❓ A WA parliamentary question scrutinising KCGM's compliance with environmental regulations regarding pipeline bunding and potential breaches, particularly concerning tailings spills and dust monitoring.
AnsweredQoN 2888Legislative Council
QuestionView source ↗
I refer to a letter dated September 17 1999, signed for Fred Tromp, Director, Pollution Prevention Division , Department of Environmental Protection (DEP) addressed to General Manager, Kalgoorlie Consolidated Gold Mines, titled ‘Tailings Spill from Fimiston Tailings Line C’ and a letter which I understand maybe dated April 30 2003, signed by Wayne Astill for Michelle Andrews, Acting Director, Environmental Regulation Division addressed to Mr John Shipp, Kalgoorlie Consolidated Gold Mines (KCGM) -
(1) Can the Minister explain why KCGM was requested to undertake a review of all pipeline bunding within the Fimiston operations?
(2) If no to (1), why not?
(3) Can the Minister explain why KCGM was requested to confirm that the capacity of each bund is adequate for its particular circumstances?
(4) If no to (3), why not?
(5) Can the Minister explain why the design and construction of each bund must be adequate to ensure the strength of each is sufficient to allow the containment of the material likely to be spilt?
(6) If no to (5), why not?
(7) Can the Minister explain why the failure of bund walls should not occur?
(8) If no to (7), why not?
(9) Can the Minister explain for what reasons did the DEP state ‘Where a bund does not meet the above criteria, KCGM should undertake the appropriate works to ensure that they do’?
(10) Did the review conducted include all tailings delivery pipelines, return water pipelines, production borefield pipelines and hypersaline water pipelines?
(11) If no to (10), why not?
(12) Can the Minister state what the penalty was in 1999 for breaching a licence condition in relation to not having bunding of pipelines containing saline, alkaline or cyanide constituents?
(13) If no to (12), why not?
(14) Can the Minister explain why KCGM were not prosecuted for breaching licence conditions in 2002-2003 for not having bunding of pipelines as identified in the letter dated April 30 2003, given that the DoE had previously asked in 1999 that KCGM undertake a review of all pipeline bunding with the Fimiston operations?
(15) If no to (14), why not?
(16) Is the history of KCGM breaching licence conditions taken into consideration for current breaches in 2005 of Ministerial conditions relating to dust monitoring obligations, licence conditions and the Environmental Protection Policy for sulphur dioxide in relation to deciding to commence any prosecution proceedings?
(17) If no to (16), why not?
(1) Can the Minister explain why KCGM was requested to undertake a review of all pipeline bunding within the Fimiston operations?
(2) If no to (1), why not?
(3) Can the Minister explain why KCGM was requested to confirm that the capacity of each bund is adequate for its particular circumstances?
(4) If no to (3), why not?
(5) Can the Minister explain why the design and construction of each bund must be adequate to ensure the strength of each is sufficient to allow the containment of the material likely to be spilt?
(6) If no to (5), why not?
(7) Can the Minister explain why the failure of bund walls should not occur?
(8) If no to (7), why not?
(9) Can the Minister explain for what reasons did the DEP state ‘Where a bund does not meet the above criteria, KCGM should undertake the appropriate works to ensure that they do’?
(10) Did the review conducted include all tailings delivery pipelines, return water pipelines, production borefield pipelines and hypersaline water pipelines?
(11) If no to (10), why not?
(12) Can the Minister state what the penalty was in 1999 for breaching a licence condition in relation to not having bunding of pipelines containing saline, alkaline or cyanide constituents?
(13) If no to (12), why not?
(14) Can the Minister explain why KCGM were not prosecuted for breaching licence conditions in 2002-2003 for not having bunding of pipelines as identified in the letter dated April 30 2003, given that the DoE had previously asked in 1999 that KCGM undertake a review of all pipeline bunding with the Fimiston operations?
(15) If no to (14), why not?
(16) Is the history of KCGM breaching licence conditions taken into consideration for current breaches in 2005 of Ministerial conditions relating to dust monitoring obligations, licence conditions and the Environmental Protection Policy for sulphur dioxide in relation to deciding to commence any prosecution proceedings?
(17) If no to (16), why not?
AnswerView source ↗
Answered
1 December 2005
Responded by
Minister for Education and Training representing the Minister for the Environment
Response time
21 days
The Minister for the Environment; Science has provided the following response: (1) Yes. As stated in the letter, the review of the pipeline bunding was undertaken in response to a tailings spill incident that occurred on 23 August 1999 (See tabled paper no ). (2) Not applicable. (3) The purpose of bunds on tailings pipelines is to contain spills that occur when the pipelines rupture, to prevent tailings from entering the environment. As far as practicable a bund should have the capacity to contain a spill at maximum pumping rates for the period it would take to isolate the source and stop the flow. (4) Not applicable. (5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(1) Yes. As stated in the letter, the review of the pipeline bunding was undertaken in response to a tailings spill incident that occurred on 23 August 1999 (See tabled paper no ). (2) Not applicable. (3) The purpose of bunds on tailings pipelines is to contain spills that occur when the pipelines rupture, to prevent tailings from entering the environment. As far as practicable a bund should have the capacity to contain a spill at maximum pumping rates for the period it would take to isolate the source and stop the flow. (4) Not applicable. (5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(2) Not applicable. (3) The purpose of bunds on tailings pipelines is to contain spills that occur when the pipelines rupture, to prevent tailings from entering the environment. As far as practicable a bund should have the capacity to contain a spill at maximum pumping rates for the period it would take to isolate the source and stop the flow. (4) Not applicable. (5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(3) The purpose of bunds on tailings pipelines is to contain spills that occur when the pipelines rupture, to prevent tailings from entering the environment. As far as practicable a bund should have the capacity to contain a spill at maximum pumping rates for the period it would take to isolate the source and stop the flow. (4) Not applicable. (5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(4) Not applicable. (5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(17) Not applicable.
(1) Yes. As stated in the letter, the review of the pipeline bunding was undertaken in response to a tailings spill incident that occurred on 23 August 1999 (See tabled paper no ). (2) Not applicable. (3) The purpose of bunds on tailings pipelines is to contain spills that occur when the pipelines rupture, to prevent tailings from entering the environment. As far as practicable a bund should have the capacity to contain a spill at maximum pumping rates for the period it would take to isolate the source and stop the flow. (4) Not applicable. (5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(2) Not applicable. (3) The purpose of bunds on tailings pipelines is to contain spills that occur when the pipelines rupture, to prevent tailings from entering the environment. As far as practicable a bund should have the capacity to contain a spill at maximum pumping rates for the period it would take to isolate the source and stop the flow. (4) Not applicable. (5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(3) The purpose of bunds on tailings pipelines is to contain spills that occur when the pipelines rupture, to prevent tailings from entering the environment. As far as practicable a bund should have the capacity to contain a spill at maximum pumping rates for the period it would take to isolate the source and stop the flow. (4) Not applicable. (5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(4) Not applicable. (5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(5) The purpose of a bund is to prevent tailings from entering the environment where it has a greater potential to cause pollution or environmental harm. Therefore, the bund should be of sufficient strength to perform this function. (6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(6) Not applicable. (7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(7) To prevent tailings from leaving the bund and entering the surrounding environment where it has a greater potential to cause pollution or environmental harm. (8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(8) Not applicable. (9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(9) Yes. To ensure that the company was undertaking all practicable measures to ensure pipeline bunding was meeting the purposes and design requirements identified in questions (3), (5) and (7). (10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(10) Yes for the Fimiston operations. The report submitted by KCGM entitled, "Fimiston Operation Report on Pipeline Bunding October 1999". states that, " This report considers the term "Fimiston Operation" to be related to the tailings transfer, decant-water return and the Eastern Borefield pipeline corridors associated with Fimiston I and II Tailings Storage Facilities" (11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(11) Not applicable. (12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(12) The maximum penalty for contravention of a licence condition for a body corporate in 1999 was $125 000 or $25 000 per day. (13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(13) Not applicable. (14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(14) The letter dated April 30 2003 states that, " There appears to be no bunding of pipelines in the photographic evidence provided for Fimiston and Gidgi vegetation monitoring program ". Further examination of the photos showed that bunding was in fact visible in these areas. This was confirmed on 13 August 2003 during a site inspection of both premises were pipeline bunding was identified to be compliant with license conditions. (15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(15) Not applicable. (16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(16) The Department of Environments "Enforcement and Prosecution Policy" states that one of the considerations when choosing the appropriate enforcement action is " previous history of the offender with regard to the environment or compliance with DoE legislation, including frequency of offences ". (17) Not applicable.
(17) Not applicable.
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