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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
Rev 1 (Final) December 2016
Rev 2 (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
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KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 3
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
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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
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KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 5
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.
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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.
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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.
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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.
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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.
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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
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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
Reference Section Requirement Compliance Auditor
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
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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.
Reference Section Requirement Compliance Auditor
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
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• 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.
• Monitoring on Traverse 9 was undertaken at the correct location, but it is noted that the associated
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.
• Monitoring on Traverse 14 was undertaken at the correct location, but it is noted that the associated
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.
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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.
Reference Section Requirement Compliance Auditor
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.
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KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 15
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.
Reference Section Requirement Compliance Auditor
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
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 16
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
Reference Section Requirement Compliance Auditor
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
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 17
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.
Reference Section Requirement Compliance Auditor
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
within 9 monthsFull Not triggered
L6420/1988/14 Table 3.8.2WADCN >0.5mg/L in any
compliance bore
Increase pumping capacity
within 9 monthsFull Not triggered
L6420/1988/14 Section 3.8.3When advised by the CEO of
DER
Take further actions to further
reduce groundwater levelsFull Not triggered
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KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 18
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
Submit groundwater summary for Q4/2015 to
DER by 15 Feb 201615-Feb-16 Full Document sighted
L6420/1988/14Section 4.2.2
and Table 4.2.2
Submit groundwater summary for Q1/2016 to
DER by 16 May 201612-May-16 Full Document sighted
L6420/1988/14Section 4.2.2
and Table 4.2.2
Submit groundwater summary for Q2/2016 to
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
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 19
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).
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 20
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.
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 21
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.
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 22
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.
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 23
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.
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 24
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.
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 25
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.
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 26
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.
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 27
• 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.
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 28
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.
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KCGM FSGMP Annual Audit for 2016 Rev 2 (Final) Page 29
List of Figures 1. Facility locations
2. Trench and pond locations
3. Groundwater production locations
4. Groundwater monitoring locations
Big Dog Hydrogeology
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
356000
358000
358000
360000
360000
362000
362000
6590
000
6590
000
6592
000
6592
000
6594
000
6594
000
6596
000
6596
000
6598
000
6598
000
6600
000
6600
000
6602
000
6602
000Legend
") Mt Charlotte Headframe
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
Aust Rail Track Corp Railway Line
FimistonI TSF
FimistonII TSF
FimistonMill
A/BPaddock
C Paddock
D Paddock
Decant 3
Decant 1
356000
356000
357000
357000
358000
358000
359000
359000
360000
360000
361000
361000
362000
362000
363000
363000 6595
000
6596
000
6596
000
6597
000
6597
000
6598
000
6598
000
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.
´
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
Aust Rail Track Corp Railway Line
FimistonI TSF
FimistonII TSF
FimistonMill
A/BPaddock
C Paddock
D Paddock
1
2
3
4
4A
5
678910
1112
1416
18 20
21
22
23
24
25
26
27
28
30
32
33
34
35
36
37
38
39
40
41
42
43
44
45
47
48
49
5152
53
54
55
5657
6061
6465
6667
68
69 70
7172 73 74 75 76
7778 7980 81
8283
8485
8687 8889
9091
92
93
94 95
96
97 98 99100
101
102
103
105106
107
108
109110
112113
114115
116 117
118 119
120121122123
124125
126 127
128129
130131
132133134
135136137
138140
58
59
141142
356000
356000
357000
357000
358000
358000
359000
359000
360000
360000
361000
361000
362000
362000
363000
363000 6595000
6596000
6596000
6597000
6597000
6598000
6598000
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:
Date:
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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
357000
357000
358000
358000
359000
359000
360000
360000
361000
361000
362000
362000
6594000
6594000
6595000
6595000
6596000
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
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
Appendix A Certification of auditor independence
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Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
Appendix B Community Reference Group responses
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
Appendix C Detailed results of compliance assessment
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
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 F10 None/None H OK
MB F11 None/None H OK
MB F12 None/None H OK
MB F18 None/None 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 F25 None/None H OK
MB F26 None/None 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 F34 None/None H OK
MB F35 None/None H OK
MB F36 None/None H OK
MB F37 None/None H OK
MB F38 Q/Q H OK
MB F39 None/None H OK
MB F40 None/None H OK
MB F41 None/None H OK
MB F42 None/None H OK
MB F43 Q/Q H OK
MB F44 None/None H OK
MB F45 Q/Q H OK
MB F46 None/None H OK
MB F47 Q/Q H OK
MB F48 None/None H OK
MB F49 Q/Q H OK
MB F50 None/None H OK
MB F51 None/None H OK
Notes: Q Quarterly monitoring required
H Half yearly monitoring required
None No monitoring required (not in Schedule 1 Table 1)
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
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 F52 None/None H OK
MB F53 None/None H OK
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 F62 None/None H OK
MB F63 None/None H OK
MB F64 None/None H OK
MB F65 Q/Q H OK
MB F66 Q/Q H OK
MB F67 Q/Q H OK
MB F69 None/None 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 F76 None/None H OK
MB F77 Q/Q H OK
MB F78 None/None 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
MB F86 None/None H OK
NTD 1 None/None H OK
NTD 2 None/None H OK
NTD 3 None/None H OK
NTD 4 None/None H OK
NTD 5 None/None H OK
NTD 6 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)
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
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 F02 Yes/Yes OK MB F51 No/No OK
MB F03 Yes/Yes OK MB F52 No/No OK
MB F04 Yes/Yes OK MB F53 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 F07 Yes/Yes OK MB F57 Yes/Yes OK
MB F08 Yes/Yes OK MB F60 Yes/Yes OK
MB F09 Yes/Yes OK MB F61 Yes/Yes OK
MB F10 No/No OK MB F62 No/No OK
MB F11 No/No OK MB F63 No/No OK
MB F12 No/No OK MB F64 No/No OK
MB F18 No/No OK MB F65 Yes/Yes OK
MB F19 Yes/Yes OK MB F66 Yes/Yes OK
MB F20 Yes/Yes OK MB F67 Yes/Yes OK
MB F21 Yes/Yes OK MB F69 No/No OK
MB F23 Yes/Yes OK MB F72 Yes/Yes OK
MB F25 No/No OK MB F73 Yes/Yes OK
MB F26 No/No OK MB F74 Yes/Yes OK
MB F27 Yes/Yes OK MB F75 Yes/Yes OK
MB F30 Yes/Yes OK MB F76 No/No OK
MB F31 Yes/Yes OK MB F77 Yes/Yes OK
MB F32 Yes/Yes OK MB F78 No/No OK
MB F33 Yes/Yes OK MB F79 Yes/Yes OK
MB F34 No/No OK MB F80 Yes/Yes OK
MB F35 No/No OK MB F81 Yes/Yes OK
MB F36 No/No OK MB F82 Yes/Yes OK
MB F37 No/No OK MB F83 Yes/Yes OK
MB F38 Yes/Yes OK MB F84 Yes/Yes OK
MB F39 No/No OK MB F85 Yes/Yes OK
MB F40 No/No OK MB F86 No/No OK
MB F41 No/No OK NTD 1 No/No OK
MB F42 No/No OK NTD 2 No/No OK
MB F43 Yes/Yes OK NTD 3 No/No OK
MB F44 No/No OK NTD 4 No/No OK
MB F45 Yes/Yes OK NTD 5 No/No OK
MB F46 No/No OK NTD 6 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
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
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 F02 Yes/Yes OK OK
MB F03 Yes/Yes OK OK
MB F04 Yes/Yes OK OK
MB F05 Yes/Yes OK OK
MB F05A Yes/Yes OK OK
MB F06 Yes/Yes OK OK
MB F07 Yes/Yes OK OK
MB F08 Yes/Yes OK OK
MB F09 Yes/Yes OK OK
MB F10 Yes/Yes OK OK
MB F11 Yes/Yes OK OK
MB F12 Yes/Yes OK OK
MB F18 Yes/Yes OK OK
MB F19 Yes/Yes OK OK
MB F20 Yes/Yes OK OK
MB F21 Yes/Yes OK OK
MB F23 Yes/Yes OK OK
MB F25 No/No OK OK
MB F26 No/No OK OK
MB F27 Yes/Yes OK OK
MB F30 Yes/Yes OK OK
MB F31 Yes/Yes OK OK
MB F32 Yes/Yes OK OK
MB F33 Yes/Yes OK OK
MB F34 Yes/Yes OK OK
MB F35 Yes/Yes OK OK
MB F36 Yes/Yes OK OK
MB F37 Yes/Yes OK OK
MB F38 Yes/Yes OK OK
MB F39 Yes/Yes OK OK
MB F40 Yes/Yes OK OK
MB F41 Yes/Yes OK OK
MB F42 Yes/Yes OK OK
MB F43 Yes/Yes OK OK
MB F44 Yes/Yes OK OK
MB F45 Yes/Yes OK OK
MB F46 Yes/Yes OK OK
MB F47 Yes/Yes OK OK
MB F48 Yes/Yes OK OK
MB F49 Yes/Yes OK OK
MB F50 Yes/Yes OK OK
MB F51 Yes/Yes OK OK
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
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 F52 Yes/Yes OK OK
MB F53 Yes/Yes OK OK
MB F54 Yes/Yes OK OK
MB F55 Yes/Yes OK OK
MB F56 Yes/Yes OK OK
MB F57 Yes/Yes OK OK
MB F60 Yes/Yes OK OK
MB F61 Yes/Yes OK OK
MB F62 Yes/Yes OK OK
MB F63 Yes/Yes OK OK
MB F64 Yes/Yes OK OK
MB F65 Yes/Yes OK OK
MB F66 Yes/Yes OK OK
MB F67 Yes/Yes OK OK
MB F69 Yes/Yes OK OK
MB F72 Yes/Yes OK OK
MB F73 Yes/Yes OK OK
MB F74 Yes/Yes OK OK
MB F75 Yes/Yes OK OK
MB F76 No/No OK OK
MB F77 Yes/Yes OK OK
MB F78 No/No OK OK
MB F79 Yes/Yes OK OK
MB F80 Yes/Yes OK OK
MB F81 Yes/Yes OK OK
MB F82 Yes/Yes OK OK
MB F83 Yes/Yes OK OK
MB F84 Yes/Yes OK OK
MB F85 Yes/Yes 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
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
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
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
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
Big Dog Hydrogeology
KCGM FSGMP Annual Audit for 2016 Rev 2 (Final)
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 F26 Yes OK Temp, Eh, DO, field HCO3, not included
PB F33 Yes OK Temp, Eh, DO, field HCO3, not included
PB F34 Yes OK Temp, Eh, DO, field HCO3, not included
PB F44 Yes OK Temp, Eh, DO, field HCO3, not included
PB F48 Yes OK Temp, Eh, DO, field HCO3, not included
PB F4A Yes OK Temp, Eh, DO, field HCO3, not included
PB F51 Yes OK Temp, Eh, DO, field HCO3, not included
PB F65 Yes OK Temp, Eh, DO, field HCO3, not included
PB F66 Yes OK Temp, Eh, DO, field HCO3, not included