dewatering Environmental Management Plan, Document SM-EN-PL-2018 V1

All 25 February 2016

Note 1: Where the details and commitments of the documents listed in condition 1.2.3 are inconsistent with any other condition of this Licence, the conditions of this Licence shall prevail.

4.2.4 The Licensee shall submit a compliance document to the CEO following the construction of the works

as listed in Table 1.2.2. 4.2.5 The compliance document shall:

(a) certify that the works were constructed in accordance with the conditions of this Licence; (b) be signed by a person authorised to represent the Licence Holder and contain the printed

name and position of that person within the company.

8. The Licence is amended by the deletion of the Premises map and text shown in strikethrough below and the insertion of the Premises map and text shown in bold underline below.

The Premises is shown in the map below. The green line depicts the Premises boundary.


In the Premises map below, the green line depicts the premises boundary, and the discharge and monitoring points defined in Tables 2.1.1 and 3.2.1 are located.


9. The Licence is amended by the deletion of the Schedule 2 Reporting and notification form as shown in strike through text below:

ANNUAL AUDIT COMPLIANCE REPORT PROFORMA

SECTION A LICENCE DETAILS

Licence Number:

Licence File Number:

Company Name: Trading as:

ABN:

Reporting period: ___________________ to ___________________

i) STATEMENT OF COMPLIANCE WITH LICENCE CONDITIONS

1. Were all conditions of the Licence complied with within the reporting period? (please tick the appropriate box)

Yes □ Please proceed to Section C

No □ Please proceed to Section B Each page must be initialled by the person(s) who signs Section C of this Annual Audit Compliance Report (AACR). Initial:


SECTION B DETAILS OF NON-COMPLIANCE WITH LICENCE CONDITION. Please use a separate page for each Licence condition that was not complied with.

a) Licence condition not complied with:

ii) b) Date(s) when the non compliance occurred, if applicable:

c) Was this non compliance reported to DER?:

Yes Reported to DER verbally

Date ___________

Reported to DER in writing

Date ___________

No

d) Has DER taken, or finalised any action in relation to the non compliance?:

e) Summary of particulars of the non compliance, and what was the environmental impact:

f) If relevant, the precise location where the non compliance occurred (attach map or diagram):

g) Cause of non compliance:

h) Action taken, or that will be taken to mitigate any adverse effects of the non compliance:

i) Action taken or that will be taken to prevent recurrence of the non compliance:

Each page must be initialled by the person(s) who signs Section C of this AACR Initial:


SECTION C SIGNATURE AND CERTIFICATION This Annual Audit Compliance Report (AACR) may only be signed by a person(s) with legal authority to sign it. The ways in which the AACR must be signed and certified, and the people who may sign the statement, are set out below.

iii) Please tick the box next to the category that describes how this AACR is being signed. If you are uncertain about who is entitled to sign or which category to tick, please contact the licensing officer for your premises.

If the licence holder is The Annual Audit Compliance Report must be signed and certified:

An individual

□

□

by the individual licence holder, or

by a person approved in writing by the Chief Executive Officer of the Department of Environment Regulation to sign on the licensee's behalf.

A firm or other unincorporated company

□

□

by the principal executive officer of the licensee; or

by a person with authority to sign on the licensee's behalf who is approved in writing by the Chief Executive Officer of the Department of Environment Regulation.

A corporation

□

□

□

□

□

□

by affixing the common seal of the licensee in accordance with the Corporations Act 2001; or

by two directors of the licensee; or

by a director and a company secretary of the licensee, or

if the licensee is a proprietary company that has a sole director who is also the sole company secretary – by that director, or



A public authority

(other than a local government)

□

□



a local government

□

□

by the chief executive officer of the licensee; or

by affixing the seal of the local government.

It is an offence under section 112 of the Environmental Protection Act 1986 for a person to give information on this form that to their knowledge is false or misleading in a material particular. There is a maximum penalty of $50,000 for an individual or body corporate.

I/We declare that the information in this annual audit compliance report is correct and not false or misleading in a material particular.

SIGNATURE: ________________________

NAME: (printed) _____________________________

POSITION: __________________________

DATE: ______/_______/________________

SIGNATURE: ________________________

NAME: (printed) _____________________________

POSITION: __________________________

DATE: ______/_______/________________

SEAL (if signing under seal


Appendix 1: Key documents

Document title In text ref Availability

1 Licence L8532/2011/1 L8532/2011/1 accessed at www.dwer.wa.gov.au

2 Email: Subject: Re: Emailing – L8532

Saracen Kailis Decision Document –

June 2016, sent from Tim Pavlos

(Saracen) 24/06/2016

Email,

24/06/2016 DWER records (A110993)

3 Kailis Gold Project Assessment of

Impact of Water Disposal to Harbour

Lights Pit, Rockwater, March 2016.

Rockwater,

2016 DWER records (A1465814)

4 Kailis Gold Project: Kailis to Harbour

Lights Dewatering Environmental

Management Plan, Document SM-

EN-PL-2018 V1, Saracen, 25

February 2016.

Kailis EMP,

2016

DWER records (A1464688)

5 Guidance Statement: Regulatory

principles. Department of Environment

Regulation, Perth. July 2015.

-

accessed at www.dwer.wa.gov.au

6 Guidance Statement: Setting conditions. Department of Environment Regulation, Perth, October 2015

-

7 Guidance Statement: Risk

Assessments. Department of

Environment Regulation, Perth,

February 2017.

-

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

-

9 Guidance Statement: Publication of Annual Audit Compliance Reports Department of Environment Regulation, Perth, May 2016

10 Kailis Operations Annual Environmental Report 2016

AER, 2016 DWER records (A1188023)

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

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


Appendix 2: Summary of Licensee comments

The Licensee was provided with the draft Amendment Notice on 7 August 2017 for review and comment. The Licence Holder responded on 11 August 2017 waiving the remaining comment period. No comments were submitted on the draft Amendment Notice.

Condition Summary of Licence Holder comment DWER response

N/A No comments provided on the draft Amendment Notice N/A

Amendment Notice 1 - der.wa.gov.au · This Amendment Notice is the result of an applicant initiated...

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