Annual Audit Compliance Report Form€¦ · compliance: 9/1/2018 Details of non-compliance:...

IR-F14 v3.0 (September 2017)

Annual Audit Compliance Report Form Environmental Protection Act 1986, Part V

Once completed, please submit this form either via email to [email protected], or to the below postal address:

Department of Water and Environmental Regulation Locked Bag 33 Cloisters Square PERTH WA 6850

Section A – Licence Details

Licence number: 4611/1987/11 Licence file number: 2012/006836

Licence holder: Agnew Gold Mining Company Pty Ltd

Trading as: Agnew Gold Mining Company Pty Ltd

ACN: 098 385 883

Registered address:

Level 5, 50 Colin Street West Perth WA 60054

Reporting period: 01/01/2018 to 31/12/2018

Section B – Statement of Compliance with Licence Conditions

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

☐ Yes – please complete:

• section C;

• section D if required; and

• sign the declaration in Section F.

☒ No – please complete:

• section C; • section D if required; • section E; and • sign the declaration at Section F.

Section C – Statement of Actual Production

Provide the actual production quantity for this reporting period. Supporting documentation is to be attached.

Prescribed Premises Category Actual Production Quantity

5 1,180,496 tonnes [processing or beneficiation of metallic or non-metallic ore]

6 1,232,745 tonnes [Mine dewatering]

Section D – Statement of Actual Part 2 Waste Discharge Quantity

Provide the actual Part 2 waste discharge quantity for this reporting period. Supporting documentation is to be attached.

Prescribed Premises Category Actual Part 2 Waste Discharge Quantity

mailto:[email protected]

Department of Water and Environmental Regulation

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Annual Audit Compliance Report Form (September 2017)

Section D – Statement of Actual Part 2 Waste Discharge Quantity

89 2600 tonnes [Putrescible landfill site]

Section E – Details of Non-Compliance with Licence Condition

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

Condition no: 1.2.1 Date(s) of non-compliance: 9/1/2018

Details of non-compliance:

Tailings slurry spill – Redeemer TSF3 booster pumps were being tested due to a potential tailings blockage, the flushing water pipeline attached to the main Tailings Discharge pipeline disconnected, causing the tailings slurry to spill from the pipeline. It is estimated that approximately 250L of tailings was not contained within primary or secondary bunding. No impacts to vegetation have been identified. Two deceased zebra finches were identified on the outside of the primary bund where the tailings water had spilt. The two zebra finch carcasses were frozen and were sent offsite for autopsies. Water samples were taken and submitted for analysis. Preliminary site analysis results had WAD Cyanide levels of 55ppm. A pump was installed to remove all excess water into Redeemer TSF3. More detailed information regarding the incident was made available to DWER in an incident notification sent on 10/01/2018.

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

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

Approximately 12m2 of area was impacted by tailings outside secondary bunding, however no vegetation deaths were identified. Autopsies were conducted on the two-deceased zebra finches. One of the birds was seen drinking water that infiltrated out of the primary tailings bund, which subsequently died soon after. The other bird was in close proximity and already deceased. Necropsy and histopathology did not reveal the cause of the deaths and unfortunately due to the size of the birds toxicological testing for cyanide in gastrointestinal contents or tissues could not be conducted. No other cause of death was evident and therefore, given the clinical history, cyanide toxicity is possible but cannot be definitively confirmed.

Cause (or suspected cause) of non-compliance:

The factors that caused the incident were determined to be:

• Tails line was over pressurised with control philosophy disabled (this was identified as the main factor)

• Earlier high WAD cyanide level was not reported

• Peroxide dosing was not checked

• Lack of Training / Procedures / Task Instructions for any work carried out around the upgraded piping around TSF3 and TSF4

• Attempting to empty left over bulkies during commissioning rather than relying on the proven detox plant to maintain WAD cyanide levels

Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the non-compliance: Actions identified in the investigation of the incident include: 1. Re-enable high line pressure trip / shut down 2. Number of changes to be made to PLC logic (telemetry system) identified by engineering consultants as part of control philosophy review 3. Review all alarms / set points / interlocks / trip points to ensure they are correct and activated 4. Review TSF4 project for other potential failure points as part of commissioning 5. Recommission TSF utilising a detailed commissioning plan with the support of CPC and BEC Engineers 6. Finalise TSF4 operating manual (include booster pump change over process)


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Section E – Details of Non-Compliance with Licence Condition 7. Set up a weekly communication meeting for projects to include all stakeholders 8. Develop process control change logbook 9. Train all relevant operations personnel on operating TSF infrastructure 10. Replace Tapping Saddle with a welded T piece 11. Discuss the importance of WAD cyanide management to all processing personnel during restart meetings 12. Rollout expectation meetings with Supervisors particularly focusing on managing compliance within the processing facility 13. Recruit new Senior Project Engineer to strengthen projects team 14. Adjust morning technical meeting to capture daily tracking of WAD cyanide levels 15. Conduct internal audit of ICMC (Cyanide Code) system 16. Conduct ICMC (Cyanide Code) audit utilising external auditors

Was this non-compliance previously reported to DWER?

Yes, and

Reported to DWER verbally Date: / /

Reported to DWER in writing Date: 10/01/2018


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Condition no: 3.4.1 Date(s) of non-compliance:

5/1/18-10/1/18, 27/7/18, 10/8/18, 2/9/18, 8/9/18


It was identified that from 5/1/18 until 10/1/18 the supernatant water in Redeemer TSF3 exceeded the DWER Licence Limit of 50 ppm WAD Cyanide. It is suspected that the elevated WAD CN levels could have impacted on the reported incident whereby two zebra finches were found deceased near Redeemer TSF3 (see previous non-compliance detailed in this AACR). More detailed information regarding this incident was made available to DWER in an incident notification sent on 11/01/2018. Elevated WADCN levels were also recorded on the following dates: 27/7/2018, 10/8/2018, 2/9/2018 and 8/9/2018. Appropriate corrective action was taken.



No immediate impact on the environment was identified.


With regards to the incident occurring between 5/1/18 and 10/1/19, hydrogen peroxide addition commenced, however was sourced from 1000L containers, rather than the cyanide detoxification plant. Intent was to use remaining hydrogen peroxide in 1000L containers to safely dispose of remaining chemicals. Hydrogen Peroxide pump was started however was faulty and did not discharge enough hydrogen peroxide into the mill circuit all the time. In addition, daily WAD CN samples were taken, however it was not identified that the 50ppm limit had been exceeded, potentially due to operator error. In the case of the elevated measurements for 27/7/2018, 10/8/2018, 2/9/2018 and 8/9/2018, it is suspected that the levels were elevated due to the flow of hydrogen peroxide decreasing. Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the non-compliance: 5/1/18 and 10/1/19: Cyanide detoxification plant re-initiated to automatically add hydrogen peroxide – WAD Cyanide levels returned to below 50ppm. Faulty pump to be replaced prior to using 1000L containers. 27/7/2018, 10/8/2018, 2/9/2018 and 8/9/2018: hydrogen peroxide flow restored, additional samples taken.


Yes, and


Reported to DWER in writing Date: 11/01/2018 and February 2019 in AACR


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Return water leak from TSF2 tailings return water pipeline due to a corroded fitting failing causing water to leak from the valve. The majority of the leaked return water flowed back into the return water pond, however the wind blew some return water onto the adjacent disturbed road and into a creekline. It is estimated 10,000L of return water flowed into the creek. The return water had low cyanide levels. A water sample was taken for further analysis. No impacts to vegetation or creekline were identified. More detailed information regarding the incident was made available to DWER in an incident notification sent on 6/06/2018.



No impacts on the environment, vegetation or creekline were identified.


Corrosion of the pipe fitting

Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the non-compliance:

• Black fitting replaced by a stainless-steel fitting that is anti scalent corroded

• Inspection of all injection points on site and pipework inspections to be undertaken.

• Dosing point relocated to make sure spillage is contained in the bund.


Yes, and




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An unauthorized discharge of mine water occurred near the Hidden Secret Pit, where a series of mine dewatering pipelines discharge into the pit. The mine water which was discharged comes from the Vivien Mine Site (Vivien), operated by Ramelius Resources. The weight of the 400mm poly pipe (which runs over the crest of the Hidden Secret Pit) caused the poly pipe to kink approximately 10m over the crest. This kink caused back pressure in the line and water discharged out of a breather line approximately 20m back from the crest of the pit. It is difficult to gauge how long the discharge was occurring for, as due to the nature of the incident low pressure alarms were not triggered. Initial observations of the spill area and knowledge of the flow rate through the pipe allow us to estimate the discharge volume at approximately 50,000L.

Further information was made available to DWER through an incident notification submitted on 17/10/2018 with additional information sent on 7/11/2018.



Results of soil sampling at areas where mine dewatering has flowed indicates that the incident did not have impact on the area.


The infrastructure and breather line at the dewatering point was not suitable for the task, and has been replaced.

Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the non-compliance:

• Bunding to be installed around the Hidden Secret Discharge area to ensure any spills are contained to the discharge location

• Full audit of all mine dewatering lines to ensure there is no risk of discharge to the natural environment

• Discharge pipeline to have an elbow installed over the pit crest so that kinks in the pipeline will not be an ongoing issue.


Yes, and

Reported to DWER verbally Date: 12/10/2018



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Condition no: Condition 1.2.3 and Table 1.2.2

Date(s) of non-compliance: Throughout 2018


The records of inspections at mine dewater pipelines and tailings facilities (delivery pipelines, return water lines, tailings deposition, decant pond and internal embankment freeboard of TSF) were not maintained to the expected level outlined in condition 1.2.3 and table 1.2.2.



No adverse impact to the environment.


Records of inspections not entered/forms not completed or inspections missed due to errors and manning levels.

Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the non-compliance: More frequent checks of the record books will be undertaken by the Environment Department, Underground Shift bosses and Processing Department Supervisors. Education and awareness raising.


Yes, and

Reported to DWER verbally Date:

Reported to DWER in writing Date: February 2019 in AACR

Annual Audit Compliance Report Form€¦ · compliance: 9/1/2018 Details of non-compliance:...

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