KCGM 2016 Annual Audit Fimiston I and Fimiston II …...KCGM 2016 Annual Audit Fimiston I and...

KCGM 2016 Annual Audit Fimiston I and Fimiston II Tailings Storage Facilities Seepage and Groundwater Management Plan

Report Status

Revision Date Signature

Rev A (Draft) December 2016

Rev 0 (Final) December 2016



Big Dog Hydrogeology

KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 2

List of Acronyms AER Annual Environmental Report

BDH Big Dog Hydrogeology Pty Ltd

CN Cyanide

CRG Community Reference Group

DER Department of Environmental Regulation

DOW Department of Water

EC Electrical Conductivity

Free CN Free cyanide

KCGM Kalgoorlie Consolidated Gold Mines Pty Ltd

LFA Landscape Function Analysis

FSGMP Fimiston Seepage and Groundwater Management Plan

KSGMP Kaltails Seepage and Groundwater Management Plan

Q1 Quarter 1, January to March

Q2 Quarter 2, April to June

SGMP Seepage and Groundwater Management Plan

TDS Total Dissolved Solids

Total CN Total cyanide

TSF Tailings Storage Facility

WADCN Weak Acid Dissociable Cyanide



TABLE OF CONTENTS

List of Acronyms ........................................................................................................................................... 2

1. Introduction............................................................................................................................................ 5

1.1 Background .................................................................................................................................... 5

1.2 Fimiston Seepage and Groundwater Management Plan ................................................................. 5

1.3 Scope of audit and relevant reference documents .......................................................................... 6

1.4 CRG consultation and review ......................................................................................................... 7

1.5 Structure of audit report .................................................................................................................. 8

2. Detailed compliance assessment .......................................................................................................... 9

2.1 Background .................................................................................................................................... 9

2.2 Data collection compliance ........................................................................................................... 10

2.2.1 Groundwater depths .............................................................................................................. 10

2.2.2 Groundwater chemistry ......................................................................................................... 10

2.2.3 Groundwater production ........................................................................................................ 12

2.2.4 Vegetation monitoring............................................................................................................ 12

2.3 Seepage management compliance .............................................................................................. 14

2.3.1 Groundwater depth targets .................................................................................................... 14

2.3.2 Bore construction .................................................................................................................. 15

2.3.3 Decant pond area targets ...................................................................................................... 15

2.3.4 Weak Acid Dissociable Cyanide concentration in groundwater targets .................................. 16

2.3.5 Production bore operation targets ......................................................................................... 16

2.3.6 Triggered actions ................................................................................................................... 17

2.4 Reporting compliance ................................................................................................................... 17

3. Review of FSGMP objectives and management requirements ............................................................ 19

3.1 Background .................................................................................................................................. 19

3.2 FSGMP objectives ........................................................................................................................ 19

3.2.1 Summary of objectives .......................................................................................................... 19

3.2.2 Auditor assessment of objectives .......................................................................................... 19

3.3 Groundwater depths ..................................................................................................................... 20

3.3.1 Summary of groundwater depth monitoring and management ............................................... 20

3.3.2 Auditor assessment of groundwater depth monitoring and management ............................... 20

3.4 Groundwater chemistry ................................................................................................................ 21

3.4.1 Summary of groundwater chemistry monitoring and management ........................................ 21

3.4.2 Auditor assessment of groundwater chemistry monitoring and management ........................ 21

3.5 Groundwater recovery .................................................................................................................. 22



3.5.1 Summary of groundwater recovery ........................................................................................ 22

3.5.2 Auditor assessment of groundwater recovery ........................................................................ 22

3.6 Vegetation monitoring and management ...................................................................................... 23

3.6.1 Summary of vegetation monitoring and management ............................................................ 23

3.6.2 Auditor assessment of vegetation monitoring and management ............................................ 23

3.7 Decant pond management ........................................................................................................... 23

3.7.1 Summary of decant pond management ................................................................................. 23

3.7.2 Auditor assessment of decant pond management ................................................................. 23

4. Assessment of progress towards objectives ........................................................................................ 24

4.1 Background .................................................................................................................................. 24

4.2 Progress towards objectives ......................................................................................................... 24

5. Conclusions and recommendations ..................................................................................................... 26

5.1 Conclusions .................................................................................................................................. 26

5.2 Recommendations ....................................................................................................................... 26

References ................................................................................................................................................. 28

List of Figures ............................................................................................................................................. 29

Appendix A Certification of auditor independence

Appendix B Community Reference Group responses

Appendix C Detailed results of compliance assessment



1. Introduction

1.1 Background Kalgoorlie Consolidated Gold Mines Pty Ltd (KCGM) manages the mining and ore processing operations at

the Fimiston Open Pit (commonly known as the Kalgoorlie Super Pit) and the Mt Charlotte underground mine,

located adjacent to the city of Kalgoorlie Boulder in the Eastern Goldfields Region of Western Australia

(Figure 1). KCGM is the management company for the mining operations, and is owned by Newmont

Australia Pty Ltd and Barrick Gold of Australia Limited.

Gold ore from the KCGM mining operations is processed through the Fimiston Processing Plant, located to

the east of the Fimiston Open Pit, as indicated in Figure 1. Process water used in the Fimiston Processing

Plant is predominantly drawn from borefields drawing highly saline water from local and regional groundwater

systems. A portion of the process water used in the mill, along with all tailings generated during ore

processing are currently directed to two tailings storage facilities (TSFs), comprising the Fimiston II TSF and

the Kaltails TSF, as identified in Figure 1. Tailings deposition to the Fimiston I TSF ceased in July 2013.

A shallow groundwater system is present below each of the three TSFs, and during the operating periods for

the facilities, seepage from the TSFs has resulted in changes in groundwater elevations and groundwater

chemistry in the shallow groundwater systems. Groundwater in the shallow system is naturally saline, and

if groundwater elevations were to be allowed to rise into the root zone of vegetation there would be potential

for impacts on vegetation health. Conditions within the shallow groundwater system are managed by the

operation of the Seepage and Groundwater Management Plans (SGMPs).

1.2 Fimiston Seepage and Groundwater Management Plan KCGM have prepared and implemented a SGMP for the Fimiston I and Fimiston II TSFs, referred to as the

Fimiston Seepage and Groundwater Management Plan (FSGMP). The plan was first released in September

2005, and has been audited on an annual basis since implementation. Implementation of the FSGMP is a

requirement of the licence issued by the Department of Environmental Regulation (DER) which governs the

operation of the KCGM facilities. KCGM regularly update the FSGMP to take account of changes in licence

conditions, comments made during annual audits, comments from DER, and the results of reviews of the

performance of the plan. The current version of the FSGMP was issued by KCGM in October 2014 (KCGM,

2014).

Implementation of the plan has included the installation and operation of groundwater production bores and

seepage interception trenches around the Fimiston I and Fimiston II TSFs, and the construction and

management of groundwater monitoring bores installed around the TSFs and within the surrounding

catchment. Collectively these are referred to as the Eastern Borefield, and the relevant facilities are shown

in Figures 2, 3 and 4. The FSGMP also includes the monitoring of vegetation health around the TSFs to

ensure that groundwater conditions are being managed to prevent impacts.



Requirements for the environmental management of the KCGM Fimiston Processing Plant and tailings

storage operations are specified by DER in Licence L6420. This licence was first issued in October 1996

and has been modified and re-issued on multiple occasions since that time. A condition of that licence

requires KCGM to undertake an annual audit of the FSGMP. Specific requirements of the audit include, but

are not limited to:

• Review KCGM progress towards existing targets and milestones in the FSGMP.

• Review whether the objectives of the FSGMP are being achieved, and if these objectives are still

appropriate.

• Include a statement of the independence of the auditor.

This report presents the 2016 annual audit of the KCGM FSGMP. Appendix A provides the required

statement of independence of the auditor.

KCGM has also implemented a SGMP for the Kaltails TSF (the Kaltails Seepage and Groundwater

Management Plan, or KSGMP). The annual audit of the KSGMP is presented in a separate report (BDH,

2016a).

1.3 Scope of audit and relevant reference documents In addition to the specific requirements for the audit defined in the DER licence and discussed in Section 1.2,

a key component of any audit is an assessment of compliance against all requirements defined in the audited

document.

Previous audits of the FSGMP were undertaken on 12 months of monitoring data collected between 1 July

and 30 June, and were required to be submitted to DER by 31 August. The current version of DER Licence

L6420 has been amended, and the annual audit is no longer required to be submitted by 31 August, and is

now required to be submitted with the Annual Environmental Report (AER), due by 31 March.

The 2015 annual audit covered the transition period between the two different reporting dates, and was

undertaken on monitoring data collected for the 15 month period from 1 July 2014 to 30 September 2015.

The September cut-off for monitoring data was selected to allow time to circulate the draft audit results around

the Community Reference Group (CRG), and to incorporate their comments into the final version of the

document to be submitted with the AER by 31 March. The current audit returns to a 12 month monitoring

period, and has been undertaken on the 12 months of monitoring data collected from 1 October 2015 to 30

September 2016.

During the current 12 month audit period, there have been two versions of DER Licence L6420 which have

regulated the KCGM operations as follows:

1. On 18 September 2015, Licence L6420/1988/14 was re-issued with minor changes, and was valid

until 28 September 2019. The portion of the audited monitoring period covered by this version of the

DER licence was October 2015 to April 2016.

2. On 8 April, 2016, Licence L6420/1988/14 was re-issued with minor changes, but with the same licence

number, and was valid until 28 September, 2025. The portion of the audited monitoring period

covered by this version of the DER licence was April 2016 to September 2016.

3. These two versions of the DER licence have the same reference number and have very similar

conditions, and are referred to collectively as L6420/1988/14 in this audit report. In any case where

they need to be referred to separately, the licence version prior to April 2016 is referred to as

L6420/1988/14A, and the version following April 2016 is referred to as L6420/1988/14B.



Condition 1.3.6 of licence L6420/1988/14 requires KCGM to undertake an audit of the FGSMP each year.

The licence defines the FSGMP to mean “the document “Kalgoorlie Consolidated Gold Mines Fimiston

Operations Seepage and Groundwater Management Plan” dated 26 September 2008, as submitted to the

CEO, and including annual revisions of that document as approved by the CEO.” KCGM re-issued the

FSGMP most recently in October 2014 and submitted it to DER for approval (KCGM, 2014). The document

against which KCGM have been assessed in the current audit is therefore the 2014 version of the FSGMP,

referred to as the 2014 FSGMP throughout this document.

In addition to the requirements set within the 2014 FSGMP, the 2014 FSGMP makes reference to external

documents to be complied with, and as the FSGMP audit covers all conditions in the FSGMP, the conditions

defined in these external documents have also been audited as follows:

1. The FSGMP refers to the DER licence, which as described above includes two versions of the licence

during the audit period, and the conditions described in both these licences have been assessed

during the audit.

2. The FSGMP refers to compliance with the Department of Water (DOW) licence. In addition to being

governed by the DER licence, operation of the Eastern Borefield is governed by Licence to Take

Water GWL66252(7) issued by DOW. The conditions described in the DOW licence have therefore

been assessed during the current audit.

3. One condition included in the DOW licence is that the Eastern Borefield must be operated in

accordance with the current Eastern Borefield Operating Strategy (KCGM, 2013). The conditions

described in the Operating Strategy have therefore been assessed in the current audit.

The scope for the compliance aspect of the 2016 audit of the FSGMP was therefore defined to be an

assessment of monitoring data collected, management actions undertaken, and reporting submitted by

KCGM for the Eastern Borefield in the period 1 October 2015 to 30 September 2016. Each of these

components has been assessed against the conditions defined collectively in:

1. The 2014 FSGMP (KCGM, 2014).

2. The two versions of DER licence L6420 applying in the period (L6420/1988/14A and

L6420/1988/14B).

3. DOW Licence to Take Water [GWL66252(7)].

4. The Eastern Borefield Operating Strategy (KCGM, 2013).

In each case, the compliance aspect of the audit has investigated whether KCGM obligations for collecting

and reporting monitoring data, and for managing groundwater conditions have been met. The audit has not

included a re-interpretation of the monitoring data collected in the audit period. However, monitoring data for

some of the audit period were plotted and interpreted in quarterly groundwater reviews submitted to DER,

and in a review of monitoring data collected up to December 2015 submitted to DOW (BDH, 2016b). The

interpretations presented in these documents have been employed to investigate whether the objectives of

the FSGMP are being achieved.

1.4 CRG consultation and review The CRG was provided with copies of the FSGMP audit for review. Copies of the comments received from

the CRG are provided in Appendix B.



1.5 Structure of audit report Definitions for the acronyms used throughout this audit report are provided before the Table of Contents

page. The scope for the audit and the five reference documents which define the conditions against which

the compliance aspects of the audit have been completed are summarised in Section 1 (this section). Section

2 provides the results of the detailed compliance audit of the FSGMP for the 12 month period to 30 September

2016, and allocates a compliance level to KCGM for each requirement, ranging from unknown to full

compliance.

Section 3 provides a review of the FSGMP objectives and requirements and investigates their suitability,

taking account of the hydrogeological conditions at the Fimiston I and Fimiston II TSFs. Section 4 examines

the progress of the FSGMP towards achieving the defined objectives. In Section 5, a summary of the audit

results and findings is provided, along with suggestions which could be considered during future revisions of

the FSGMP and associated reference documents.



2. Detailed compliance assessment

2.1 Background All of the conditions described in the FSGMP, and specified in the five reference documents defined in Section

1.3, have been summarised into tables in the following sections, grouped into common monitoring types. In

each row of each table, the compliance result determined from the audit is provided. The compliance result

in each case has been determined from:

1. The period over which that condition applied (i.e. applying L6420/1988/14A prior to April 2016 and

applying L6420/1988/14B following April 2016 if the conditions differ between these two licences).

2. Consideration of both the detail and the intent of the condition in the relevant reference document.

3. An inspection of monitoring data in the period October 2015 to September 2016 exported from the

KCGM environmental monitoring database. More detail on the data inspection undertaken for each

individual monitoring and production bore is provided in the tables in Appendix C.

4. Digital copies of various documents, reports and manuals relevant to the FSGMP provided by KCGM.

In each of the tables, the allocated compliance result is one of:

• Full compliance (shaded green). All of the requirements of that condition have been complied with or

were not triggered.

• Substantial compliance (shaded orange). Most of the requirements of that condition have been

complied with, and any missing components do not impede the interpretation of hydrogeological

conditions at the TSFs, or the management of seepage.

• Non-compliance (shaded red). The required data have not been collected, or the specified targets

have not been met, or the required actions have not been undertaken within the required timeframe.

• Unknown compliance (shaded grey). There are no data available to determine whether the condition

has been complied with.

• Not assessed (shaded grey). Compliance against the particular condition was not assessed.

The audit of compliance against specific conditions has been divided into the following components of the

FSGMP and associated reference documents:

1. Data collection compliance – has the required data been collected at the required frequency and by

applying the appropriate sampling, measurement and calibration techniques. This assessment has

not examined the actual values of the data, but simply whether a value is present in the database, or

a valid reason for non-collection (bore dry etc.) is present in the database.

2. Seepage management compliance – has the management of the Eastern Borefield met the defined

targets, including those defining groundwater depth, groundwater chemistry and the maximum extent

of the decant pond in each TSF paddock, and if targets were not met were the triggered actions

undertaken within the required timeframe

3. Reporting compliance – were all of the reporting obligations met by submitting all of the required

information to the appropriate agencies within the required deadlines.



2.2 Data collection compliance

2.2.1 Groundwater depths

The requirements for measuring groundwater depths are summarised in Table 1, along with the results of

the audit assessment in each case. A detailed summary of data collected at individual bores is included in

the tables in Appendix C. The DER licences applicable in the monitoring period required KCGM to measure

depth to groundwater in the selected monitoring bores highlighted with red circles in Figure 4. The Eastern

Borefield Operating Strategy referred to in GWL66252(7) required KCGM to measure all monitoring bores

six monthly. The audit included both a check on whether a datapoint was available in the database at the

required frequency for each bore, and also a check on the methods for calculating groundwater depth below

ground surface (given that the value recorded in the field is the depth below the top of the bore casing). As

detailed in Table 1, KCGM was fully compliant with all of the requirements to collect groundwater depth data

defined in the FSGMP and associated reference documents.

Table 1: Groundwater depth monitoring compliance

2.2.2 Groundwater chemistry

Table 2 compiles all of the requirements for groundwater chemistry monitoring defined in the reference

documents. The trenches and ponds defined in the DER licences for quarterly and annual hydrochemical

sampling are illustrated in Figure 2.

The Eastern Borefield Operating Strategy required annual sampling of major components at the 10

production bores circled in blue in Figure 3. Quarterly sampling of compliance monitoring bores was required

under L6420/1988/14 (those monitoring bores with blue symbols in Figure 4).

As summarised in Table 2, and assessed in detail in the tables in Appendix C, the majority of the required

sampling was undertaken at the required frequency during the audit period. The intervening periods between

sampling were consistent with the minimum separations defined in the DER licences. The analytes included

in the laboratory analyses exactly matched those defined in the DER licences. Samples were analysed at

Australian Laboratory Services Pty Ltd (ALS), and documentation from the laboratory confirms that is NATA

accredited (accreditation No 825), and that the analysis methods were consistent with the specifications in

the reference documents.

Groundwater samples were collected, preserved and despatched by Gecko Environmental Monitoring and

Sampling Services, and the monitoring manual provided by Gecko confirmed that the sampling, preservation

and handling procedures were consistent with the guidelines provided in standard AS/NZS 5667.1998.

Reference Section Requirement Compliance Auditor

Document Comment

L6420/1988/14 Table 3.3.1Quarterly in specified monitoring

bores (Schedule 1 Table 1)Full Data sighted

L6420/1988/14 Section 3.1.2 Minimum intervals between samples Full Data sighted

Operating

StrategySection 2.4 Six monthly in all monitoring bores Full Data sighted



For the 10 production bores required to be sampled annually for major components by the Eastern Borefield

Operating Strategy, it is noted that:

• All ten bores were sampled during the audit period.

• The timing of sampling met the requirements for annual monitoring.

• Sample handling matched the requirements of the Eastern Borefield Operating Strategy.

• The majority of the analytes defined in Appendix C3 of DOW Operational Policy N0. 5.2 (DOW, 2009)

were included in the laboratory suite.

• But the field parameters of temperature, Eh, Dissolved Oxygen and bicarbonate were not included in

the analyses.

None of the omitted parameters are considered to be critical to the interpretation of hydrochemical conditions

in the Eastern Borefield, and this aspect of the groundwater chemistry monitoring is therefore defined to be

substantially compliant with the SGMP. KCGM were therefore either fully or substantially compliant with

groundwater sampling and hydrochemical analysis requirements of the FSGMP during the audit period.

Table 2: Groundwater chemistry monitoring compliance


Document Comment

2014 FSGMP Section 2.4

Samples collected per AS5667.1,

analysed at NATA laboratory, using

APHA AWWA WEF methods

Full Manuals sighted

L6420/1988/14 Section 3.1.1Samples collected per AS5667.1,

analysed at NATA laboratoryFull Manuals sighted

L6420/1988/14 Section 3.1.2 Minimum intervals between samples Full Data sighted

L6420/1988/14 Section 3.1.4 Monitoring equipment calibrated Full Records sighted

Operating

StrategySection 2.4

Samples collected per AS5667.1,

analysed at NATA laboratoryFull Manuals sighted

L6420/1988/14 Table 3.8.1Quarterly pH EC at selected dams

and trenchesFull Data sighted

L6420/1988/14 Table 3.8.1Annual TDS CN at selected dams and

trenchesFull Data sighted

L6420/1988/14 Table 3.8.1Quarterly pH EC TDS CN at selected

monitoring boresFull Data sighted

Operating

StrategySection 2.4

Annual major components at 10

selected production boresSubstantial

Data sighted, field

measurements of

temperature, Eh,

Dissolved Oxygen,

bicarbonate listed in

DOW Operational

Policy 5.12 (DOW,

2009) were not

included but do not

preclude

interpretation



2.2.3 Groundwater production

Requirements for monitoring the volume of groundwater removed by the Eastern Borefield are defined in the

Eastern Borefield Operating Strategy which is referenced by GWL66252(7). This requires that pumped

volumes are recorded on a monthly basis at five borefield flow meters which aggregate flows from the

individual production bores and trenches, and that indicative monthly volumes are recorded from each

individual production bore and trench. Monthly production volumes from each of these sources for almost

the entire audit period were sighted during the audit. In December 2015, the monthly volume was not

available from one aggregating flow meter, as the meter failed. However, the individual bores connected to

the aggregating flow meter did have operating flow meters in this month, allowing the aggregated total to be

calculated. The intent of the requirement in the Operating Strategy was met, and KCGM was fully compliant

with this monitoring requirement of the FSGMP.

Table 3: Groundwater production monitoring compliance

2.2.4 Vegetation monitoring

Requirements for monitoring vegetation health and Landscape Function Analysis (LFA) are described in

Appendix 2 of the FSGMP and are defined in detail in the DER licences. Vegetation monitoring is required

to be undertaken in spring (September). As a result of this annual timing, field surveys of vegetation are

undertaken in one audit period, and reporting of the results occurs in the following audit period. To avoid

having to delay the audit while reporting of the field surveys is completed, the approach which has been taken

is to audit the vegetation monitoring from the previous period. The current audit which applies to the period

October 2015 to September 2016 therefore audits the 2015 vegetation monitoring which was undertaken in

September 2015. Vegetation monitoring was undertaken in September 2016, and will be audited in the 2017

audit. This approach is consistent with that taken for the 2015 audit, which reviewed vegetation monitoring

data collected in September 2014.

As discussed in Section 1.3, L6420/1988/14A was issued on 18 September 2015. The 2015 vegetation

monitoring was undertaken from 1 to 10 September 2015. The 2015 vegetation monitoring has therefore

been audited against the conditions defined in DER licence L6420/1988/14 which was issued on 25

September 2014. These conditions are similar to those described in the FSGMP issued in October 2014,

but it is identified that monitoring requirements differ between the September 2014 DER licence and the

October 2014 FSGMP as follows:

• Traverse D refers to NTD 3 in the licence and to 358537 6597384 in the FSGMP.

• Traverse E refers to NTD 4 in the licence and to 358884 6597023 in the FSGMP.

• Traverse H refers to NTD 5 in the FSGMP which is not included in the licence.

• Traverse T is included in the FSGMP but is not included in the licence.

• Traverse 6 refers to MB F84 in the licence and to PB F82 in the FSGMP.

• Traverse 7 refers to MB F20 in the licence and to MB F79 in the FSGMP.


Document Comment

Operating

StrategySection 2.4

Monthly flow volumes from 5

aggregating flow meters and indicative

volumes from individual bores and

trenches

Full

Data sighted except

for one failed

aggregating flow

meter in the month of

December 2015



• Traverse 9 refers to PB F114 in the licence and to PB F112 in the FSGMP.

• Traverse 14 refers to 356260 6598485 in the licence and to MB F72 in the FSGMP.

For the purposes of the current audit, it is considered that the DER licence takes precedence over the FSGMP

where these documents have conflicting requirements, and the audit has been conducted against the DER

licence conditions.

The DER licence audit of the 2015 photo monitoring and LFA analyses has been based on the results

presented in the relevant monitoring reports (Botanica, 2015a and Botanica, 2015b). These reports confirm

that monitoring was undertaken from 1 to 10 September, in spring as required. Comparing the data presented

in these reports with the requirements defined in the version of L6420/1988/14 issued in September 2014,

and based on follow up enquiries with Botanica, it is identified that:

• Photos were taken and interpreted, and LFA data collected and interpreted at the majority of the

required locations.

• Three photo locations on Traverse R were deliberately omitted due to access being unavailable to

the active mining area.

• Monitoring on Traverse 6 was undertaken at the correct location, but it is noted that the associated

bore near the traverse was referred to as PB F82 in the report, whereas Schedule 1 of the DER

licence refers to Traverse 6 as being associated with MB F84.


bore near the traverse was referred to as PB F112 in the report, whereas Schedule 1 of the DER

licence refers to Traverse 9 as being associated with PB F114.


bore near the traverse was referred to as MB F72 in the report, whereas Schedule 1 of the DER

licence refers to Traverse 14 as being associated with GDA 356260 6598485.

• Monitoring on Traverse H included NTD5 which is not required under the DER licence.

• Monitoring was undertaken on Traverse T which is not required on the DER licence.

KCGM were therefore fully compliant with the 2015 spring vegetation monitoring requirements of the FSGMP,

as defined by the DER licence in place at that time. The licence uses associated bores to identify the general

location of each traverse, but the actual traverse locations are defined separately from the bores. As

described above, for a few traverses the associated bore used in the Botanica report is different from (but

located close to) the associated bore listed in the licence. To avoid confusion, it is recommended that the

associated bores used in the Botanica report be made consistent with those listed in the DER licence.

It is also noted that the description of vegetation monitoring in the 2014 FSGMP in place at the time of the

2015 vegetation monitoring was not consistent with the licence and requires updating.



Table 4: Vegetation monitoring compliance

2.3 Seepage management compliance

2.3.1 Groundwater depth targets

The 2014 FSGMP defines targets for the minimum depth to groundwater in the Eastern Borefield. Table 1

defines a minimum target depth to groundwater in Eastern Borefield compliance bores of 4 m and a stretch

target of 6 m for these bores, and Section 8 defines the target as 4 m. The limit defined in the DER licences

for the same compliance bores is 4 m. As described in Table 5, the various nominated targets for

groundwater depth were met in all cases, as the shallowest depth to groundwater measured in a compliance

monitoring bore in the audit period was 6.25 m at MB F27. Appendix C (Table C2) provides a detailed list of

the bores which were included as compliance monitoring bores, and the results of the assessment of

compliance at each individual bore. KCGM was therefore fully compliant with these requirements for

monitoring bores.


Document Comment

L6420/1988/14

(Sep 2014 version)

Section 3.8.4 and

Schedule 1

Undertake annual vegetation

monitoring in September 2015 at 37

transects including photos and annual

LFA monitoring at 16 specified

locations

Full

Photos sighted, LFA

data sighted,

collected from 1 to 10

September 2015.

Descriptions of

locations are not

consistent with

licence but actual

locations matched

licence.

2014 FSGMP Appendix 2

Undertake annual vegetation

monitoring in September 2015 at 38

transects including photos and annual

LFA monitoring at 16 specified

locations

Not assessed

Vegetation monitoring

requirements in the

2014 FSGMP differ

from the DER licence

and so compliance

was assessed

against the DER

licence.



Table 5: Groundwater depth target compliance

2.3.2 Bore construction

Section 2.3 of the 2014 FSGMP describes the standards that must be applied to the construction or

decommissioning of any production or monitoring bores in the Eastern Borefield. As no bores were

constructed or decommissioned in the audit period, KCGM was fully compliant with this aspect of the FSGMP.

2.3.3 Decant pond area targets

During tailings deposition, water released from the settled tailings forms a decant pond at the low point in the

TSF paddock (see Figure 2 for paddocks in each facility). Section 4.3 of the 2014 FSGMP identifies that the

size of the decant pond is a controlling factor on the rate of seepage from the facility. An objective of

maintaining the decant pond area to less than 15% of the total paddock area has been defined.

During the audit period, tailings deposition did not occur to Fimiston I. At Fimiston II, tailings deposition

occurred to:

• Paddock C from October 2015 to March 2016.

• Paddock D from March 2016 to June 2016.

• Paddock AB from October 2015 to December 2015 and from June 2016 to September 2016.

Survey data were collected every two weeks defining the extent of the decant pond in each active paddock,

and the results are summarised in Table 6. KCGM is identified to have been compliant with the objective to

maintain the pond at less than 15% of the paddock area at Fimiston II C Paddock, and substantially compliant

in the Fimiston II AB Paddock (one exceedance in 12 surveys) and in the Fimiston II D Paddock (2

exceedances in 10 surveys). All three pond size exceedances measured at Fimiston II during the monitoring

period resulted from poor performance or failure of decant pumps removing water from the decant ponds,

and on all three occasions the pumps were repaired or replaced within two weeks to allow the pond size to

be compliant in the following survey.


Document Comment

2014 SGMP Table 1

Stretch target of 6 m depth for

groundwater in all monitoring

compliance bores

Full

Shallowest

groundwater depth

6.6 m at MB F27

2014 SGMP Section 8

Achieve and maintain depth to

groundwater >4m in all monitoring

compliance bores

Full

Shallowest

groundwater depth

6.6 m at MB F27

L6420/1988/14 Table 3.3.1Maintain depth to groundwater >4m in

45 nominated monitoring boresFull

Shallowest

groundwater depth

6.6 m at MB F27



Table 6: Decant pond area target compliance

2.3.4 Weak Acid Dissociable Cyanide concentration in groundwater targets

Section 8 of the 2014 FSGMP sets a target of maintaining Weak Acid Dissociable Cyanide (WADCN)

concentrations in groundwater below 0.5 mg/L in compliance monitoring bores. The compliance monitoring

bores are not defined in the FSGMP, and are assumed to refer to the DER licences (i.e. the 45 nominated

compliance monitoring bores in Table 1 of L6420/1988/14). As summarised in Table 7, and assessed in

detail in Appendix C, the target set in the FSGMP for WADCN concentrations was fully complied with by

KCGM in the audit period.

Table 7: WADCN target compliance

2.3.5 Production bore operation targets

The 2014 FSGMP set targets for the availability of production bores installed in the Eastern Borefield, to

ensure that the maximum possible amount of groundwater is removed by the installed infrastructure. The

wording used in the SGMP is a target of “an availability of more than 90% availability for the installed

production bores in any full calendar month”. For the purposes of determining compliance in the current

audit, it has been assumed that:

1. The total number of production bores in the Eastern Borefield is those that are described as being

active in the Eastern Borefield Operating Strategy (KCGM, 2013, 131 production bores listed as

active).

2. Any bore that produces a measurable groundwater volume during the month is considered to have

been available in that month.

3. The target is 90% of the total number of production bores being available in that month.

Based on these definitions, Table 8 defines KCGM to be compliant with this component of the FSGMP in the

audit period.

PaddockMinimum

Area

Maximum

Area

Average

Area

Number of

Surveys

Surveys

Exceeding 15%Compliance

Fimiston II AB 3% 18% 8% 12 1 Substantial

Fimiston II C 2% 13% 7% 12 0 Full

Fimiston II D 3% 17% 9% 10 2 Substantial

All 1% 18% 8% 55 3 Substantial


Document Comment

2014 SGMP Section 8

Maintain groundwater quality

<0.5mg/L WADCN in all compliance

monitoring bores

Full

WADCN was less

than 0.5 mg/L in all

45 monitoring bores



Table 8: Production bore operation target compliance

2.3.6 Triggered actions

The FSGMP defines a range of actions and milestones to be achieved, which are triggered based on

monitoring results from the Eastern Borefield, and are defined in the DER licences. These are compiled

along with the relevant reference documents in Table 9. During the audit period there have been in place

requirements to increase pumping rates if depth to water is less than 4 m or 6 m in compliance bores, if a

groundwater WADCN concentration greater than 0.5 mg/L is recorded in any compliance bore, or if advice is

received from the DER. None of these conditions have been triggered during the audit period and so KCGM

are fully compliant with these components of the FSGMP.

Table 9: Triggered action compliance

2.4 Reporting compliance Obligations for reporting on the FSGMP are summarised from the relevant reference documents in Table 10.

All of the required reports were delivered to the relevant authority on or before the due date, including the

2015 FSGMP audit and the 2015 Annual Environmental Review (AER). KCGM is therefore fully compliant

with these components of the FSGMP.


Document Comment

2014 SGMPSection 4.1 and

Section 8

Target 90% availability of the installed

production bores over a full calendar

month

FullMonthly availability

between 92 and 95%

Reference Section Trigger Required Action Compliance Auditor

Document Comment

L6420/1988/14 Table 3.8.2 Groundwater depth <4mIncrease pumping capacity

within 6 monthsFull Not triggered

L6420/1988/14 Table 3.8.2Groundwater depth >4m and

<6m

Increase pumping capacity


L6420/1988/14 Table 3.8.2WADCN >0.5mg/L in any

compliance bore

Increase pumping capacity


L6420/1988/14 Section 3.8.3When advised by the CEO of

DER

Take further actions to further

reduce groundwater levelsFull Not triggered



Table 10: Reporting compliance

Reference Section Reporting Obligation Date Submitted Compliance Auditor

Document Comment

GWL66252(7) Section 7Annual monitoring summary to be submitted to

DOW by 28 Feb 1626-Feb-16 Full Document sighted

L6420/1988/14Section 4.2.2

and Table 4.2.2

Submit groundwater summary for Q3/2015 to

DER by 15 Nov 201512-Nov-15 Full Document sighted

L6420/1988/14Section 4.2.2

and Table 4.2.2


DER by 15 Feb 201615-Feb-16 Full Document sighted

L6420/1988/14Section 4.2.2

and Table 4.2.2


DER by 16 May 201612-May-16 Full Document sighted

L6420/1988/14Section 4.2.2

and Table 4.2.2


DER by 15 Aug 201629-Jul-16 Full Document sighted

L6420/1988/14Section 4.2.1

and Table 4.2.1

Submit AER (to 31 Dec 15) to DER by 31 Mar

16, including FSGMP audit report to September

2015, 2015 annual vegetation monitoring report,

and 2015 annual audit compliance report.

24-Mar-16 Full Document sighted

L6420/1988/14Section 4.3.1

and Table 4.3.1

Report any exceedance of a licence limit to

DER within 24 hoursN/A Full Not triggered

L6420/1988/14Section 4.3.1

and Table 4.3.1

Provide a report describing planned corrective

actions within 7 days of any exceedance of a

licence limit

N/A Full Not triggered



3. Review of FSGMP objectives and management requirements

3.1 Background A specific requirement defined in L6420/1988/14 for the annual audits of the FSGMP is to review the FSGMP

objectives and whether they remain appropriate. In the following sections, both the objectives and the

management requirements defined in the FSGMP to achieve them are first summarised, and then reviewed

by the auditor as to whether they remain appropriate. It is recognised that the FSGMP has undergone

multiple iterations since 2005 in response to various stakeholder feedback, and that the rationale for some

conditions may no longer be described within the FSGMP text. However, the auditor review has been based

on the objectives as currently defined and explained in the FSGMP, using the auditor’s detailed

understanding of the hydrogeological regime below the Fimiston I and Fimiston II TSFs, and drawing on

experience of groundwater management programs in comparable hydrogeological environments.

3.2 FSGMP objectives

3.2.1 Summary of objectives

Section 3 of the 2014 FSGMP states:

“The primary objective of the FSGMP is to prevent impact to vegetation as a consequence of rising

groundwater levels due to seepage from the Fimiston TSFs. The secondary objective of the FSGMP is

to manage the groundwater levels at post closure. The Eastern Borefield will require active

management after cessation of TSF operation. Groundwater levels are expected to stabilise over time,

with gradual reduction in pumping volumes. It is anticipated that groundwater will naturally deepen toward

estimated historical groundwater levels for this area in the long term.”

3.2.2 Auditor assessment of objectives

The primary objective of the FSGMP is based on vegetation being the primary environmental value requiring

protection in the area surrounding the Fimiston TSFs. The FSGMP correctly identifies that protecting this

environmental value requires managing groundwater elevations to prevent them rising into the root zone.

This not only prevents impacts to existing vegetation, but also prevents salinisation of the near surface soils

and hence potential impacts to future vegetation. Targets for maximum groundwater elevations have been

set at 4 to 6 m below ground.

The targets set for groundwater depths in the SGMP are effectively the minimum depths which are thought

to protect vegetation and soil health. These minimum depth targets are considered appropriate, taking into

account that vegetation monitoring results indicate these depth targets have been successful in protecting

vegetation to date.

The primary objective of the FSGMP does not consider groundwater chemistry, which is appropriate given

that:

1. Groundwater within the shallow groundwater system is naturally saline, containing greater than

20,000 mg/L Total Dissolved Solids (TDS). Regardless of any changes in groundwater chemistry,

environmental harm will potentially occur if groundwater with natural background TDS concentrations

rises into the root zone.

2. As a result of the elevated background TDS concentrations in the shallow groundwater system, the

only beneficial use for the groundwater system recognised during water resource planning for the

Eastern Goldfields area is use in mineral processing (Water Authority of Western Australia, 1993).



The secondary objective of the FSGMP for post closure also recognises that vegetation is the primary

environmental value requiring protection in the long term, and that this will be achieved by long term

management of groundwater elevations, which is appropriate. Section 4.4 of the FSGMP notes that closure

groundwater depth targets will be developed in the KCGM Mine Closure Plan. The most recent version of

the KCGM Mine Closure Plan (KCGM, 2015) states that closure criteria for groundwater will be developed

on a facility specific basis, and outlines a closure approach for the Eastern Borefield where pumping rates

reduce during closure, and pumping is terminated once groundwater elevations reach agreed targets which

are protective of vegetation, allowing groundwater elevations potentially to naturally approach the pre-mining

elevations. This approach is considered appropriate, as once the TSFs have drained down, seepage will

significantly reduce, and the Eastern Borefield will be primarily removing groundwater in storage (i.e.

removing the groundwater mound which exists beneath the TSFs and lowering groundwater elevations).

However, it is noted that:

1. As a result of the permanent changes to the hydrological regime associated with the facilities,

groundwater elevations are unlikely to reach the estimated pre-mining elevations in all locations;

2. The target depths at which it is appropriate to terminate pumping will need to be defined and agreed

prior to closure;

3. These target depths will need to consider whether groundwater depths less than 4 m naturally occur

in any part of the managed area; and

4. These target depths will need to consider how much groundwater elevations may naturally rise in

response to unusually large precipitation events.

3.3 Groundwater depths

3.3.1 Summary of groundwater depth monitoring and management

The FSGMP requires:

• Depth to groundwater to be measured quarterly in the monitoring bores circled in red in Figure 4.

• Depth to groundwater be measured twice per year in all monitoring bores in Figure 4.

• Groundwater depth in bores located outside the operational areas of the TSFs (highlighted with red

circles in Figure 4) to be maintained at more than 4 m below ground.

3.3.2 Auditor assessment of groundwater depth monitoring and management

The locations and monitoring frequency for groundwater depth monitoring are considered appropriate, taking

account of the typical rates of change in groundwater elevations observed to date, the known directions of

groundwater flow, and the locations of vegetation in the receiving environment.

The use of a TSF operational area with a maximum extent of 100 m from the facility is considered appropriate

in setting groundwater depth targets. This area forms part of the footprint of the facility and associated

infrastructure, and is highly disturbed. While the minimum depth requirement is not applied in the operational

area, KCGM continue to manage groundwater elevations within this area, as high groundwater elevations

would potentially cause non-compliances for groundwater immediately outside the operational area.

The nominated minimum groundwater depth of 4 m below ground appears to have been protective of

vegetation in the area to date, and so remains an appropriate target for the FSGMP, as discussed in Section

3.2.



3.4 Groundwater chemistry

3.4.1 Summary of groundwater chemistry monitoring and management

The FSGMP requires:

• Quarterly measurement of pH and EC at Decant 1, Decant 3, Fimiston I North trench, Fimiston II

South trench as marked in Figure 2.

• Annual measurement of TDS, WADCN, Free CN and Total CN at Decant 1, Decant 3, Fimiston I

North trench, Fimiston II South trench as marked in Figure 2.

• Quarterly measurement of EC, pH, TDS, WADCN, Free CN, Total CN at selected monitoring bores

(bores labelled in blue in Figure 4).

• Annual measurement of major ion components at 10 selected production bores (highlighted with blue

circles in Figure 3).

• Pumping rates to be increased within 9 months if WADCN concentrations exceed 0.5 mg/L in any

compliance bore.

3.4.2 Auditor assessment of groundwater chemistry monitoring and management

As discussed in Section 3.2, the primary objective of the FSGMP is to manage impacts to vegetation, which

is achieved by managing groundwater elevations. Groundwater quality is therefore of secondary (i.e. limited)

importance to the objectives of the FSGMP. Groundwater quality monitoring may assist in understanding

the role of seepage in the local hydrogeological regime, and the influence of natural recharge, and hence

may be of value in studies setting targets for post closure groundwater conditions. However, it is noted that

cyanide is a poor hydrochemical indicator for the presence of TSF seepage, as it is not conserved during

flow through the groundwater system, and parameters such as TDS and major ions which remain in solution

within the groundwater system are likely to be more diagnostic of regional seepage extent.

It is therefore identified that:

1. Annual monitoring of major components at the 10 production bores located in the central drainage

between the Fimiston I and Fimiston II TSFs provides useful data for tracking the extent of seepage

and the role of recharge in the hydrogeological regime.

2. Monitoring of pH, EC and TDS at monitoring bores, ponds and trenches is of value for tracking

seepage and recharge influences.

3. Monitoring of cyanide species in monitoring bores, ponds and trenches is of limited value in tracking

seepage influences, and does not contribute to the objective of protecting vegetation, but may

potentially have a role in stakeholder consultation or in meeting obligations of the International

Cyanide Management Code (ICMC).

4. The rationale for increasing pumping if WADCN exceeds 0.5 mg/L is unclear as it does not have a

relationship to the objective of protecting vegetation, and the origin of the value of 0.5 mg/L is not

discussed in the FSGMP. While it is possible this condition has a role in managing stakeholder

concerns, or meeting aspects of the ICMC, it is noted that removal of this condition would not affect

the progress of KCGM towards achieving the objectives as currently defined in the FSGMP.



3.5 Groundwater recovery

3.5.1 Summary of groundwater recovery

Groundwater recovery aspects of the FSGMP include:

• Groundwater will be removed by the Eastern Borefield.

• The maximum allowable annual abstraction from the Eastern Borefield is 4,000,000 kL (equivalent to

an average total pumping rate of 127 L/s).

• The production bores in the Eastern Borefield will target 90% availability in any calendar month.

• Abstracted groundwater will form a component of the process water supply used in the Fimiston

Processing Plant.

• Abstracted volumes will be monitored monthly.

• Pumping rates to be increased within 6 months if groundwater depth is less than 4 m in a compliance

monitoring bore and within 9 months if groundwater depth is between 4 and 6 m in a compliance

monitoring bore.

3.5.2 Auditor assessment of groundwater recovery

Recovery of groundwater from the Eastern Borefield is the key component of the FSGMP in achieving the

primary objective of protecting vegetation. In 2015, total abstraction was 72% of the allowable limit,

equivalent to an average rate of 91 L/s, and the limit set by GWL66252(7) is therefore sufficient for borefield

management. The target of 90% availability of production bores provides an appropriate balance between

the objective of maximising the groundwater production from the installed infrastructure and allowing for

operational constraints including shut downs of the Fimiston Processing Plant when the Eastern Borefield is

necessarily turned off once the holding ponds are full. Monthly monitoring of abstracted volumes is useful

for interpreting the causes of any changes in groundwater elevations in monitoring bores.

The use of groundwater from the Eastern Borefield in the Fimiston Processing Plant reduces the demand on

groundwater sourced from regional aquifer systems (palaeochannel groundwater supply borefields) and

therefore is of benefit in managing groundwater resources in the Eastern Goldfields.

The nominated periods of 6 months and 9 months for increasing pumping rates are realistic taking account

that the FSGMP allows the increases to be achieved by adjusting or modifying the existing infrastructure at

existing bores. However, it is noted that in the event that an investigation concluded new production bores

would be required to manage groundwater depths, commissioning of the bores would be unlikely to occur

within those timeframes, taking account of the complex approvals process, and the budgeting, permitting,

contracting, field works and infrastructure construction which would be required.

It is noted that the current wording in the FSGMP does not define how the 90% production bore availability

target is intended to be calculated. There is no definition of how many or which production bores are active

and included in the target, and this could potentially be improved by referencing the production bore status

as listed in the Eastern Borefield Operating Strategy. There is also no clear definition of whether a production

bore which was available for one day in a calendar month is counted as being available in that month. While

the target is appropriate, clarifying the intent of the target would simply facilitate external auditing of

compliance.



It is also noted that the Eastern Borefield Operating Strategy (KCGM, 2013) potentially requires updating.

For example, Table 1 of the Operating Strategy lists production bores PB F64A, PB F108, PB F109 and PB

F110 as active, but it is noted from the monitoring data inspected that these bores did not produce any

groundwater during the entire audit period, or during the previous audit period.

3.6 Vegetation monitoring and management

3.6.1 Summary of vegetation monitoring and management

Vegetation monitoring in the FSGMP includes annual photo monitoring of vegetation health along 37

transects, and annual Landscape Function Analysis at 16 specified locations. The monitoring is undertaken

around the perimeters of the Fimiston I and Fimiston II TSFs, within the central surface drainage channel,

and at two analogue locations 2 to 5 km north of the TSFs.

3.6.2 Auditor assessment of vegetation monitoring and management

The vegetation monitoring locations are well defined in the field, but the references to the locations are not

consistent in the FSGMP and the DER licence. In general, the monitoring locations are considered

appropriate, taking account of groundwater flow directions and the estimated pre-mining depths of

groundwater below surface. The analogue locations are located in areas where the naturally saline

groundwater is more than 17 m below surface, so that any changes in vegetation health in the analogue

locations will reflect environmental conditions, and not the influence of groundwater.

The primary function of vegetation monitoring has been to confirm that the groundwater depth limits used for

the proactive management of groundwater are appropriately set to be protective of the specific vegetation

present near the Eastern Borefield. It is noted that sufficient data have been collected to validate the

groundwater management approach in the FSGMP, and that there appears to be limited value in continued

vegetation monitoring. The most effective and highest priority component of the FSGMP continues to be the

proactive management and monitoring of groundwater depths.

3.7 Decant pond management

3.7.1 Summary of decant pond management

The FSGMP defines a target of maintaining the area of the decant pond within each tailings paddock to less

than 15% of the surveyed area of the entire paddock.

3.7.2 Auditor assessment of decant pond management

The extent of the decant pond controls the portion of the tailings pile which remains permanently saturated,

and therefore retains hydraulic connection from the pond at the surface of the facility to the potential seepage

zone at the base of the facility. As a result, the extent of the decant pond is a known control on seepage

rates. The influence of the decant pond extent has been confirmed by numerical modelling of seepage from

the Fimiston I TSF which identified that allowing a decant pond equivalent to 20% of the paddock resulted in

significantly shallower groundwater elevations around the facility compared to maintaining a pond area of

10% of the paddock (Golder, 2015). Maintaining decant pond areas below the 15% target is therefore an

important and appropriate component of the FSGMP.



4. Assessment of progress towards objectives

4.1 Background Section 3 of the 2014 FSGMP states:

“The primary objective of the FSGMP is to prevent impact to vegetation as a consequence of rising

groundwater levels due to seepage from the Fimiston TSFs. The secondary objective of the FSGMP is

to manage the groundwater levels at post closure. The Eastern Borefield will require active

management after cessation of TSF operation. Groundwater levels are expected to stabilise over time,

with gradual reduction in pumping volumes. It is anticipated that groundwater will naturally deepen toward

estimated historical groundwater levels for this area in the long term.”

The secondary objective can most feasibly be achieved after the TSFs have been decommissioned. The

performance of KCGM during the audit period has therefore been assessed against the primary objective, to

implement the FSGMP in a manner which maintains groundwater depths that prevent impacts to vegetation.

The assessment has been undertaken using the data plotted and interpreted in various reports compiled as

part of the FSGMP, and no analyses of raw monitoring data have been undertaken.

4.2 Progress towards objectives Groundwater production from the Eastern Borefield during the period October 2015 to September 2016 was

equivalent to an average flow rate of 89 L/s, which represents a small decline from the average reported for

the year to December 2015 (91 L/s) and the average for the year to December 2014 (104 L/s), but is

representative of efficient utilisation of the Eastern Borefield. The reduction in the total average pumping rate

from 2014 to 2016 reflects the lowering of groundwater levels in some areas of the Eastern Borefield which

reduces the yield available from the individual bores.

Depths to groundwater were presented as time series hydrographs extending to December 2015 in the

annual review compiled for the DOW (BDH, 2016b). These hydrographs illustrate that in the initial part of the

audit period (October 2015 to December 2015), groundwater depths were stable or declining across the area

of the FSGMP. The Q1 2016 groundwater monitoring report compiled by KCGM identified continuing

declining groundwater elevations over most of the area from January to March of 2016. The Q2 2016

groundwater monitoring report compiled by KCGM identified predominantly stable groundwater depths

across the FSGMP area from April to June of 2016.

No groundwater depths shallower than 4 m below ground were measured in any compliance monitoring bore

in the audit period, and in fact the shallowest groundwater depth was 6.6 m below ground. In combination,

these observations indicate that the operation of the Eastern Borefield has successfully controlled

groundwater depths throughout the audit period, and that the objectives of Eastern Borefield operation are

being achieved.



Vegetation monitoring around the Fimiston TSFs and at analogue sites was conducted in the spring of 2015,

and included photo monitoring points which were interpreted by an environmental professional to determine

any changes in vegetation health from the previous year (Botanica Consulting, 2015a), and LFA monitoring

to generate metrics defining stability, infiltration, nutrient cycling, species diversity, species density and

vegetation cover (Botanica Consulting, 2015b). The conclusions from these studies were:

“The lower than average rainfall in 2015 has resulted in many species not being in flower during this

monitoring period or had finished flowering after an early start to spring which possibly was from the above

average rainfall received in August. There were some annuals recorded, although not as many

compared to the 2014 monitoring. Many Poaceae species (grasses) were not present and the shrub Ptilotus

nobilis (mulla mulla) was absent in 2015. At T12 MB F01 the shrub species Maireana triptera which occurs

in large numbers has declined since 2014. Other species have not shown any change and therefore this

species decline is probably age related. The only other change in the photographic evidence was

the vegetation removal in the bunding at MB F19 SW0. Overall, vegetation is generally classed as

2 (depicting that there has been no change since 2014).”

“Based on the results of the monitoring, despite a decrease in biodiversity, the vegetation surrounding the

TSFs does not appear to be impacted by groundwater level variations and is following a similar trend to the

analogue sites. Ongoing monitoring is required to determine whether the vegetation is being affected by the

TSFs.”

These conclusions indicate that the proactive maintenance of groundwater depths by operation of the Eastern

Borefield continues to successfully achieved the objective of protecting vegetation within the area of the

FSGMP, and that there is limited value in continued vegetation monitoring.

Tailings deposition in the Fimiston II TSF has been managed to meet the objective of maintaining a decant

pond area less than 15% of the total paddock over most of the audit period. Continued effort to minimise the

decant pond extent will minimise the rates of seepage from the TSFs.



5. Conclusions and recommendations

5.1 Conclusions This audit of the FSGMP covers the monitoring period from 1 October 2015 to 30 September 2016. The

audit has included 1) an inspection of whether all of the required monitoring, management and reporting

components of the FSGMP have been completed by KCGM within the required timeframes; 2) a review of

the objectives of the SGMP and whether they remain valid; and 3) an assessment of whether implementation

of the FSGMP is making progress towards the objectives.

The detailed compliance audit identifies that in the audit period:

• KCGM were fully compliant with the requirements to monitor groundwater depths and groundwater

production.

• KCGM were fully compliant with the requirements to monitor vegetation health.

• KCGM were substantially compliant with the requirements to monitor groundwater chemistry.

• KCGM were fully compliant with all reporting obligations.

• KCGM were fully compliant with targets set for groundwater depth, groundwater chemistry, production

bore operation and triggered actions.

• KCGM were substantially compliant with the target of maintaining decant ponds less than 15% of the

tailings paddock area in each TSF.

The objectives defined in the FSGMP have been concluded to remain valid, as they are based around

managing depth to groundwater, and preventing naturally saline groundwater rising into the root zone or into

the shallow soils.

It is concluded KCGM are making good progress towards the objectives defined for the operating period in

the FSGMP. Operation of the Eastern Borefield has resulted in groundwater depths being generally stable

or declining in the audit period. Monitoring of vegetation health in the spring of 2015 did not identify any

impacts from TSF operation.

5.2 Recommendations Auditor recommendations for modifications to the FSGMP and associated reference documents, which arise

from the detailed audit of each document, and could be considered during any future revisions of the

documents are summarised as follows:

• The value of continued vegetation monitoring could be investigated, as sufficient data have been

collected to confirm that the proactive approach of managing and monitoring groundwater depths is

effective.

• If vegetation monitoring is continued, the FSGMP needs to be carefully reviewed and the vegetation

monitoring location descriptions made consistent with the relevant DER licence conditions.

• The rationale for monitoring groundwater cyanide concentrations could be included in the FSGMP as

it does not contribute to the stated objective of preventing harm to vegetation.

• The rationale for requiring groundwater production to be increased if WADCN concentrations higher

than 0.5 mg/L are observed in compliance locations could be included in the FSGMP as it is not

directly relevant to the stated objectives, alternatively consideration could be given to removing this

condition.



• The target of maintaining groundwater WADCN concentrations less than 0.5 mg/L in Section 8 of the

FSGMP could be reviewed, as this is not specifically defined as a compliance limit in L6420/1988/14

(it only appears as a triggered action) and is not linked to the objectives of protecting vegetation.

• The wording of the FSGMP could be improved to better define how it is intended to calculate the

target of 90% availability of production bores in the Eastern Borefield in any calendar month to

facilitate future audits.

• The Eastern Borefield Operating Strategy could be updated by reviewing the status of all production

bores, including PB F64A, PB F108, PB F109 and PB F110 which have not produced any

groundwater in the last two audit periods.

• The parameters intended to be included for major component analyses of groundwater samples from

ten selected production bores could be more clearly defined in the Eastern Borefield Operating

Strategy and then translated into field sampling protocols.

• Section 2.1 of the FSGMP could be updated as the Table numbers in the referenced DER licence

have changed in the most recent version of the licence issued in April 2016.



References BDH 2016a, 2016 Annual Audit, Kaltails Tailings Storage Facility Seepage and Groundwater Management

Plan, Big Dog Hydrogeology Pty Ltd.

BDH 2016b, KCGM, Groundwater Monitoring Summary for 2015, Eastern Borefield, Kalgoorlie, Big Dog

Hydrogeology Pty Ltd.

Botanica 2015a, Fimiston I and II and Kaltails Tailings Storage Facilities, Photographic Monitoring Report,

Botanica Consulting.

Botanica 2015b, Fimiston I and II and Kaltails Tailings Storage Facilities. Landscape Function Analysis and

Vegetation Monitoring Report, Botanica Consulting.

DOW 2009, Operational Police No. 5.1.2 – Hydrogeological Reporting Associated With a Groundwater Well

Licence, Department of Water.

Golder 2015, Summary of Preliminary Seepage Results for the Fimiston I Tailings Storage Facility, Golder

Associates.

KCGM 2013, Eastern Borefield Operating Strategy, GWL66252, KCGM.

KCGM 2014, Fimiston Seepage and Groundwater Management Plan, KCGM.

KCGM 2015, Mine Closure Plan, KCGM.

Water Authority of Western Australia 1993, Goldfields Groundwater Area Management Plan, Water

Corporation.



List of Figures 1. Facility locations

2. Trench and pond locations

3. Groundwater production locations

4. Groundwater monitoring locations


KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)

Figures

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Facility locationsReport:

Date:

")

City ofKalgoorlie -

Boulder

Mt Monger Road

Aust Rail Track Corp Railway Line

Mt CharlotteHeadframe Fimiston

I TSF FimistonII TSF

FimistonMill

SilverlakeResources

Limited TSFKaltails

TSF

FimistonPit

Mt Percy TSF(Inactive)

354000

354000

356000

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Railway0 1 2 km ´Map projection: Transverse MercatorHorizontal Datum: Geocentric Datum of Australia 1994Grid: Map Grid of Australia, Zone 51This map contains data which are reproduced by permission ofthe Western Australian Land Information Authority, CL39/2009.

Figure 1

FSGMPAnnual Audit for 2016

December 2016

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Trench and pond locationsFigure 2

Report:FSGMP

Annual Audit for 2016

Date:December 2016

Bulong Road

$

Fimiston II BTrench

$

C PaddockSouthTrench

$

FimistonII SouthTrench

$

Fimiston I(North &

South) Trench

$

FimistonII Trench

$

FimistonII NorthTrench


FimistonI TSF

FimistonII TSF

FimistonMill

A/BPaddock

C Paddock

D Paddock

Decant 3

Decant 1

356000

356000

357000

357000

358000

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LegendFimiston II TSF paddockboundarySeepage interception trenchPond Railway

0 0.5 1 km

Map projection: Transverse MercatorHorizontal Datum: Geocentric Datum of Australia 1994Grid: Map Grid of Australia, Zone 51This map contains data which arereproduced by permission of theWestern Australian Land InformationAuthority, CL39/2009.

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G:\Projects\BDH Projects\KCGM\GIS\Figures\FSGMP Annual Audit for 2016

Groundwater production locationsFigure 3

Report:FSGMP

Annual Audit for 2016

Date:Decem ber 2016

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Bulong Road


FimistonI TSF

FimistonII TSF

FimistonMill

A/BPaddock

C Paddock

D Paddock

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360000

360000

361000

361000

362000

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363000

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6596000

6596000

6597000

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Legend!( Production bore

Production bore – DOW annualm ajor com ponent sam plingFim iston II TSF paddockboundary Railway

0 0.5 1km´Map projection: Transverse MercatorHoriz ontal Datum : Geocentric Datum of Australia 1994Grid: Map Grid of Australia, Zone 51This m ap contains data which arereproduced by perm ission of theW estern Australian Land Inform ationAuthority, CL39/2009.

G:\Projects\BDH Projects\KCGM\GIS\Figures\FSGMP Annual Audit for 2016

Groundwater monitoring locationsReport:

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MB F25

MB F26

MB F76

MB F78

MB F86

MB F1

MB F2MB F3

MB F4

MB F5MB F5A

MB F6

MB F7

MB F8

MB F9

MB F10MB F11MB F12

MB F18

MB F19

MB F20

MB F21

MB F23

MB F27

MB F30

MB F31

MB F32

MB F33

MB F34MB F35

MB F36

MB F37MB F38

MB F39

MB F40

MB F41

MB F42

MB F43MB F44

MB F45

MB F46

MB F47MB F48MB F49

MB F50MB F51

MB F52MB F53

MB F54

MB F55

MB F56

MB F57

MB F60

MB F61

MB F62

MB F63MB F64

MB F65MB F66

MB F67

MB F69MB F72

MB F73

MB F74

MB F75

MB F77

MB F79

MB F80

MB F81MB F82

MB F83

MB F84

MB F85

NTD 1NTD 2

NTD 3

NTD 4

NTD 5

NTD 6

TRE

TRP 2

Bulong Road

FimistonI TSF

FimistonII TSF

FimistonMill

FimistonPit

A/BPaddock

C Paddock

D Paddock

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357000

358000

358000

359000

359000

360000

360000

361000

361000

362000

362000

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6594000

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6595000

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6596000

6597000

6597000

6598000

6598000

6599000

6599000

6600000

6600000

6601000

6601000

6602000

6602000

Legend

!(Monitoring bore included in Operating Strategybut rem oved from DER licence

!( Monitoring bore – DER quarterly sam plingMonitoring bore – DER com pliance for depths togroundw aterT SF operational areaFim iston II T SF paddock boundary Railw ay

Map projection: T ransverse MercatorHorizontal Datum : Geocentric Datum of Australia 1994Grid: Map Grid of Australia, Zone 51T his m ap contains data w hich are reproduced by perm ission ofthe Western Australian Land Inform ation Authority, CL39/2009.

0 1 2k m

Figure 4

FSGMPAnnual Audit for 2016

Decem ber 2016



Appendix A Certification of auditor independence

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Appendix B Community Reference Group responses



Appendix C Detailed results of compliance assessment



Table C1: Compliance for measuring groundwater depth in monitoring bores

Monitoring DER L6420/1988 GWL66252(7) Audit

Bore Pre Apr 16/Post Apr 16 Result

MB F01 Q/Q H OK

MB F02 Q/Q H OK

MB F03 Q/Q H OK

MB F04 Q/Q H OK

MB F05 None/None H OK

MB F05A None/None H OK

MB F06 Q/Q H OK

MB F07 Q/Q H OK

MB F08 Q/Q H OK

MB F09 Q/Q H OK





MB F19 Q/Q H OK

MB F20 Q/Q H OK

MB F21 Q/Q H OK

MB F23 Q/Q H OK



MB F27 Q/Q H OK

MB F30 Q/Q H OK

MB F31 Q/Q H OK

MB F32 Q/Q H OK

MB F33 Q/Q H OK





MB F38 Q/Q H OK





MB F43 Q/Q H OK


MB F45 Q/Q H OK


MB F47 Q/Q H OK


MB F49 Q/Q H OK



Notes: Q Quarterly monitoring required

H Half yearly monitoring required

None No monitoring required (not in Schedule 1 Table 1)



Table C1: Compliance for measuring groundwater depth in monitoring bores (Continued)

Monitoring DER L6420/1988 GWL66252(7) Audit

Bore Pre Apr 16/Post Apr 16 Result



MB F54 Q/Q H OK

MB F55 Q/Q H OK

MB F56 Q/Q H OK

MB F57 Q/Q H OK

MB F60 Q/Q H OK

MB F61 Q/Q H OK




MB F65 Q/Q H OK

MB F66 Q/Q H OK

MB F67 Q/Q H OK


MB F72 Q/Q H OK

MB F73 Q/Q H OK

MB F74 Q/Q H OK

MB F75 Q/Q H OK


MB F77 Q/Q H OK


MB F79 Q/Q H OK

MB F80 Q/Q H OK

MB F81 Q/Q H OK

MB F82 Q/Q H OK

MB F83 Q/Q H OK

MB F84 Q/Q H OK

MB F85 Q/Q H OK


NTD 1 None/None H OK






TRE Q/Q H OK

TRP 2 Q/Q H OK

Notes: Q Quarterly monitoring required

H Half yearly monitoring required

None No monitoring required (not in Schedule 1 Table 1)



Table C2: Compliance for groundwater depth <4m and <6m in monitoring bores

Monitoring Compliance Bore Audit Monitoring Compliance Bore Audit

Bore Pre Apr 16/Post Apr 16 Result Bore Pre Apr 16/Post Apr 16 Result

MB F01 Yes/Yes OK MB F50 No/No OK




MB F05 No/No OK MB F54 Yes/Yes OK

MB F05A No/No OK MB F55 Yes/Yes OK

MB F06 Yes/Yes OK MB F56 Yes/Yes OK




MB F10 No/No OK MB F62 No/No OK






















MB F41 No/No OK NTD 1 No/No OK


MB F43 Yes/Yes OK NTD 3 No/No OK


MB F45 Yes/Yes OK NTD 5 No/No OK


MB F47 Yes/Yes OK TRE Yes/Yes OK

MB F48 No/No OK TRP 2 Yes/Yes OK

MB F49 Yes/Yes OK



Table C3: Quarterly chemistry analyses at monitoring bores compliance

Monitoring Quarterly Audit Result Audit Result

Bore Sampling Data for pH EC TDS WADCN <0.5 mg/L

Required Total CN Free CN

Pre Apr 16/Post Apr 16 WADCN

MB F01 Yes/Yes OK OK





MB F05A Yes/Yes OK OK













MB F25 No/No OK OK

MB F26 No/No OK OK


























Table C3: Quarterly chemistry analyses at monitoring bores compliance (Continued)

Monitoring Quarterly Audit Result Audit Result

Bore Sampling Data for pH EC TDS WADCN <0.5 mg/L

Required Total CN Free CN

Pre Apr 16/Post Apr 16 WADCN




















MB F76 No/No OK OK


MB F78 No/No OK OK








MB F86 No/No OK OK

NTD 1 Yes/Yes OK OK

NTD 2 Yes/Yes OK OK

NTD 3 Yes/Yes OK OK

NTD 4 Yes/Yes OK OK

NTD 5 Yes/Yes OK OK

NTD 6 Yes/Yes OK OK

TRE Yes/Yes OK OK

TRP 2 Yes/Yes OK OK



Table C4: Pond, trench, production bore pH and EC sampling compliance

Sampling L6420/1988 Audit

Point Requirement Result

Pre Apr 16/Post Apr 16

Decant 1 Quarterly/Quarterly OK

Decant 3 Quarterly/Quarterly OK

Fim I Nth Trench Quarterly/Quarterly OK

Fim II S Trench Quarterly/Quarterly OK



Table: C5 Pond, trench, production bore annual TDS, WADCN, Total CN, Free CN compliance

Sampling L6420/1988 Audit

Point Requirement Result

Pre Apr 16/Post Apr 16

Decant 1 Annual/Annual OK

Decant 3 Annual/Annual OK

Fim I Nth Trench Annual/Annual OK

Fim II S Trench Annual/Annual OK



Table C6: Production bore annual major component compliance

Sampling Annual Major Audit Audit

Point Components Result Comment

Required

PB F21 Yes OK Temp, Eh, DO, field HCO3, not included






PB F4A Yes OK Temp, Eh, DO, field HCO3, not included




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