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Government of Western Australia Application form: Department of Water and Environmental Regulation Works Approval / Licence / Renewal / Amendment / Registration Part V, Division 3, Environmental Protection Act 1986 Environmental Protection Regulations 1987
Part 1: Application type INSTRUCTIONS: • Completion of this form is a statutory requirement under section 54(1)(a) of the Environmental Protection Act 1986 (WA) (EP Act) for works approval applications; section 57(1)(a) for licence applications; section 59B(1)(a) for applications for an amendment; and under regulation 5B(2)(a) of the Environmental Protection Regulations 1987 (WA) (EP Regulations) for applications for registration of premises. • The instructions set out in this application form are general in nature. • A reference to ‘you’ in these instructions is a reference to the applicant. • The information provided to you by the Department of Water and Environmental Regulation (DWER) in relation to making applications does not constitute legal advice. DWER recommends that you obtain independent legal advice. • Applicants seeking further information relating to requirements under the EP Act and/or EP Regulations are directed to the Parliamentary Counsel’s Office website (www.legislation.wa.gov.au). Schedule 1 of the EP Regulations contains the categories of prescribed premises. • For prescribed premises where activities fall within more than one category, ALL applicable categories must be identified. This applies for existing prescribed premises seeking renewal or amendment, as well as new prescribed premises. • The application form must be completed with all relevant information attached. If there is insufficient space on any part of this form, please continue on a separate sheet of paper and attach to this form. If an application form has been submitted which is incomplete or materially incorrect, the Chief Executive Officer (CEO) of DWER will decline to deal with the application and advise the applicant accordingly. • On completing this application form, please submit it to DWER in line with the instructions in Part 14 of the form.
1.1 This is an application for: ~ Works approval [select only one option] under Part V, Division 3 of the EP Act □ Licence Please see Guidance Statement: Decision Existing registration number(s): [ ] Making for more information relating to the Existing works approval number(s): [ ] process for assessing and determining applications. □ Renewal Existing licence number: [ ]
□ Amendment Number of the existing licence or works approval to be amended: [ ]
□ Registration (works approval already obtained) Existing works approval number(s): [ ]
1.2 This application is for the following [Category 89; Class II Putrescible Landfill] categories of prescribed premises: (specify all prescribed premises category numbers)
All activities that meet the definition of a prescribed premises as set out in Schedule 1 of the EP Regulations have been specified above (tick, if yes).
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Completion Matrix The matrix below explains what sections are required to be completed for different types of applications. New Application/ Application Form Section Renewal Amendment Registration
Part 1: Application type ● ● ●
Part 2: Applicant details – sections 2.1 ● ● ●
Part 2: Applicant details – section 2.1 onwards ● ● Δ
Part 3: Premises details ● ● Δ
Part 4: Proposed activities ● ● ●
Part 5: Index of Biodiversity Surveys for Assessment If required. If required. If required.
Part 6: Other DWER approvals ● ● ●
Part 7: Other approvals and consultation ● ● ●
Part 8: Fit and competent operator ● ● Δ
Part 9: Emissions, discharges, and waste ● ● Δ
Part 10: Siting and location ● ● N/A
Part 11: Submission of any other relevant information ● ● If required.
Part 12: Proposed fee calculation ● ● ●
Part 13: Commercially sensitive or confidential ● ● ● information
Part 14: Submission of application ● ● ●
Part 15: Declaration and signature ● ● ●
Attachment 1A: Proof of occupier status ● ● N/A
Attachment 1B: ASIC company extract ● ● N/A
Attachment 1C: Authorisation to act as a representative If required. If required. If required. of the occupier
Attachment 2: Premises map/s ● ● Δ
Attachment 3A: Proposed activities ● ● Δ
Attachment 3B: Map of area proposed to be cleared ● ● ● (only applicable if clearing is proposed)
Attachment 3C: Additional information for clearing If required. If required. If required. assessment
Attachment 4: Biodiversity surveys (only applicable if ● ● ● biodiversity surveys included in application)
Attachment 5: Other approvals and consultation ● ● Δ documentation
Attachment 6A: Emissions and discharges If required. If required. If required.
Attachment 6B: Waste acceptance If required. If required. If required.
Attachment 7: Siting and location ● ● Δ
Attachment 8: Additional information submitted If required. If required. If required.
Attachment 9: Proposed fee calculation ● ● ●
Attachment 10: Request for exemption from publication If required. If required. If required.
Key: ● Must be submitted Δ to the extent changed/required in relation to the amendment N/A Not required with application, but may be requested subsequently depending on DWER records “If required” Sections for applicants to determine.
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Part 2: Applicant details
INSTRUCTIONS: • The applicant (the occupier of the premises) must be an individual(s), a company, body corporate, or public authority, but not a partnership, trust, or joint-venture name. Applications made by or on behalf of business names or unincorporated associations will not be accepted. • If applying as an individual, your full legal name must be inserted. • If applying as a company, body corporate, or public authority, the full legal entity name must be inserted. • Australian Company Number's (ACN) must be provided for all companies or body corporates. • DWER prefers to send all correspondence electronically via email. We request that you consent to receiving all correspondence relating to instruments and notices under Part V of the EP Act (“Part V documents”) electronically via email, by indicating your consent in Section 2.3. • Companies or body corporates making an application must nominate an authorised representative from within their organisation. Proof of authorisation will be required. • Details of a contact person must be provided for DWER enquiries in relation to your application. This contact person can be a consultant if authorised to represent the applicant. Written evidence of this authorisation must be provided. • Details of the occupier of the premises must be provided. One of the options must be selected and if you have been asked to specify, please provide details. For example, if ‘lease holder’ has been selected, please specify the type of lease (for example, pastoral lease, mining lease, or general lease) and provide a copy of the lease document(s). Note that contracts for sale of land will not be sufficient evidence of occupancy status.
2.1 Applicant name/s (full legal Covalent Lithium Pty Ltd name/s): [the proposed holder of the works approval, licence or registration]
ACN (if applicable):
2.2 Trading as (if applicable):
2.3 Authorised representative Name details: [the person authorised to receive correspondence and Position Part V documents on behalf of the applicant under the EP Telephone Act. Where ‘yes’ is selected, all correspondence will be sent Email to you via email, to the email address provided in this Yes No section. Where ‘no’ has been selected, Part V documents I consent to all written correspondence between myself (the will be posted to you in hard applicant) and DWER, regarding the subject of this copy to the postal / business application, being exclusively via email, using the email
address specified in section address I have provided above. ~ □ 2.4. Other general correspondence may still be sent to you via email.]
2.4 Address for receipt of Part V documents under the EP Act: [this must be a physical address to which a Part V document may be delivered.
2.5 Postal address for all other correspondence: [if different from section 2.4] -
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Part 2: Applicant details
2.6 Contact person details for Name DWER enquiries relating to the application (if different from the authorised Position representative): [for example, could be a Organisation consultant or a site based employee]
Address
Telephone
2.7 Occupier status: Registered proprietor on certificate of title □ [Occupier is defined in section 3 of the EP Act and Lease holder (please specify, including date of expiry of lease) includes a person in occupation or control of the Mining Tenement M77/1066 premises, or occupying a different part of the premises Expiry Date – 12/12/2025 whether or not that person is Public authority that has care, control or management of the land the owner.] □ Other (please specify – for example, joint venture operating entity, contract, or other legal document) □
Attachments N/A Yes 2.8 Attachment 1A: Proof of Copies of certificate of title, lease or other instruments occupier status evidencing proof of occupier status, including the expiry
date or confirmation that there is no expiry date, have been □ provided and labelled as Attachment 1A. 2.9 Attachment 1B: ASIC A current company information extract purchased from the company extract ASIC website(s) for all new applications/registrations has □ been provided and labelled as Attachment 1B. 2.10 Attachment 1C: A copy of the documentation authorising the applicant to Authorisation to act as act on the occupier’s behalf as their authorised
representative of the agent/representative has been provided and labelled as □ occupier Attachment 1C.
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Part 3: Premises details
3.1 Premises legal description (whole or Mining Tenement M77/1066 part to be specified): [Include the land description (volume and folio number, lot or location number/s); Crown lease or reserve number; pastoral lease number; or mining tenement number (as appropriate), of all properties, as shown on title details registered with Landgate.]
Premises street address [Include the suburb.]
Premises name (if applicable): Earl Grey Lithium Project
3.2 Local Government Authority area: Shire of Yilgarn [City, Town or Shire] 3.3 GPS or map coordinates: 762092mE by 6443886mN [GPS coordinates (latitude and longitude) must be provided where cadastre or mining tenements are not used as the premises boundary] Attachments N/A Yes 3.4 Attachment 2: An aerial photograph, map and site plan of the premises must be Premises map/s included as an attachment to this application form and labelled Attachment 2. You must provide an aerial photograph of sufficient scale showing the prescribed premises. You must also provide a map or maps of the prescribed premises, identifying: • layout of key infrastructure and buildings, clearly labelled; • the premises boundary; □ • emission and discharge points (with GPS coordinates where available); • sensitive receptors and land uses; and • all areas proposed to be cleared (if applicable). Maps must contain a north arrow, clearly marking the area in which the activities are carried out. The map or maps must be of reasonable clarity and have a visible scale.
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Part 4: Proposed activities INSTRUCTIONS: • You must provide a description and the scope, size and scale of all prescribed activities of Schedule 1 to the EP Regulations including the maximum production or design capacity of each prescribed activity. • If applying for a works approval or licence amendment involving the construction of new infrastructure, you must provide information on infrastructure to be constructed and how long construction is expected to take. You must confirm if commissioning is to occur and how long it will take. • If applying for a works approval or licence amendment not involving the construction of new infrastructure, provide details of the proposed amendment. • You must identify all emission sources on the premises map/s. • You must also provide information on activities which directly relate to the prescribed premises category which have, or are likely to result in, an emission or discharge. • If clearing activities are proposed provide a description and details. If a relevant exemption under Schedule 6 of the EP Act or regulation 5 of the Environmental Protection (Clearing of Native Vegetation) Regulations 2004 (WA) (Clearing Regulations) may apply, provide details. 4.1 Description/overview:
Covalent propose to undertake Minor or Preliminary Works in order to deconstruct and remove historic Mt Holland structures, plant, equipment, debris and waste materials (historical infrastructure) in order to remove environmental and safety hazards and ensure a safe site for future Covalent employees and Contractors. This will include the construction of a proposed Landfill (305 t/pa) under Category 64, according to Schedule 1 of the Environmental Protection Regulations 1987. The proposed landfill will be used to dispose of waste generated by the MPW workforce. Concrete from deconstructing the old processing facility on site is planned to be crushed, but if that is not possible, it will need to be landfilled as well.
4.2 Estimated operating period of the project / premises (e.g. based on 26 Weeks during Minor or estimated infrastructure life): Preliminary Works
4.3 Proposed date/s for commencement of works (if applicable): Q2 or 3 of 2019
4.4 Proposed date/s for commissioning of works (if applicable): Q2 or 3 of 2019
4.5 Proposed date/s for commencement of operations (if applicable): Q2 or 3 of 2019
4.6 Maximum production or design capacity for each category applied Landfill – 305 t/pa for (based on infrastructure operating 24 hours a day, 7 days a week): [Refer to categories listed in 1.2. Units must be consistent with Schedule 1 of the EP Regulations] 4.7 Estimated/actual throughput for each category applied for: Landfill – 305 t/pa [Refer to categories listed in 1.2. Units must be consistent with Schedule 1 of the EP Regulations] 4.8 Proposed activities: You must provide details of proposed activities, identifying: • scope, size and scale, including details as to frequency and production or design capacity; • key infrastructure and equipment; • description of processes or operations (a process flow chart may be included as an attachment); • emission/discharge points; • locations of waste storage or disposal; and • activities occurring during construction, commissioning and operation (if applicable). Additional information relating to the proposed activities may be included in Attachment 3A (see 4.10 below). See attachment 3A
Attachments N/A Yes 4.9 Attachment 2: Emission/discharge points are clearly labelled on the map/s
Premises map required for Part 3.4 (Attachment 2). □
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Part 4: Proposed activities 4.10 Attachment 3A: Additional information relating to the proposed activities
Proposed activities has been included in Attachment 3A (if required). Clearing activities [4.11 to 4.17 are only required if the application includes clearing of native vegetation] 4.11 Proposed clearing area (hectares and/or number of individual trees 0 to be removed): 4.12 Details of any relevant exemptions: Proposed facility is on already [refer to DWER’s A guide to the exemptions and regulations for clearing cleared land. native vegetation]
4.13 Proposed method of clearing: N/A
4.14 Period within which clearing is proposed to be undertaken: N/A [for example, May 2019 – June 2019] 4.15 Purpose of clearing: N/A
Clearing activities – Attachments N/A Yes 4.16 Attachment 3B: You must provide an aerial photograph or map of sufficient Map of area scale showing the proposed clearing area and prescribed proposed to be premises boundary cleared OR if you have the facilities, a suitable portable digital storage device of the area proposed to be cleared as an ESRI shapefile with the following properties: □ • Geometry type: Polygon Shape • Coordinate system: GDA 1994 (Geographic latitude/longitude) Datum: GDA 1994 (Geocentric Datum of Australia 1994). 4.17 Attachment 3C: Additional information to assist in the assessment of the clearing Additional proposal may be attached to this application (for example, information for reports on salinity, fauna or flora studies or other environmental □ clearing reports conducted for the site). assessment
Part 5: Index of Biodiversity Surveys for Assessments (IBSA) INSTRUCTIONS: • Biodiversity surveys submitted to support this application must meet the requirements of the EPA’s Instructions for the preparation of data packages for the Index of Biodiversity Surveys for Assessments (IBSA). • If these requirements are not met, DWER will decline to deal with the application. Attachments N/A Yes 5.1 Attachment 4: All biodiversity surveys submitted with this application meet the requirements of the EPA’s Instructions for the preparation of Biodiversity surveys data packages for the Index of Biodiversity Surveys for □ Assessments (IBSA).
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Part 6: Other DWER approvals INSTRUCTIONS: • If you have applied, or intend to apply, for other approvals within DWER that may be relevant to this application, you must provide relevant details. • If you have referred, or intend to refer, your proposal to the Environmental Protection Authority (EPA), you must provide details.
Pre-application scoping 6.1 Have you had any pre-application / pre- □ No referral / scoping meetings with DWER regarding any planned applications? ~ Yes – provide details: [17/12/2018 – meeting with Ana Mesquita and Louise Lavery regarding minor or preliminary works
Environmental Impact Assessment (Part IV of the EP Act) 6.2 Have you referred or do you intend to □ Yes refer the proposal to the EPA? Section 37B(1) of the EP Act defines a ‘significant □ Yes – intend to refer (proposal is a ‘significant proposal’) proposal’ as “a proposal likely, if implemented, to have a significant effect on the environment”. □ Yes – intend to refer (proposal will require a section 45C If DWER considers that the proposal in this amendment to the current Ministerial Statement): application is likely to constitute a ‘significant MS [ ] proposal’, DWER is required under section 38(5) of the EP Act to refer the proposal to the EPA for assessment under Part IV, if such a referral has □ No – a valid Ministerial Statement applies: MS [ ] not already been made. If a relevant Ministerial Statement already exists, ~ No – not a ‘significant proposal’ please provide the MS number in the space provided.
Clearing of Native Vegetation (Part V, Division 2 of the EP Act and Country Area Water Supply Act 1947)
6.3 Have you applied or do you intend to □ Yes – clearing application reference (if known): [ ] apply for a native vegetation clearing permit? □ No – this application includes clearing (please complete questions 4.11 to 4.17) In accordance with the Guidance Statement: Decision Making, where clearing of native vegetation is of an exempt kind under the □ No – a valid permit applies: CPS [ ] Environmental Protection (Clearing of Native Vegetation) Regulations 2004 (WA), or is being No – exemption applies (explain why): [ ] assessed by a relevant authority which would lead □ to an exemption under Schedule 6 of the EP Act, the clearing will not be assessed by DWER or be ~ No – permit not required subject to any additional controls by DWER. If the proposed clearing action is to be assessed in accordance with, or under, an Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act) accredited process, such as the assessment bilateral agreement, Form Annex C7 – Assessment bilateral agreement must be completed and attached to your clearing permit application.
6.4 Have you applied or do you intend to □ Yes – application reference (if known): [ ] apply for a Country Area Water Supply Act 1947 licence? □ No – a valid licence applies: [ ] If a clearing exemption applies in a Country Area Water Supply Act 1947 (CAWS) controlled ~ No – licence not required catchment, or if compensation has previously been paid to retain the subject vegetation, a Country Area Water Supply Act 1947 clearing licence is required. If yes, contact the nearest DWER regional office for a Form 1 Application for licence. Map of CAWS Act controlled catchments
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Part 6: Other DWER approvals
Water Licences and Permits (Rights in Water and Irrigation Act 1914) 6.5 Have you applied, or do you intend to □ Yes –application reference (if known): [ ] apply for: 1. a licence or amendment to a licence □ No – a valid licence / permit applies: [ ] to take water (surface water or groundwater); or ~ No – licence / permit not required 2. a licence to construct wells (including bores and soaks); or 3. a permit or amendment to a permit to interfere with the bed and banks of a watercourse?
Part 7: Other approvals and consultation
INSTRUCTIONS: • Please provide copies of all relevant documentation indicated below, including any conditions, exclusions, or expiry dates. • Major Project means: A State Development Project, where the lead agency is the Department of Jobs, Tourism, Science and Innovation (including projects to which a State Agreement applies); or A Level 2 or 3 Major Resource Project, as defined in the Lead Agency Framework. N/A No Yes 7.1 Is the proposal a Major Project? □ 7.2 Is the proposal subject to a State Agreement Act? □
If yes, specify which Act:
7.3 Has the proposal been allocated to a “Lead Agency”? □
If yes, specify Lead Agency contact details: DMIRS
7.4 Has the proposal been referred and/or assessed under the EPBC Act (Commonwealth)? □ □ If yes, please specify referral, assessment
and/or approval number: 7.5 Has the proposal obtained all relevant planning approvals? □ □
If planning approval is necessary but has not been obtained, please provide details indicating why:
If planning approval is not necessary, please provide details indicating why:
7.6 For renewals or amendment applications, are the relevant planning
approvals still valid (that is, not expired)? □ □ 7.7 Has the proposal obtained all other necessary statutory approvals (not including any other DWER approvals identified in Part 6)? □ □
If no, please provide details of approvals already obtained, outstanding approvals, and expected dates for obtaining these outstanding approvals:
Approval under Section 41A(3) of the EP Act 1986 for Minor or Preliminary Woks has been granted by the EPA (Attachment 5). Approval under the Mining Act 1978 is currently being sought from DMIRS.
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Part 7: Other approvals and consultation
N/A No Yes
7.8 Has consultation been undertaken with parties considered to have a direct interest in the proposal (that is, interested parties or persons who are considered to be directly affected by the proposal)? □ □ DWER will give consideration to submissions from interested parties or persons in accordance with the Guidance Statement: Decision Making.
Attachments N/A Yes
7.9 Attachment 5: Other Details of other approvals specified in Part 7 of this approvals and application, including copies of relevant decisions and any
consultation consultation undertaken with direct interest stakeholders □ documentation have been provided and labelled Attachment 5.
Part 8: Applicant history Note: • Under this section, DWER will undertake an internal due diligence of the applicant’s fitness and competency based on DWER’s compliance records. • If you wish to provide additional information for DWER to consider in making this assessment, you may provide that information as a separate attachment (see Part 11).
N/A No Yes
8.1 If the applicant is an individual, has the applicant previously held, or do they currently hold, a licence or works approval under Part V of the EP Act? □ □
8.2 If the applicant is a corporation, has any director of that corporation previously held, or do they currently hold, a licence or works approval under Part V of the □ □ EP Act?
8.3 If yes to 8.1 or 8.2 above, specify the name of company and/or licence or works approval number:
8.4 If the applicant is an individual, has the applicant ever been convicted, or paid a penalty, for an offence under a provision of the EP Act, its subsidiary legislation,
or similar environmental protection or health-related legislation in Western □ □ Australia or elsewhere in Australia? 8.5 If the applicant is a corporation, has any director of that corporation ever been convicted, or paid a penalty, for an offence under a provision of the EP Act, its
subsidiary legislation, or similar environmental protection or health-related □ □ legislation in Western Australia or elsewhere in Australia? 8.6 If the applicant is a corporation, has any person concerned in the management of the corporation, as referred to in section 118 of the EP Act, ever been convicted of, or paid a penalty, for an offence under a provision of the EP Act, its □ □ subsidiary legislation, or similar environmental protection or health-related legislation in Western Australia or elsewhere in Australia? 8.7 If the applicant is a corporation, has any director of that corporation ever been a director of another corporation that has been convicted, or paid a penalty, for an offence under a provision of the EP Act, its subsidiary legislation, or similar □ □ environmental protection or health-related legislation in Western Australia or elsewhere in Australia? 8.8 With regards to the questions posed in 8.4 to 8.7 above, have any legal proceedings been commenced, whether convicted or not, against the applicant for an offence under a provision of the EP Act, its subsidiary legislation, or □ □ similar environmental protection or health-related legislation in Western Australia or elsewhere in Australia? 8.9 Has the applicant had a licence or other authority suspended or revoked due to a breach of conditions or an offence under the EP Act or similar environmental
protection or health-related legislation in Western Australia or elsewhere in □ □ Australia?
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Part 8: Applicant history 8.10 If the applicant is a corporation, has any director of that corporation ever had a licence or other authority suspended or revoked due to a breach of conditions or
an offence under the EP Act or similar environmental protection or health-related □ □ legislation in Western Australia or elsewhere in Australia? 8.11 If the applicant is a corporation, has any director of that corporation ever been a director of another corporation that has ever had a licence or other authorisation suspended or revoked due to a breach of conditions or an offence under the EP □ □ Act or similar environmental protection or health-related legislation in Western Australia or elsewhere in Australia? 8.12 If yes to any of 8.4 to 8.11 above, you must provide details of any charges, convictions, penalties paid for an offence, and/or licences or other authorisations suspended or revoked:
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Part 9: Emissions, discharges, and waste
INSTRUCTIONS: • Please see Guidance Statement: Risk Assessments and provide all information relating to emission sources, pathways and receptors relevant to the application. • You must provide details on sources of emissions (for example, kiln stack, baghouses or discharge pipelines) including fugitive emissions (for example, noise, dust or odour), types of emissions (physical, chemical, or biological), and volumes, concentrations and durations of emissions. • The potential for emissions should be considered for all stages of the proposal (where relevant), including during construction, commissioning and operation of the premises. No Yes
9.1 Are there potential emissions or discharges arising from the proposed activities? □ If yes, identify all potential emissions and discharges arising from the proposed activities and complete the Emission Table below. □ Gaseous and particulate emissions (e.g. Dust (e.g. from equipment, unsealed roads emissions from stacks, chimneys or baghouses) and/or stockpiles) □ Wastewater discharges (e.g. treated sewage, Waste and leachate (e.g. emissions through wash water, or process water discharged to lands seepage, leaks and spills of waste from storage, or waters) process and handling areas) ~ Noise (e.g. from machinery operations and/or Odour (e.g. from wastes accepted at putrescible vehicle operations) landfills) □ Contaminated or potentially contaminated Electromagnetic radiation* stormwater (e.g. stormwater with the potential to come into contact with chemicals or waste materials) Other (please specify) [ ] □
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Part 9: Emissions, discharges, and waste
*For electromagnetic radiation, copies/details of other relevant approvals (such as from the Department of Mines, Industry Regulation and Safety or the Radiological Council) must be provided where applicable. Details of any pollution control equipment or waste treatment system, including any control mechanisms used to ensure proper operation of this equipment, must be included in the proposed controls column of the ‘Emissions and discharges table’ below. Details of management measures employed to control emissions should also be included.
Additional rows may be added as required and/or further information may be included as an attachment (see section 9.3). Emissions and discharges table: Source of Emission or Volume and Proposed Location (on emission or discharge type frequency controls site layout plan discharge – see 3.4) The landfill will be covered on a regular Landfill Odour Negligible basis (at least weekly) in See Attachment 2 order to minimise odours. • Vehicles and mining • Construction, equipment will keep earthwork and to designated roads
maintenance • Vehicles will be activities. required to travel at • Vehicle movements safe operating on unsealed roads. Dust Negligible speeds on unsealed See Attachment 2 • Combustion roads. emissions from • Dust suppression will earthmoving be carried out during equipment and light construction, vehicles. operation and closure. • Earthwork, construction, and maintenance activities. • All vehicles and plant • Landfill facility, equipment will be operational activities regularly maintained including machinery, Noise Negligible to ensure they are See Attachment 2 warning alarms and operating efficiently reversing vehicles and are not unduly sirens. noisy. • Transport of materials, equipment and wastes. Minor - depth to groundwater is around Landfill – putrescible Leachate and discharge 65 mbgl and only small No controls proposed. See Attachment 2 waste volumes of waste will be disposed of.
No Yes
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Part 9: Emissions, discharges, and waste 9.2 Is there waste accepted, buried, stored, or recycled on the premises?
(includes leachate and contaminated storm water generated and stored on the premises) Solid waste types must be described with reference to Landfill Waste Classification and Waste Definitions 1996 (as amended December 2009) and the Environmental Protection (Controlled Waste) Regulations 2004. Liquid waste types must be described with reference to the Environmental Protection (Controlled Waste) Regulations 2004. Detail must be provided on storage type (for example, hardstand and containment infrastructure), capacity, likely storage volumes, and containment features (for example, lining and bunding). Additional rows may be added as required and/or further information may be included as an attachment (see section 9.4). Waste acceptance table: Waste type Quantity Storage infrastructure Monitoring Location (on (e.g. (including specifications) (if site layout plan tonnes, applicable) – see 3.4) litres, cubic metres) The landfill design incorporates a costean/trench of approximately 20 m long by 10 m wide by 4 m deep excavation. The design length of 20 m incorporates a ramp down into the trench where the waste can be deposited and then compacted prior to more waste being deposited.
Prior to excavation works topsoil will be Domestic removed and stockpiled. Excavated (putrescible material will be used to cover waste on and non-putrescible), a weekly basis. Additional material will non- be placed around the edge of the landfill recyclablePutrescible to create a minimum height 1 m safety waste Up to 305 t/a bund. An appropriately sized fence will N/A Attachment 2 be erected around the boundary of the Type 1 waste landfill facility to ensure an effective barrier is in place to minimize access by animals to waste materials. The fence Clean fill for the minor or preliminary works landfill facility will also create a barrier for any waste material that may be blown out, and therefore minimise the potential of littering the surrounding environment. The landfill will be secured by a lockable gate to allow for the entry of vehicles and machinery. Signage will be put in place designating the waste types permitted to be placed into the landfill.
Attachments N/A Yes
9.3 Attachment 6A: Emissions If required, further information for Part 9.1 has been and discharges (if required) included as an attachment labelled Attachment 6A. □
9.4 Attachment 6B: Waste If required, further information for Part 9.2 has been acceptance (if required) included as an attachment labelled Attachment 6B. □
Part 10: Siting and Location 10.1 What is the distance to the nearest sensitive land uses (that is, a Accommodation Fly Camp located 1.5 residence or other land use which may be affected by an km away. emission or discharge associated with the proposed activities): No Yes
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Part 10: Siting and Location 10.2 Is the premises located within, or within close proximity to, any specified ecosystems, or any environmentally sensitive areas (ESAs) as declared under the Environmental Protection (Environmentally Sensitive) Notice 2005? □ (See Guidance Statement: Environmental Siting) If no, identify the distance in which there are no specified ecosystems and/or ESAs. If yes, provide details of the specified ecosystems and/or ESAs, and the distance to these: 350 m away from the nearest Banksia sphaerocarpa var. population. 700 m away from the nearest Microcorys sp. Mt Holland (D. Angus DA 2397). 10.3 If yes to 10.2, you must also provide further information including details on topography, geology, soil type, depth to groundwater and quality of groundwater at the premises. For premises answering no to 10.2, additional information including topography, geology, soil type, groundwater depth, and water quality is recommended to be included if this information is available.
See attachment 3A
Attachments N/A Yes
10.4 Attachment 7: Siting You must provide details and a map describing the siting and and location location of the premises, including identification of distances to □ sensitive land uses and/or any specified ecosystems. See attachment 3A
Part 11: Submission of any other relevant information Attachments No Yes 11.1 Attachment 8: Applicants seeking to submit further information may include Additional information information labelled Attachment 8. If submitting multiple submitted additional attachments, label them 8A, 8B, etc. □ Where supplementary documentation is submitted, please specify the name of documents below. List title of supplementary document/s attached:
Part 12: Proposed fee calculation
INSTRUCTIONS: To pay a fee via BPoint, or for information for paying via secure electronic funds transfer or cheque, consult DWER’s website at https://dwer.wa.gov.au/make-a-payment. If paying by credit card, select biller code “Industry Regulation”. Fee calculators are available online to assist in completing this section. • Licence: www.der.wa.gov.au/LicenceFeeCalculator • Works approval: www.der.wa.gov.au/WorksApprovalFeeCalculator • Amendment:: www.der.wa.gov.au/AmendmentFeeCalculator Different fee units apply for different fee components. Fee units may also have different amounts depending on the period in which the calculation is made. Further information on fees can be found in the Fact Sheet: Industry Regulation fees, available from DWER’s website.
12.1 Only the relevant fee calculations are to be completed ~ Section 12.3 for works approval applications as follows: □ Section 12.4 for licence applications [mark the box to indicate sections completed - for Section 12.5 for registration applications concurrent applications, each relevant fee section is □ to be completed] □ Section 12.6 for amendment applications □ Section 12.7 for applications requiring clearing of native vegetation 12.2 All information and data used for the calculation of proposed fees has been provided in
accordance with section 12.8.
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Part 12: Proposed fee calculation 12.3 Proposed works approval fee Proposed works approval fee (see Schedule 3 of the EP Regulations) Fees relate to the cost of the works, including all capital costs (inclusive of GST) associated with the construction and establishment of the works proposed under the works approval application. This includes, for example, costs associated with earth works, hard stands, drainage, plant hire, equipment, processing plant, relocation of equipment and labour hire. Costs exclude: - the cost of land; - the cost of buildings to be used for purposes unrelated to the purposes in respect of which the premises are, or will become, prescribed premises; costs for buildings unrelated to the prescribed premises activity or activities; and - consultancy fees relating to the works. Fee component Proposed fee
Cost of works: -
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12.4 Proposed licence fee Detailed licence fee calculations Part 1 Premises component (see regulation 5D and Part 1 of Schedule 4 of the EP Regulations) The production or design capacity should be the maximum capacity of the premises. For most categories the production or design capacity refers to an annual rate. The figure should be based on 24 hour operation for 365 days, unless there is another regulatory approval or technical reason that restricts operation. The premises component fee applies to the category in Part 1, Schedule 4 incurring the higher or highest amount of fee units in accordance with regulation 5D(2) of the EP Regulations. List all categories (insert additional rows as required). Use only the higher or highest amount of fee units to determine the Part 1 fee component. Category Production or design capacity Fee units
Using the higher or highest amount of fee units, Part 1 component subtotal I $ Part 2 Waste (see regulation 5D(1a)(b) and Part 2 of Schedule 4 of the EP Regulations) If your premises includes one or more of the following categories specify any applicable Part 2 waste amounts. Do not include Part 3 waste components of these discharges in the below sections. Categories: 5, 6, 7, 8, 9, 12, 14, 44, 46, 53, 54A, 70, 80, or 85B Part 2 waste means waste consisting of – (a) tailings; or (b) bitterns; or (c) water to allow mining of ore; or (d) flyash; or (e) waste water from a desalination plant. If the premises does not fall into one of the categories listed above, or there are no applicable Part 2 waste amounts, the sub total for this section will be $0. Insert additional rows as required. Sum all Part 2 waste fees to determine the sub total. Discharge quantity (tonnes/year) Fee units
Part 2 component subtotal I $ Part 3 Waste - Discharges to air, onto land, into waters (see Part 3 of Schedule 4 of the EP Regulations) Choose the appropriate location of the discharge and enter the discharge amount(s) in the units specified in the EP Regulations. This should be the amount of waste expected to be discharged over the next 12 months, expressed in the units and averaging period applicable for that waste kind (for example, g/minute or kg/day). Amounts can be measured, calculated, or estimated and can be based on data acquired over the previous 12 months, but should be based on the maximum premises capacity and not the forecast operating hours. Where there are discharges, all prescribed waste types must be considered in the fee calculation. If a specified waste type is not present in the discharge, this must be justified using an appropriate emission estimation technique (for example, sampling data, industry sector guidance notes, National Pollution Inventory guides and emission factors).
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Discharges to air
Discharge rate Discharge rate Discharges to air Discharges to air (g/min) (g/min)
Carbon monoxide I Nickel Oxides of nitrogen I Vanadium Sulphur oxides I Zinc Particulates (Total PM) I Vinyl chloride Volatile organic compounds I Hydrogen sulphide Inorganic fluoride I Benzene Pesticides I Carbon oxysulphide Aluminium I Carbon disulphide Arsenic I Acrylates Chromium I Beryllium Cobalt I Cadmium Copper I Mercury Lead TDI (toluene-2, I 4-di-iso-cyanate) Manganese MDI (diphenyl-methane I di-iso-cyanate) Molybdenum I Other waste Part 3 component subtotal $ Discharges onto land or into waters Discharge rate 1. Liquid waste that can potentially deprive (a) biochemical oxygen demand (in receiving waters of oxygen (for each the absence of chemical oxygen kilogram discharged per day) — demand limit) (b) chemical oxygen demand (in the absence of total organic carbon limit) (c) total organic carbon 2. Bio-stimulants (for each kilogram discharged (a) phosphorus per day) — (b) total nitrogen
3. Liquid waste that physically alters the (a) total suspended solids (for each characteristics of naturally occurring kilogram discharged per day) waters — (b) surfactants (for each kilogram discharged per day) (c) colour alteration (for each platinum cobalt unit of colour above the ambient colour of the waters in each megalitre discharged per day) (d) temperature alteration (for each 1°C above the ambient temperature of the waters in each megalitre discharged per day) — (i) in the sea south of the Tropic of Capricorn (ii) in other waters
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4. Waste that can potentially accumulate in the (a) aluminium environment or living tissue (for each kilogram discharged per day) — (b) arsenic (c) cadmium (d) chromium (e) cobalt (f) copper (g) lead (h) mercury (i) molybdenum (j) nickel (k) vanadium (l) zinc (m) pesticides (n) fish tainting wastes (o) manganese 5. E. coli bacteria as indicator species (in each (a) 1,000 to 5,000 organisms per 100 megalitre discharged per day) — ml (b) 5,000 to 20,000 organisms per 100 ml (c) more than 20,000 organisms per 100 ml 6. Other waste (per kilogram discharged per (a) oil and grease day) — (b) total dissolved solids (c) fluoride (d) iron (e) total residual chlorine (f) other Part 3 component subtotal $ Summary – Proposed licence fee Part 1 Component Part 2 Component Part 3 Component Total proposed licence fees: $
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12.5 Prescribed fee for registration A fee of 24 units applies for an application for registration of premises, unless the occupier of the premises holds a licence in respect of the premises, in □ (Tick to acknowledge) accordance with regulation 5B(2)(c) of the EP Regulations. 12.6 Works approval amendment or licence amendment fee Proposed works approval amendment or licence amendment fee (see Schedule 4 Part 1 of the EP Regulations). The fee prescribed for an application for an amendment to a works approval or licence is calculated in accordance with regulation 5BB(1)(a) of the EP Regulations: • for a single category of prescribed premises to which the works approval or licence relates, by using the fee unit number corresponding to the prescribed premises category and relevant production or design capacity threshold in Schedule 4 Part 1 of the EP Regulations. • for multiple categories of prescribed premises to which the works approval or licence relates, by using the highest fee unit number corresponding to the prescribed premises categories and production design or capacity threshold in Schedule 4 Part 1 of the EP Regulations. The relevant fee unit under Schedule 4 Part 1 of the EP Regulations for calculating the application form amendment fee is to be determined by reference to the actual production or design capacity reported for the preceding year’s annual licence fee. If an annual licence fee has not previously been paid or is not applicable as is the case for works approvals, the fee unit for an application for amendment is to be determined by reference to the production or design capacity currently prescribed in the licence or works approval. Fee Units Proposed fee $ 12.7 Prescribed fee for clearing permit In accordance with the Guidance Statement: Decision Making, where a concurrent application for clearing of native vegetation is made, DWER may elect to either jointly or separately determine the clearing component of the application. Where DWER separately determines the clearing component of a concurrent application, the application will be deemed to be an application for a clearing permit under section 51E of the EP Act and the CEO will waive the payment of the fee (Tick to acknowledge) prescribed in the Clearing Regulations for an application for clearing permit. □ Note: If a clearing permit application has been separately submitted and accepted by DWER, a refund for the clearing permit application will not be provided where DWER determines to address clearing requirements as part of a related works approval application. 12.8 Information and data used to calculate proposed fees The detailed calculations of fee components, including all information and data used for the calculations are to be provided as attachments to this application, labelled as Attachment 9, with an appropriate suffix (for example 9A, 9B etc.). Please specify the relevant attachment number in the space/s provided below. Proposed fee for works approval Attachment No Details for cost of works I 9 Proposed fee for licence Attachment No Part 1: Premises I Part 2: Waste types I Part 3: Discharges to air, onto land, into waters I
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Part 13: Commercially sensitive or confidential information
NOTE: Information submitted as part of this application will be made publicly available. If you wish to submit commercially sensitive or confidential information, please identify the information in Attachment 10, and include a written statement of reasons why you request each item of information be kept confidential. Information submitted later in the application process may also be made publicly available at DWER’s discretion. For any commercially sensitive or confidential information, please follow the same process as described above. DWER will take reasonable steps to protect genuinely confidential or commercially sensitive information. Please note in particular that all submitted information may be the subject of an application for release under the Freedom of Information Act 1992. All information which you would propose to be exempt from public disclosure has been separately placed in Attachment 10 (located at the end of this form). Grounds for claiming exemption in accordance with □ Schedule 1 to the Freedom of Information Act 1992 must be specified.
Part 14: Submission of application Check one of the boxes below to nominate how you will submit your application. Files larger than 50MB cannot be received via email by DWER. Files larger than 50MB can be sent via File Transfer. Alternatively, email DWER to make other arrangements. A full, signed, electronic copy of the application form including all attachments has been submitted via email to [email protected]; OR A signed, electronic copy of the application form has been submitted via email to [email protected] and attachments have been submitted via File Transfer, or electronically by other means as arranged with DWER; □ OR A full, signed hard copy has been sent to: APPLICATION SUBMISSIONS Department of Water and Environmental Regulation □ Locked Bag 33 Cloisters Square PERTH WA 6850
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Part 15: Declaration and signature General I/We confirm and acknowledge that: • the information contained in this application is true and correct and I/we acknowledge that knowingly providing information which is false or misleading in a material particular constitutes an offence under section 112 of the Environmental Protection Act 1986 (WA) and may incur a penalty of up to $50,000; • I/We have legal authority to sign on behalf of the applicant (where authorisation provided); • I/We have not altered the requirements and instructions set out in this application form; • I/We have provided a valid email address in Part 2.3 for receipt of correspondence electronically via email from DWER in relation to this application; • I/We acknowledge that successful delivery to my/our server constitutes receipt of correspondence sent electronically via email from DWER in relation to this application; and • I/We have provided a valid postal and/or business address in Part 2.4 for the service of all Part V documents.
Publication I/We confirm and acknowledge: • this application (including all attachments apart from the sections identified in Attachment 10) is a public document and may be published; • biodiversity surveys provided in accordance with Part 5 will be published and used, for the purposes of the IBSA project, in accordance with your declaration made in the Metadata and Licensing Statement; • all necessary consents for the publication of information have been obtained from third parties; • information considered exempt from public disclosure has been placed in Attachment 10 with reasons as to why the information should be exempt in accordance with the grounds specified in Schedule 1 to the Freedom of Information Act 1992 (WA); • subsequent information provided in relation to this application will be a public document and may be published unless written notice has been given to DWER by the applicant, at the time the information is provided, claiming that the information is considered exempt from public disclosure; and • the decision to not publish information will be at the discretion of the CEO of DWER and will be made consistently with the provisions of the Freedom of Information Act 1992 (WA).
Signature Date
Name
Position
NOTE: This form may be signed: • if the applicant is an individual, by the individual; • if the applicant is a corporation, by: the common seal being affixed in accordance with the Corporations Act 2001; or two directors; or a director and a company secretary; or if a proprietary company has a sole director who is also the sole company secretary, by that director; and • by a person with legal authority to sign on behalf of the applicant.
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ATTACHMENT 10 – Confidential or commercially sensitive information
Request for exemption from publication
Information which you consider should not be published, on the grounds of a relevant exemption found in Schedule 1 to the Freedom of Information Act 1992 (WA), must be specified in this Attachment. NOT FOR PUBLICATION IF GROUNDS FOR EXEMPTION ARE DETERMINED Section [x]: Ground for claiming exemption:
Section [x]: Ground for claiming exemption:
______Full Name and Signature
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Attachment 1A
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Register for Tenement M 77 / 1066 I Identifier: I M 77/1066 • I New Search I Previous I Next I Status: Live Area: 999. 60000 HA Markout: 12/ 02/ 2004 15 : 17 :00 Received: 12/ 02/ 2004 16 :28:00 Term Granted: 21 Years Commence: 13/12/ 2004 Ex piry: 12/12/ 2025 Death:
Holders Descr iption II Relationsh ips II Survey General Shire Grant I 11 11 11 Documents . Current Holders I Holder Changes II Applicants On Receival I
Organisation MONTAG UE RESOURCES AUSTRALIA PTY LTD 100/100 ACN ABN Principa l Place of Business Details Address SAME AS CORRESPONDENCE
Designated Tenement Contact (Correspondence Details) Address C/ - AU STWIDE MI NING TITLE MANAGE MENT PTY LTD, PO BOX 1434, WANGARA, WA, 6947
Department of Water and Environmental Regulation
Attachment 1C
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KIDMAN RESOURCES NE Suite, Lvl 30, 140 Williams St, Melbourne VIC 3000 p +61 3 9671 3801 e [email protected]
26 February 2019
Dr Phil Gorey Deputy Director General of Resource and Environmental Regulation DMIRS' Resource and Environmental Compliance Division 100 Plain Street Perth WA 6004
Dear Phil,
RE: Mt Holland / Earl Grey Lithium Project Mining Proposal for the Minor and Preliminary Works
We write this letter in support of the mining proposal submitted to the Department of Mines, Industry Regulation and Safety pursuant to the Mining Act 1978 (WA) on or around the date of this letter (Mining Proposal) by Covalent Lithium Pty Ltd (ACN 623 090 139) (Covalent) in relation to the minor and preliminary works to be undertaken with respect to the Earl Grey lithium deposit (forming part of the Mount Holland Lithium Project).
MH Gold Pty Ltd (MH Gold) and Montague Resources Australia Pty Ltd (Montague) (both wholly owned subsidiaries of Kidman Resources Limited (Kidman)) are currently the registered holders or applicants in relation to the tenements listed in the table below which are the subject of the Mining Proposal:
Tenement Registered Holder M77/1066 Montague M77/1080 Montague L77/176 MH Gold L77/194 MH Gold L77/208 MH Gold M77/1065 Montague G77/129 MH Gold G77/130 MH Gold G77/131 MH Gold G77/132 Montague G77/133 Montague L77/295 MH Gold L77/296 MH Gold L77/298 MH Gold
In relation to the tenements above highlighted grey, pursuant to a sale agreement dated 11 September 2017 (Sale Agreement), Kidman, Montague and MH Gold (amongst others) agreed to transfer 50% of their interests in such tenements to SQM Australia Pty Ltd (SQM). While a 50% beneficial interest in such
kidmanresources.com.au I ACN: 143 526 096
tenements passed to SQM on 21 December 2017, the formal transfer of such tenements has not yet occurred.
By way of an unincorporated joint venture agreement dated 21 December 2017 between MH Gold, Montague and SQM (amongst others) (JV Agreement) Covalent was appointed manager of the Mount Holland Lithium Project to develop the Earl Grey lithium deposit and has authority to apply for and carry out the Mining Proposal in relation to these tenements.
In relation to the remainder of the tenements above that are not highlighted grey, Kidman and SQM are in negotiations to transfer these into the JV Agreement. Whilst these negotiations are taking place, Kidman authorises Covalent to submit the Mining Proposal and access such tenements on Kidman’s behalf to carry out the Mining Proposal.
Kind regards,
Page 2 of 2 20190226_KDR_COV_Letter of Consent_Mining Proposal_Prelim Works
Department of Water and Environmental Regulation
Attachment 2
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Department of Water and Environmental Regulation
Attachment 3A
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1 EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS
M77/1066
WORKS APPROVAL APPLICATION - LANDFILL VERSION 1
PREPARED FOR:
COVALENT LITHIUM PTY LTD
Environmental Group Site Name: Earl Grey Lithium Project Environmental Group Site Code: New Project (TBD)
Contact Details Name: Susanna Beech Title: Manager Environment, Approvals and Community Postal Address: PO Box Z5200 St Georges Terrace Perth WA 6831 Phone: (08) 9230 5434 Email: [email protected]
Date of Submission: 1 April 2019 (Version 1)
PREPARED BY: Martinick Bosch Sell Pty Ltd 4 Cook Street West Perth WA 6005 Ph: (08) 9226 3166 Email: [email protected] Web: www.mbsenvironmental.com.au
MAHTINICK BOSCH SEU
ARN 60 102 614 479
environmental and geoscience consultants
EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION
Distribution List: Company Contact Name Copies Date Department of Mines, Industry Regulation and Rosemarie De Bari [01] 2 April 2019 Safety Covalent Lithium Pty Ltd Susanna Beech [01] 2 April 2019
Document Control for Job Number: CLWA Document Status Prepared by Authorised by Date Draft Report Jacob Azzarello Jonathon Barker 26 February 2019 Final Report Jonathon Barker Kristy Sell 2 April 2019
Disclaimer, Confidentiality and Copyright Statement This report is copyright. Ownership of the copyright remains with Martinick Bosch Sell Pty Ltd (MBS Environmental).
This report has been prepared for Covalent Lithium Pty Ltd on the basis of instructions and information provided by Covalent Lithium Pty Ltd and therefore may be subject to qualifications which are not expressed.
No other person other than those authorised in the distribution list may use or rely on this report without confirmation in writing from MBS Environmental. MBS Environmental has no liability to any other person who acts or relies upon any information contained in this report without confirmation.
This report has been checked and released for transmittal to Covalent Lithium Pty Ltd.
These Technical Reports: • Enjoy copyright protection and the copyright vests in Martinick Bosch Sell Pty Ltd (MBS Environmental) unless otherwise agreed in writing. • May not be reproduced or transmitted in any form or by any means whatsoever to any person without the written permission of the Copyright holder.
------Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx .11 COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION
TABLE OF CONTENTS
1. BACKGROUND INFORMATION ...... 1 1.1 OWNERSHIP AND THIRD PARTY AUTHORISATION ...... 1 1.2 PURPOSE ...... 1 1.3 PRESCRIBED PREMISE CATEGORIES ...... 5 1.4 STRUCTURE OF SUBMISSION ...... 5 2. BASELINE ENVIRONMENTAL DATA ...... 6 2.1 CLIMATE ...... 6 2.2.1 Regional Geology ...... 7 2.3 LANDFORMS ...... 8 2.4 SOILS AND SOIL PROPERTIES ...... 8 2.5 HYDROGEOLOGY ...... 8 2.5.1 Groundwater Quality ...... 9 2.7 FLORA AND VEGETATION ...... 10 2.7.1 Flora ...... 10 2.7.2 Vegetation Communities ...... 10 2.7.3 Conservations Significant Flora ...... 17 2.7.4 Introduced Species ...... 17 2.8.1 Fauna ...... 19 2.8.2 Fauna Habitat ...... 19 2.8.3 Conservation Significant Fauna ...... 20 2.8.4 Short Range Endemics ...... 25 2.8.5 Subterranean Fauna ...... 26 2.10 SOCIAL ENVIRONMENT ...... 27 2.10.1 Land Use ...... 27 2.10.2 Native Title ...... 27 2.10.3 Aboriginal Heritage ...... 27 2.10.4 European Heritage ...... 28 3. CHARACTERISTICS OF THE PROJECT ...... 29 3.1 KEY ACTIVITIES ...... 29 3.1.1 Landfill ...... 29 4. POLLUTION CONTROL ...... 31 4.1 EMISSIONS TO AIR ...... 31 4.1.1 Sources ...... 31 4.1.2 Receptors ...... 31 4.1.3 Potential Impacts ...... 31 4.1.4 Control Measures ...... 32 4.1.5 Predicted Residual Environmental Risk ...... 32 4.2 NOISE EMISSIONS ...... 32 4.2.1 Sources ...... 32 4.2.2 Receptors ...... 32 4.2.3 Potential Impacts ...... 33 4.2.4 Control Measures ...... 33 4.2.5 Predicted Residual Environmental Risk ...... 33 4.3 DISCHARGES TO SURFACE AND GROUNDWATER ...... 33 4.3.1 Sources ...... 33 4.3.2 Receptors ...... 33 4.3.3 Potential Impacts ...... 33 4.3.4 Control Measures ...... 34
------Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx .t COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION
4.3.5 Predicted Residual Environmental Risk ...... 34 4.4 DISCHARGES TO LAND ...... 34 4.4.1 Sources ...... 34 4.4.2 Receptors ...... 34 4.4.3 Potential Impacts ...... 34 4.4.4 Control Measures ...... 34 4.4.5 Predicted Residual Environmental Risk ...... 34 5. REFERENCES ...... 35
TABLES Table 1: Prescribed Premises Category from Schedule 1 of the Environmental Protection Regulations 1987...... 5 Table 2: Vegetation Communities at the Earl Grey Project ...... 11 Table 3: Comparison of Ironcap Hills Vegetation Complex to Vegetation Communities within the Development Envelope ...... 14 Table 4: Fauna Habitats at the Earl Grey Project ...... 19 Table 5: Conservation Significant Species with Potential to Occur in Minor or Preliminary Works Landfill Area and/or Surrounding Areas ...... 21 Table 6: Proposed Minor or Preliminary Works Key Characteristics Requiring a Works Approval ...... 29
FIGURES Figure 1: Project Location ...... 3 Figure 2: Indicative Site Layout and Prescribed Premise Boundary for the Earl Grey Lithium Project ...... 4 Figure 3: Vegetation Communities in the Minor or Preliminary Works Landfill Area ...... 16 Figure 4: Conservation Significant Flora in the Minor or Preliminary Works Landfill Area ...... 18 Figure 5: Fauna Habitat in the Minor or Preliminary Works Landfill Area ...... 23 Figure 6: Conservations Significant Fauna in the Minor or Preliminary Works Landfill Area ...... 24
CHARTS Chart 1: Climate Data ...... 7
APPENDICES Appendix 1 : Tenement Holders Approval Letters Appendix 2 : EPA Approval Notice For MPW
------Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx .t COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION
1. BACKGROUND INFORMATION The proposed Earl Grey Lithium Project (the project) is located 105 km south southeast of Southern Cross in the Shire of Yilgarn, Western Australia and is accessed from the Great Eastern Highway via Parker Range Road. No pastoral leases or agricultural activities occur near the project. The towns of Marvel Loch and Hyden are located 80 km north and 100 km west of the project, respectively (Figure 1).
The deposit and proposed operation are situated at the abandoned Mt Holland mine site (Mt Holland). Mt Holland was operated as a Gold Mine from 1988 to 2001 and comprised open pits, an underground mine, a processing plant, waste rock dumps, tailings storage facilities and other infrastructure. The mine which was abandoned in 2004 was left largely unrehabilitated and is currently a liability to the State of Western Australia.
The project is currently being formally assessed by the Environmental Protection Authority (EPA) under Part IV of the Environmental Protection Act 1986 (EP Act) at the level of Environmental Review (Public Consultation) (EPA Assessment 2123).
While the project is under formal assessment, Covalent Lithium Pty Ltd (Covalent) proposes to undertake minor and preliminary works.
1.1 OWNERSHIP AND THIRD PARTY AUTHORISATION The Earl Grey Lithium Project will be managed by Covalent Lithium Pty Ltd (Covalent) (ABN 70 623 090 139). Covalent is a joint venture between Kidman Resources Limited (Kidman) and Sociedad Química y Minera (SQMs).
Covalent have approval from all tenement holders to undertake the works on these tenements (Appendix 1).
The key proponent contact details for the project are:
Name: Susanna Beech Company: Covalent Lithium Pty Ltd Title: Manager Environment, Approvals and Community
Address: PO Box Z5200 St Georges Terrace Perth WA 6831 Phone: (08) 9230 5434 Email: [email protected] All compliance and regulatory requirements regarding the assessment document should be forwarded by post, courier or email to the following:
Name: Jonathon Barker Company: MBS Environmental Title: Senior Environmental Scientist
Address: 4 Cook Street West Perth WA 6005 Phone: (08) 9226 3166 Email: [email protected]
1.2 PURPOSE An application to obtain consent for minor or preliminary works was approved by the EPA on 13 March 2019 (Appendix 2) for:
Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 1 COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION
• Deconstruction and removal of historic Mt Holland structures, plant, equipment, debris and waste materials (historical infrastructure) to remove environmental and safety hazards and ensure a safe site for future Covalent employees and Contractors. • Construction of new groundwater bores. • Construction of new infrastructure required to carry out the Works including: − Construction of a 60 person Accommodation Camp (including waste water treatment plant (WWTP), landfill and water supply infrastructure). − Construction of site offices and storage areas. − Small scale concrete batching plant to supply concrete for construction. − 1 x 55 kL self bunded diesel storage tank to be stored at site office storage compound. • Upgrade/refurbishment of: − Existing power supply and communication infrastructure. − Maintenance of existing roads. − HDPE lined water storage ponds. • Storage of long lead infrastructure components required for the Project within existing disturbed areas.
In order to conduct these works, Covalent will need to construct an Accommodation Camp to house the workforce. The minor and preliminary works camp will consist 60 accommodation rooms and supporting facilities including an administration office area, kitchen and dining area, wet mess, laundry, potable water storage tanks, fuel tanks and recreational facilities. A landfill is proposed in this Works Approval Application to meet the waste disposal requirements of this workforce, as well as for the disposal of waste arising from demolition and site clean-up works.
An indicative site plan is presented in Figure 2.
Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 2 300000 m 450000 m 600000 m 750000 m 900000 m 1050000 m
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1.3 PRESCRIBED PREMISE CATEGORIES The proposed landfill facility falls under prescribed premise category 89, according to Schedule 1 of the Environmental Protection Regulations 1987 (Table 1).
Table 1: Prescribed Premises Category from Schedule 1 of the Environmental Protection Regulations 1987
Category Category Description Prescribed Premise Threshold No. Putrescible landfill site: premises on which waste is More than 20 but less than 5,000 89 accepted for burial. tonnes per year.
1.4 STRUCTURE OF SUBMISSION This application is structured into four sections as follows:
Section 1 provides an introduction to the Earl Grey Lithium Project including background details, the purpose of the application, information about the proponent, the location of the project, project tenure and prescribed premise categories.
Section 2 summarises the existing environmental aspects of the Earl Grey Lithium Project as it is relevant to this application.
Section 3 provides specific detail on key characteristics and features of the Earl Grey Lithium Project which are the subject of this application.
Section 4 describes pollution control measures as they apply to discharges to land, water, air and noise emissions, detailing pollution management and mitigation measures to prevent or reduce adverse environmental impacts.
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2. BASELINE ENVIRONMENTAL DATA The existing physical, biological and socio-economic characteristics in relation to the proposed minor or preliminary works Landfill of the Earl Grey Project are detailed in the following sections. This information was gathered during physical and biological surveys conducted specifically for the project.
2.1 CLIMATE The climate is semi-arid with a mean annual rainfall varying from 300 to 350 millimetres (mm), with mean and median annual rainfalls of 332 mm and 329 mm respectively. The rainfall that occurs during the early winter months of June and July tends to be more reliable and generally of a greater total amount than the less dependable, but more intense, summer rainfalls from January to March. Remnant tropical cyclones and associated depressions can occasionally bring heavy rains to the region; however, they are erratic in nature and occur infrequently. Minimum and maximum annual rainfalls of 156.2 and 558.3 mm, respectively, have been recorded at the Lake Carmody rainfall station (Chart 1).
On average, there are approximately 66 rain days each year, although this may be as low as 15 days and as high as 130 days. The longest period without rain was 138 days, between 1 November 1920 and 19 March 1921.
Temperatures recorded at the BOM Hyden synoptic station (Chart 1); situated approximately 88 kilometres west southwest of the project, indicate the following: • Mean daily maximum temperatures range from 33.7°C in January to 16.4°C in July. • Mean daily minimum temperatures range from 15.9°C in February to 4.6°C in July. • Highest and lowest daily temperatures of 48.6°C and -5.6°C have been recorded in February (2007) and July (1982) respectively. • Typically there will be in the order of 10 days each year with daily maximum temperatures in excess of 40°C, of which approximately 8.5 occur in December, January and February. • On average, minimum temperatures will be 2°C or less and light ground frosts are possible for 31 days each year. Two thirds of such days will occur in June, July and August.
In the absence of a local evaporation records, the average of pan evaporation data for the Merredin and Salmon Gums Research Stations has been applied to the project. This provides a mean annual pan evaporation of approximately 1,867 mm.
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- Mean Ra infall (Carmody) --Mean Max Temperature (Hyden) --Mean Min Tempterature (Hyden)
Chart 1: Climate Data
2.2 GEOLOGY
2.2.1 Regional Geology The Project is located in the Kalgoorlie Province in the Mt Holland Gold Field which covers southern sections of the Archaean Southern Cross – Forrestania Greenstone Belt. The Belt extends over 300 km and generally strikes NNW (Kidman 2017). Regional mapping identified two distinct lithostratigraphic units within the Belt; an ultramafic metavolcanic suite, and a sequence of overlying immature clastic metasediments. These units are regionally folded with a north plunging synform, steep east and shallow west limbs (East and West ultramafic-mafic domains) with a core of Package One ultramafic-mafic-sedimentary rocks (Kidman 2017).
The greenstones are predominantly mafic and ultramafic flows, generally intercalated with banded iron formations (BIF), cherts, and clastic sediments. Regional metamorphism is recorded at amphibolite grade, with local areas of retrograde chlorite metamorphic facies. The Belt is enclosed by syntectonic granitoids.
The Eastern Domain mafic-ultramafic basal rocks comprise a thick sequence of tholeiitic basalts with minor high- magnesium basalts and exhalative sediments. The basal rocks overlie a granitoid basement, and are overlain by the Bounty sequence. The Bounty sequence is approximately 600 m thick and consists of komatiitic peridotite flows and basalts which are intercalated with BIFs. This sequence is host to the Bounty Gold mine and the nickel mineralisation within the Forrestania Belt. A dolerite sill overlies the Bounty sequence and is the basal unit of the uppermost ultramafic suite, which also contains tholeiitic basalts and minor exhalative sediment horizons.
The basal rocks of the Western Domain consist of clastic metasediments which lie upon a younger intrusive granitoid (west). Stratigraphically above the basal metasediments are a thick package of (from bottom to top) komatiitic high MgO olivine orthocumulate; then a low MgO pyroxenite with locally developed dolerite-gabbro differentiates and intercalated flow sediments; then finally a unit of high MgO basalts with intercalated flow sediments (Kidman 2017).
The Central Domain consists mainly of pelitic and psammitic schists (± garnet), thin BIF lenses and bands of graphitic schists. Two major shear zones in the Forrestania Belt separate the three domains. The Mt Holland Shear defines the Central and Eastern Domains. Likewise, the Van Uden Shear separates the Central and Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 7 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION
Western Domains. Additional shear zones are recorded as parallel and crosscutting stratigraphy dominantly orientated north south; and north north-west to south southeast (Kidman 2017).
Lastly, NNE striking sets of Proterozoic dykes cut the three domains.
2.3 LANDFORMS The Project is located within the Southern Cross Zone, with the border of the Norseman Zone approximately 6 km to the east. The Southern Cross Zone is characterised by undulating plains and uplands (with some salt lake and low hills) on deeply weathered mantle, colluvium and alluvium over greenstone and granitic rocks, and is located the eastern Wheatbelt/south-western Goldfields between Bullfinch and Mt Holland. The Norseman Zone is characterised by undulating plains and uplands (with some sandplains and salt lakes) on granitic rocks of the Yilgarn Craton, located in the southern Goldfields between Koolyanobbing, Menzies, Zanthus (Trans-Australian Railway), Norseman and Lake Hope (MBS 2017).
Locally, there are no distinct, recognisable natural landforms in the Project area or surrounds. Topography within the disturbance envelope is generally subdued, with elevations ranging between 463 m RL Australian Height Datum (AHD) in the northwest and 390 m RL AHD in the southeast. The average elevation across the Project is approximately 435 m RL AHD.
Natural gradients across the Project area are very gentle, typically less than 2 degrees. The steepest natural gradients (5 – 6 degrees) are associated with a subtle ridgeline located to the northeast of the proposed Accommodation Camp. Steeper gradients are associated with the historic mining operation, where slope angles range from 15 – 20 degrees on waste rock dumps, 20 – 35 degrees on the TSFs or over 80 degrees in abandoned pits. Elevations of these landforms typically do not exceed 35 m above surrounding ground levels.
2.4 SOILS AND SOIL PROPERTIES Two physically and chemically distinctive soil types were identified within the Project area (MBS 2017) namely: • Duplex sandy gravel (DAFWA Soil Group 302). • Yellow/brown loamy duplex (DAFWA Soil Group 508).
Duplex sandy gravel soil profiles consist of a shallow gravelly sand A-horizon over a compacted lateritic gravel B- horizon. This soil type is present on topographically elevated areas and usually identified by association with sandplain heath vegetation with sparse to scattered low eucalypts. It is typically naturally strongly acidic throughout (with lower pH in the B-horizon), non-saline and low in sodicity. Deeper sand phases, indicated by the presence of Banksia species, may become water repellent when dry (MBS 2017).
Yellow/brown loamy duplex soil profiles consist of a shallow sandy loam A-horizon over a compacted sandy clay to clay loam B-horizon. This soil type is present on lower lying landscapes and drainage lines and usually identified by association with low eucalypt woodland and Melaleuca shrubs. The duplex character of profiles of this soil type is reflected by a circum-neutral, non-saline A-horizon over an alkaline, saline and highly sodic B- horizon (MBS 2017).
Surface soils of both soil types are characterised by very low concentrations of plant-available phosphorus and relatively high C/N values (MBS 2017).
2.5 HYDROGEOLOGY The project is located within the Westonia Groundwater Area of the Southern Cross Province. The main groundwater sources in the Southern Cross Province are derived from: • Regional catchment controlled flow systems in fresh and weathered fractured rock.
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• Tertiary palaeochannel sands. • Calcrete units that commonly overlie palaeochannel deposits. • Shallow alluvium.
Significant aquifer types in the Southern Cross region are derived from palaeochannel, calcrete and shallow alluvial deposits. Groundwater quality varies with salinity, generally increasing downstream along the drainage lines. The lowest salinity groundwater typically occurs beneath catchment divides. In the vicinity of Earl Grey, tertiary palaeochannel sediments comprise gypsiferous silt and sands to the east of the Project area.
The deep weathering profile of the ultramafic and basaltic sequences, characteristic of the Southern Cross region, comprises a thick siliceous caprock. Modest supplies of groundwater can be derived from fractured rock aquifers within this weathered zone. Fractured basement aquifers are characterised by secondary porosity and permeability, resulting in complex fracturing enhanced by chemical dissolution. The storage capacity and hydraulic conductivity of these aquifers is largely related to the degree of fracture intensity. In the vicinity of the Project area, fracturing below the caprock is prevalent, with the disturbance of siliceous magnesite veins. The groundwater supplies are typically saline to hypersaline.
Small quantities of potable water are known to occur in fractures within granite outcrops in the Southern Cross province. The limited exposure of granite indicates there is limited recharge potential and consequently is not considered sustainable as a project supply. No fresh water supplies have been identified near the Project area.
Groundwater Resource Management (GRM) completed baseline groundwater studies for the Mount Holland Project which incorporates the Earl Grey Project (GRM 2017)
The minor and preliminary works for the landfill are not expected to intersect the groundwater table.
2.5.1 Groundwater Quality Historic water quality data from various production and dewatering bores in the area indicates that natural groundwater quality can be characterised as follows: • Circumneutral to slightly acidic, with pH values varying between 6.1 and 7.1. • Hypersaline, with total dissolved solids (TDS) varying between approximately 70,000 mg/L and 120,000 mg/L. • Relatively consistent major ion composition, with sodium and chloride as the dominant ions. Sulfate, bicarbonate, calcium and magnesium are also present in elevated concentrations and the water is therefore classified as very hard. • Elevated boron and manganese concentrations that exceed long term irrigation trigger levels (ANZECC 2000). • Slightly elevated concentrations of other metals and metalloids including aluminium, beryllium, and copper, which are not of environmental significance.
The groundwater quality in the Earl Grey pit expansion area was found to be brackish to hypersaline, neutral to slightly alkaline and of the sodium chloride type. Iron ranged from 0.47 to 68.8 mg/L, with low concentrations of most other metal. Salinity was the greatest in the north eastern section of the proposed pit (GRM 2017).
The proposed landfill works are considered unlikely to impact groundwater quality.
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2.6 HYDROLOGY The project is located within the upper headwaters of the Lake Eva sub-catchment of the Avon/Yilgarn Basin. The Lake Eva sub-catchment has an area of approximately 15,240 km2 within the 58,000 km2 basin. Local creeks and drainages are ephemeral in nature, occurring periodically during the summer months from January to March, when the potential exposure to high intensity cyclonic or tropical depression related rainfall is greatest. Consequently, on occasion, flows may be high and may cause localised flooding if appropriate measures are not in place.
The Project area was subject to previous mining between 1988 and 2001. A combination of earth bunds and landforms dating from these earlier operations forms an effective drainage diversion around most of the site. Recent aerial imagery and site photos indicate no new watercourses or significant erosion gullies have formed as a result of flow concentration by these structures in the 20 years or more they have been in place.
Within the Project area, there are very few surface water features due to a limited total upper catchment area of less than 1,000 ha and the subdued relief. The only notable surface water feature is a constructed ephemeral drainage line that starts at the northwest tip of the airstrip and runs northeast past the processing plant area. Apart from this constructed drainage line, the Project area does not intersect any other identifiable drainage lines or creeks, with runoff generally occurring as sheetwash in a north-easterly direction. A small sub-catchment containing the southern end of the airstrip and accommodation village drains to the south. Runoff from the project area generally drains offsite as sheet flow and shallow concentrated flow in minor watercourses, flowing in a north- easterly direction.
2.7 FLORA AND VEGETATION Several assessments of flora and vegetation have been undertaken either in or within the vicinity of the project with the most recent detailed flora and vegetation assessment being completed by Mattiske in 2018 (Mattiske 2018 a, b and c).
2.7.1 Flora A total of 450 plant taxa were identified in the desktop assessment as having the potential to occur within the project area (Mattiske 2017b). These 450 taxa are representative of 54 families and 160 genera.
A total of 369 vascular plant taxa that are representative of 140 genera and 49 families were recorded across 214 survey quadrats. The majority of taxa recorded were representative of the Myrtaceae (73 taxa), Fabaceae (48 taxa), Proteaceae (42 taxa), Asteraceae (19 taxa), Rutaceae (17 taxa), and Ericaceae (11 taxa) families (Mattiske, 2018a). The majority of the taxa recorded were widespread both locally and more broadly within the associated biogeographical subregion.
2.7.2 Vegetation Communities The majority of the Proposal is situated on sandy, sandy clay or clay loam flats and gentle slopes supporting Eucalyptus mallee woodlands over Melaleuca shrublands.
Mattiske (2018a) defined and mapped 26 vegetation communities in the vicinity of the proposal. These comprised one heathland, three shrubland and 22 woodland communities (Table 2).
Within the areas mapped as cleared are smaller patches of highly degraded, ruderal vegetation. While still comprised of native species, these areas were deemed functionally cleared given the size of the vegetation patches and spatial context within existing cleared areas.
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Overall, the species recorded during the field survey, and the vegetation communities subsequently defined, are typical of the flora and vegetation which has been previously reported in the Forrestania region by Beard (1972, 1990), and in more recent surveys in the vicinity of the Project.
The condition of the vegetation ranged from excellent to completely degraded. These communities are shown in Figure 3.
No Threatened Ecological Communities (TEC), as listed by the Department of Biodiversity, Conservation and Attractions (DBCA), occur within the vicinity of the project. No TEC, pursuant to the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) and as listed by the Department of the Environment and Energy (DoEE), occur within the vicinity of the project.
The Development Envelope is situated wholly within the designated area for Ironcap Hills Vegetation Complexes (Mt Holland, Middle, North and South Ironcap Hills, Digger Rock and Hatter Hill) (banded ironstone), a Priority 3 Ecological Community (PEC). Banded ironstone formations or any form of outcropping are however not present within the Development Envelope. The terrain of the Project is gently undulating flats with occasional low rises, none of which exhibited any outcropping that would be indicative of the PEC. Two studies of the community have been done by Gibson (2004) and Thompson and Allen (2013), with the more recent study focused on the Mt Holland area in the vicinity of the proposal.
Table 2: Vegetation Communities at the Earl Grey Project
Area within Area Disturbance Land to be Code Description Mapped Envelope cleared (ha) (Ha) (ha)
Woodlands W4 Eucalyptus flocktoniae subsp. flocktoniae, Eucalyptus eremophila low open mallee woodland over Melaleuca depauperata, Callitris canescens, Melaleuca phoidophylla mid-tall sparse shrubland over Acacia tetraptera, 235.8 7.1 0.0 Grevillea acuaria low isolated heath shrubs on orange brown sandy clay soils with ironstone or quartz pebbles on flats and slopes. W5 Eucalyptus rigidula, Eucalyptus burracoppinensis low open mallee woodland over Micromyrtus erichsenii, Persoonia helix, Hakea erecta mid 138.7 9.4 0.0 sparse heathland over Hibbertia rostellata, Hibbertia stowardii low isolated shrubs on gravelly orange brown clayey sand soils on flats and slopes. W6 Eucalyptus burracoppinensis, Allocasuarina acutivalvis, Allocasuarina spinosissima tall open mallee woodland over Hakea erecta, Petrophile stricta, Banksia laevigata subsp. fuscolutea mid sparse heathland over 82.3 12.3 0.0 Drummondita hassellii, Hibbertia exasperata, Psammomoya choretroides low sparse shrubland on yellow brown sandy soils on flats. W7 Burnt Eucalyptus sp. (E. cylindriflora, E. flocktoniae subsp. flocktoniae, E. prolixa, E. salmonophloia, E. eremophila, E. capillosa subsp. polyclada) low open woodland over Melaleuca hamata, Melaleuca eleuterostachya mid 85.2 0.0 0.0 sparse shrubland over Daviesia argillacea, Acacia hemiteles, Acacia deficiens low sparse heathland on orange brown sandy clay soils on flats. W8 Eucalyptus prolixa, Eucalyptus salmonophloia, Eucalyptus urna mid mallee woodland over Santalum acuminatum, Daviesia argillacea, Melaleuca eleuterostachya mid sparse heathland over Acacia merrallii, Daviesia 259.0 1.7 0.0 argillacea, Microcybe multiflora subsp. multiflora low sparse shrubland on red brown sandy clay flats. W9 Eucalyptus urna, Eucalyptus ravida, Eucalyptus prolixa low mallee woodland over Melaleuca pauperiflora, Dodonaea stenozyga, Daviesia 559.0 267.3 0.0 argillacea mid sparse shrubland over Acacia merrallii, Grevillea acuaria, Microcybe multiflora subsp. multiflora low sparse shrubland.
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Area within Area Disturbance Land to be Code Description Mapped Envelope cleared (ha) (Ha) (ha)
W10 Eucalyptus sp. (E. urna, E. cylindrocarpa, E, rigidula, E gracilis) low mallee woodland over Melaleuca pauperiflora, Daviesia scoparia mid sparse 49.0 0.0 0.0 shrubland over Acacia merrallii, Grevillea huegelii, Olearia muelleri low sparse shrubland on red clay soils on flats. W11 Eucalyptus eremophila, Eucalyptus rigidula, Eucalyptus flocktoniae subsp. flocktoniae low mallee woodland over Melaleuca lateriflora, Melaleuca eleuterostachya, Melaleuca acuminata subsp. acuminata mid sparse 600.1 173.2 0.0 shrubland over Grevillea acuaria, Acacia hystrix subsp. hystrix, Microcybe ambigua low sparse shrubland on orange brown clay soils on flats. W12 Eucalyptus cylindriflora, Eucalyptus cylindrocarpa, Eucalyptus prolixa low open mallee woodland over Melaleuca eleuterostachya, Melaleuca lateriflora, Daviesia argillacea mid sparse shrubland over Grevillea acuaria, 186.8 75.3 0.0 Acacia merrallii, Acacia camptoclada low sparse shrubland on yellow brown to red brown sandy clay soils on flats. W13 Callitris canescens, Eucalyptus rigidula low open mallee woodland over Micromyrtus erichsenii, Persoonia helix, Allocasuarina spinosissima mid tall sparse shrubland over Beyeria sulcata, Drummondita hassellii low sparse 370.4 226.7 0.0 shrubland on yellow brown to orange brown clayey sands on flats and slopes. W14 Burnt Eucalyptus salmonophloia, Eucalyptus eremophila mid open woodland over Santalum acuminatum, Senna artemisioides subsp. filifolia 61.0 5.2 0.0 mid sparse shrubland over Acacia hemiteles, Olearia muelleri low sparse shrubland on orange brown clay spoils on flats. W15 Burnt Allocasuarina acutivalvis, Eucalyptus sp. (E. cylindriflora, E. eremophila, E, gracilis, E. rigidula, E. burracoppinensis) low open mallee woodland over Hakea minyma, Melaleuca cordata, Melaleuca hamata mid 174.3 0.1 0.0 sparse shrubland over Dampiera sacculata, Pimelea sulfurea, Hybanthus floribundus subsp. floribundus low sparse forbland. W16 Burnt Eucalyptus sp. (E. cylindriflora, E. tenuis, E. burracoppinensis, E. eremophila) low open mallee woodland over Persoonia helix, Gastrolobium spinosum, Acacia assimilis mid sparse shrubland over Dampiera tenuicaulis 113.7 2.8 0.0 subsp. curvula, Glischrocaryon aureum, Dampiera eriocephala low sparse forbland on orange red gravelly sandy loam soils on flats. W17 Burnt Eucalyptus sp. (E. cylindriflora, E. tenuis, E. burracoppinensis, E. eremophila) low open mallee woodland over Persoonia helix, Gastrolobium spinosum, Acacia assimilis mid sparse shrubland over Dampiera tenuicaulis 2.8 2.8 0.0 subsp. curvula, Glischrocaryon aureum, Dampiera eriocephala low sparse forbland on orange red gravelly sandy loam soils on flats. W18 Eucalyptus rigidula. Eucalyptus platycorys, Callitris canescens low open mallee woodland over Melaleuca hamata, Allocasuarina spinosissima, Hakea erecta mid sparse shrubland over Hibbertia gracilipes, Phebalium 69.3 3.8 0.0 obovatum, Cyathostemon heterantherus low sparse shrubland on yellow brown sandy soils on flats. W19 Eucalyptus prolixa low open mallee woodland over Daviesia argillacea, Santalum acuminatum mid sparse shrubland over Acacia merrallii, 68.6 50.6 0.0 Microcybe ambigua, Grevillea acuaria low sparse shrubland on orange-red brown sandy clay soils on flats. W20 Burnt Eucalyptus urna, Eucalyptus salmonophloia, Eucalyptus tenuis mid open mallee woodland over Melaleuca pauperiflora mid sparse shrubland 48.3 16.7 0.0 over Acacia deficiens, Daviesia argillacea, Daviesia grahamii low sparse shrubland on red brown clay soils on flats.
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Area within Area Disturbance Land to be Code Description Mapped Envelope cleared (ha) (Ha) (ha)
W21 Eucalyptus eremophila, Eucalyptus flocktoniae subsp. flocktoniae low open mallee woodland over Melaleuca hamata over Acacia acanthoclada subsp. acanthoclada, Dampiera sacculata, Westringia cephalantha subsp. 21.3 173.2 0.0 cephalantha low sparse shrubland on grey brown clayey sand soils on flats and slopes. W22 Eucalyptus eremophila low open mallee woodland over Melaleuca hamata, Melaleuca eleuterostachya, Melaleuca laxiflora mid sparse shrubland over Hibbertia exasperata, Cyathostemon heterantherus, Acacia sphacelata 66.0 11.1 0.0 subsp. sphacelata low sparse shrubland on slightly gravelly yellow-orange brown clay soils on flats and slopes. Mallee Woodlands MW6 Eucalyptus burracoppinensis, Eucalyptus eremophila mid open mallee woodland over Thryptomene kochii, Melaleuca laxiflora, Acacia acuminata mid open shrubland over Drummondita hasseli, Microcybe ambigua low 112.0 6.3 0.0 sparse heathland on grey–brown to orange–brown clay to clay sand, often with scattered ironstone pebbles on flats. MW7 Eucalyptus capillosa subsp. polyclada mid open mallee woodland over Allocasuarina spinosissima, Callitris canescens, Hakea minyma mid tall 63.1 45.3 0.0 sparse shrubland over Phebalium megaphyllum low sparse shrubland on orange brown clay soils on flats and slopes. MW8 Eucalyptus eremophila low open mallee woodland over Melaleuca hamata, Leptospermum erubescens, Melaleuca lateriflora mid sparse shrubland over Thomasia sp. Salmon Gums (C.A. Gardner s.n. PERTH 02708639), 2.5 0.4 0.0 Darwinia sp. Karonie (K. Newbey 8503) low sparse shrubland on orange brown clay in minor drainage channel. Shrubland S1 Allocasuarina acutivalvis, Allocasuarina spinosissima tall closed shrubland over Hakea subsulcata, Melaleuca cordata, Micromyrtus erichsenii mid 65.0 27.0 0.0 sparse heathland on lateritic orange-red clay soils on flats and lower slopes. S2 Allocasuarina acutivalvis, Allocasuarina spinosissima, Eucalyptus burracoppinensis tall open shrubland over Thryptomene kochii, Persoonia helix, Micromyrtus erichsenii mid sparse heathland over Cyathostemon 228.2 71.6 0.0 heterantherus, Hibbertia exasperata, Drummondita hassellii low sparse shrubland on orange brown clayey sand soils on flats. S3 Allocasuarina acutivalvis, Eucalyptus burracoppinensis tall sparse shrubland over Banksia purdieana, Hakea subsulcata, Melaleuca cordata mid sparse 38.5 0.0 shrubland over Micromyrtus erichsenii, Persoonia helix low isolated shrubs 106.0 on gravelly yellow brown to orange brown clay to clayey sand soils on flats. Heathland H1 Melaleuca cliffortioides, Allocasuarina campestris, Dodonaea adenophora mid open heathland over Grevillea lissopleura (P1), Trymalium myrtillus 2.0 0.0 0.0 subsp. myrtillus low sparse shrubland on rocky red-brown sandy clay soils on slopes. Cleared Land Cleared land, includes isolated small patches of degraded ruderal 647.4 351.3 0.0 CL vegetation.
A qualitative review of species and vegetation communities observed within the Development Envelope as compared to the Ironcap Hills vegetation complexes defined by Thompson and Allen (2013) is shown in Table 3. The comparison reveals a poor correlation between the identified vegetation communities, dominant vegetation types and representative species associated with Ironcap Hills Vegetation Complexes in addition to the lack of comparative landforms and geology associated with the PEC.
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Notable in Table 3 as compared to surveyed dominant vegetation described in Table 2 for the Development Envelope is the lack of correlation between dominant groupings. Even when dominant vegetation shows some degree of correlation, such as Community types 2 and 4 in Table 3, the dominant species were found to correlate to dominance in disparate surveyed communities under Table 2, often with notable geographic separation. The most notable correlation was between Community type 4 and local vegetation community W11, which still lacks a level of significance to suggest the presence of the PEC in the Development Envelope.
Based on the lack of a strong correlation between surveyed vegetation communities and species composition within the Development Envelope to the Ironcap Hills Vegetation Complexes, coincident with a lack of associated landforms, would support the proposition that the Proposal is not of consequence in relation to the Ironcap Hills PEC.
Table 3: Comparison of Ironcap Hills Vegetation Complex to Vegetation Communities within the Development Envelope
Representative Species Ironcap Hill PEC Geology/Landform Dominant Vegetation Found in Development Surveyed Community Envelope
Community Number 1 Predominantly upland Allocasuarina acutivalvis and 33 of 81 Present (41%) basalt/laterite sites with gentle Acacia yorkrakinensis subsp. gradients acrita over Melaleuca calyptroides, Thryptomene kochii, Hibbertia exasperata and Drummondita hassellii. Community Number 2 Upland sites characterised by Allocasuarina campestris over 25 of 63 Present (40%) granular or banded ironstone Calothamnus quadrifidus subsp. coarse fragments seminudus, Hakea subsulcata and Melaleuca cordata over Stenanthemum stipulosum and Stylidium sejunctum. Community Number 3 Upland laterite and weathered Eucalyptus eremophila, Acacia 26 of 61 Present (43%) ironstone sites castanostegia, Baeckea crispiflora, Beyeria sulcata, Hakea multilineata, Melaleuca hamata and Stenanthemum stipulosum over Phebalium filifolium and Platysace maxwellii over Lepidosperma sp. A2 Inland Flat. Community Number 4 Laterite and basalt sites with gentle E. flocktoniae and Allocasuarina 27 of 64 Present (42%) slopes acutivalvis over Dodonaea bursariifolia, M. acuminata subsp. acuminata, M. hamata, M. lateriflora subsp. lateriflora and Grevillea acuaria. Community Number 5 Coarse rock fragments E. salubris over D. stenozyga, 20 of 40 Present (50%) predominantly basalt and Trymalium myrtillus subsp. undifferentiated greenstone with myrtillus and G. acuaria with slight presence of exposed Thysanotus patersonii. bedrock recorded as basalt Community Number 6 Footslopes and pediments with E. calycogona subsp. calycogona, 36 of 84 Present (43%) little slope Exocarpos aphyllus and Santalum acuminatum over D. stenozyga, G. acuaria over Acacia erinacea and Wilsonia humilis. Community Number 7 Most widespread distribution Eucalyptus extensa over A. 24 of 59 Present (41%) characterised by the presence of merrallii, Daviesia articulata and calcrete in the substrate and low Dodonaea stenozyga with W. species richness humilis.
Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 14 COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION
Representative Species Ironcap Hill PEC Geology/Landform Dominant Vegetation Found in Development Surveyed Community Envelope
Community Number 8 Plains with little or no gradient E. salmonophloia over 24 of 59 Present (41%) Santalum acuminatum over A. merrallii, Daviesia scoparia, Eremophila ionantha and Olearia muelleri with Austrostipa elegantissima.
The minor and preliminary works for the landfill are proposed to take place on already disturbed and cleared land with no vegetation proposed to be cleared.
Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 15 E c::J .....,_ Minor nl l'l VIVI 17 I N-2018-m•• I - 0..ralt.nl - H1 --IIIW7 - szSI.""" - ssWIO - WU - Wl2 Wll Wl♦ - Wl.5 \ - Wit W17 - W1' - W19 --Wll - W5W,tWZI -~I'llW1w, 7f:1111111Jm ~ntLitNum Ply Lid Flgul93 D 1km Earl 018'f utliklm Pm)llcl Yegmtlonc-dlN lnt!Mllllnor ., MnorcrPnlmmryWcrbWcrbAppoval- or PNlllltlnll)'WGl!a Landlll Alu COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 2.7.3 Conservations Significant Flora One threatened flora taxon (Banksia sphaerocarpa subsp. dolichostyla (T)) listed as vulnerable under the Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act) and Critically Endangered under the Biodiversity Conservation Act 2016 (BC Act) (previously listed as Schedule 1 under the Wildlife Conservation Act 1950) was recorded within the project survey area. A targeted survey for this species was undertaken by Mattiske in 2018 (Mattiske, 2018b). Twenty individual populations of Banksia sphaerocarpa var. dolichostyla (T) (with a total of 16,505 specimens) were recorded across the project area. In addition to the Banksia sphaerocarpa var. dolichostyla (T) there were nine Priority Flora taxa and one range extension recorded within the disturbance envelope area which include: • Acacia undosa (P3). • Brachyloma stenolobum (P1). • Centolepis strigosa supsp. Rupestris (Range Extension) • Daviesia sarissa subsp. redacta (P2). • Eutaxia lasiocalyx (P2). • Hakea pendens (P3). • Labichea rossii (P1). • Microcorys sp. Mount Holland (P1) (D. Angus DA 2397). • Orianthera exilis (P2). • Verticordia stenoptela (P3). Locations of conservation significant flora are shown in Figure 4. 2.7.4 Introduced Species Only one introduced (exotic) plant taxon, Centaurium tenuiflorum, was recorded in the Development Envelope by Mattiske (2017a). This taxon is listed as Permitted (s11) pursuant to the Biosecurity and Agriculture Management Act 2007. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 17 757500m 759000m 700500m 762DOOm N E E s + I!! i • i • • • • • • • E + .,."Hlctill.,.... e, ens , Ra*-·~__ ,~ I • --J Specb • --3Specb ♦ ...... $1&-nnpa.a:. ,, •• - 100.--11111n1a111 ---1111 ..... dolldiollitl] • ... - 10--1)4-.,. "" Mt ttol~nil (0. Nip D.U$1)] c::::J Dmatawa B~ c:::::] n1fti& en _..,Llllilal'Njo41'___ .. # • • c::::J Nini~" • • • c::::J Gnni"'-" D " som c::::J Ni 7 ec • UOl!nC:e 757500m 7591Dlm 700500m 7621100m S.-:1:20000 Cowlant Lithium Piy Ltd Flgul94 ~lla:M D 11cm EBII Grey Lllh~m Prqect CollalMllon Slgnltleam FIDl'II In 1111 ., Miner or Pre1m•1111y- wens WOl!cs ApproYaJ ■nar or Plllll'lllnar, WOllra llllllftl ArN COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 2.8 FAUNA AND HABITAT Six fauna assessments have been completed for the project disturbance envelope and wider surrounding area between 2016 and 2017 (Western Wildlife 2017). 2.8.1 Fauna The faunal assemblage is diverse as it contains elements from both the Eremaen (arid with irregular rainfall) and Bassian (southwest with regular winter rainfall) regions. The results of the fauna survey, supplemented with database records and published information, indicate that there are up to nine frogs, 67 reptiles, 108 birds and 32 mammals (27 native mammals) that have the potential to occur. Fauna surveys recorded a total of one frog, 32 reptiles, 77 birds and 19 mammals (14 native and five introduces) from the project area and regional areas (Western Wildlife 2017). 2.8.2 Fauna Habitat Three broad fauna habitats were defined by Western Wildlife (2017) in the project area. Habitats were identified during the fauna surveys and on the basis of vegetation mapping (Mattiske, 2018a) (Table 4). Table 4: Fauna Habitats at the Earl Grey Project Area within Area Disturbance Cleared Type Description Mapped Envelope Land (ha) (Ha) (ha) The ‘mallee woodland’ habitat describes a structural type, and within that the habitat there is much variability in plant species Mallee Woodland composition and the density and composition of the shrubland 2917.8 891.4 0.0 understory, ranging from minimal understory to dense shrubland These woodlands occur mostly in the eastern and southern parts of the Development Envelope, and are characterised by an open canopy of Salmon Gum (Eucalyptus salmonophloia), Salmon Gum sometimes with Merrit (Eucalyptus flocktoniae), Sand Mallee 453.5 23.6 0.0 Woodland (Eucalyptus eremophila), Eucalyptus urna or other eucalypts, over a sparse shrub understorey on clay flats. Salmon Gum woodlands were also noted to occur patchily in the Regional Survey Area. Shrublands occur on sandy-clay flats, gravelly sands and lateritic rises and vary in composition, but are usually dominated by species of Allocasuarina, Hakea, Acacia, Banksia and/or Melaleuca. Although sparse low mallee Shrubland eucalypts may be present, this habitat lacks large trees. The 399.2 137.1 0.0 dense structure of the vegetation provides shelter and nesting habitat for ground-dwelling birds. When in flower, shrubland habitats are likely to attract a suite of nectar-feeding bird species. Cleared Land Cleared Land 647.4 351.3 0.0 None of the habitats were considered to be restricted or unique in the region. Uncommon habitat types, such as granite outcrops, salt lakes or freshwater wetlands, are absent from the project area. Historically cleared areas including waste dumps and open pits are present in the study area, and are only likely to support a small complement of native fauna. Significant parts of the regional study areas were burnt approximately two years prior to the surveys. Fauna habitats are shown in Figure 5. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 19 COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 2.8.3 Conservation Significant Fauna Fauna surveys identified a number of conservation significant fauna that have potential to occur within the project disturbance envelope and surrounding areas. Table 5 lists these species and describes the likelihood of them occurring within the Minor or Preliminary Works Area and surrounding area. A total of four conservation significant species were recorded during the survey which included: • Malleefowl (Leipoa ocellata) – Listed as Vulnerable under the EPBC and BC Acts (previously Schedule 3 under the WC Act). • Peregrine Falcon (Falco peregrinus) – Listed as Species in need of Special Protection (OS) under the BC Act (previously Schedule 7 under the WC Act). • Rainbow Bee-eater (Merops ornatus) – Listed as Migratory under the BC Act (previously Schedule 5 of the WC Act). • Chuditch (Dasyurus geoffroii) – Listed as Vulnerable under the EPBC and BC Acts (previously Schedule 3 under the WC Act). In addition there were two Priority Fauna taxa a recorded within the disturbance envelope area, namely the: • Inland Western Rosella (Platycercus icterotis xanthogenys) (P4). • Western Brush Wallaby (Macropus irma) (P4) The locations of conservation significant species observed during project specific surveys are shown in Figure 6. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 20 COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION Table 5: Conservation Significant Species with Potential to Occur in Minor or Preliminary Works Landfill Area and/or Surrounding Areas Conservation Significance Likelihood of Recorded with Species Records Habitat preferences occurrence in Disturbance EPBC WC Landfill Area Envelope DBCA Act Act Reptiles Paroplocephalus Nearby at Lake Cronin & Jilbadji Nature Reserve atriceps P3 Woodlands & shrublands. Moderate No (Appendix 8) Lake Cronin Snake Aspidites ramsayi Historical records to the north at Marvel Loch and P1 Sandplains. Low No Woma (southwest Yellowdine (Appendix 8) popn) Nephrurus stellatus Spotted Knob-tail Recorded in Regional Survey Area. Mallee woodlands on sandplains. High No Gecko Birds Active and recently active mounds recorded in the Acacia thickets, mallee woodlands and Leipoa ocellata Disturbance Envelope & Regional Survey Area. Vu S3 shrublands with leaf litter. Also forages in Known to occur Yes Birds sighted in the Disturbance Envelope and Malleefowl adjacent habitats. Regional Survey Area. Calyptorhynchus Forages in eucalypt woodlands and latirostris Nearby at Cosmic Boy and Flying Fox Mines proteaceous vegetation, breeds in large En S2 Low No Carnaby’s Black- (Appendix 8). eucalypt hollows, particularly Salmon Cockatoo Gum. Falco peregrinus Recorded in Disturbance Envelope & Regional Variety of habitats, nests in tall trees, cliffs, S7 Known to occur Yes Peregrine Falcon Survey Area. open pits. Apus pacificus Mig S5 Recorded in Forrestiana (Appendix 8). Overfly any habitat. Moderate No ------Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 21 .11 COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION Conservation Significance Likelihood of Recorded with Species Records Habitat preferences occurrence in Disturbance EPBC WC Landfill Area Envelope DBCA Act Act Fork-tailed Swift Merops ornatus Recorded in Disturbance Envelope & Regional Forages in a variety of habitats, breeds in S5 Known to occur Yes Rainbow Bee-eater Survey Area. sandy areas. Platycercus icterotis xanthogenys Recorded in Disturbance Envelope & Regional Eucalypt woodlands. Nests in tree P4 Known to occur Yes Inland Western Survey Area. hollows. Rosella Mammals Forests, woodlands & shrublands, denning Dasyurus geoffroyii Recorded in Disturbance Envelope & Regional Vu S2 in hollow logs, babbler nests, burrows or Known to occur Yes Survey Area. Chuditch rock crevices. Phascogale calura Wandoo or York Gum woodlands with a Red-tailed En S6 Nearby (Appendix 8). Rock Sheoak understorey. Sometimes Low No Phascogale other shrublands or woodlands. Macropus irma Recorded in Disturbance Envelope & Regional Woodlands & shrublands, sheltering in P4 Known to occur Yes Western Brush Survey Area. dense vegetation. Wallaby Nyctophilus major tor Known from Jilbadji Nature Reserve (Duncan et al. Woodlands, roosting in tree hollows and P4 Moderate No Central Long-eared 1999) crevices. Bat ------Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx 22 .11 '61000m E I E E I E E I l'lllr-M tl918 ! i1111 aeaf'lld1..anc1 11111 Make Woodland en Clily Lae1111 I 11111 Malee Woodland an Sands Mallie Woodland on Sllnlt/ Clays 11111 SllmonGumWoodllnd 11111 Sh111blnl on Fla 11111 9'111blilrd on~ RIM c:::J Dillllimnce rr..e1ape c::::J Propored Minar and Prdmlnary WGllt 76000011'1 7G1000 m 762000 m 8Cllla: 1:20000 CcMllanl Lithium Ply Ltd Flgu11 5 0,tgNllllze:M 61111: !IGAll4(5D} Ea!I Grey Ltlhllln Prqed Minor ct Praliminary WOllts Faura H1blllt In tit.._°" 0 .500 m Worlll Approval Plllll!kwfWcm Laldftll Am .. ·. ~-~· F6•-- I 159&00m 161300m I N & E E ! I E Llndflll E I + I E E I . . r------., i c:::::J lltstlml-EIMlape c::::::J ,,...i,unorwoott- • Known Malled'owt Nmnl Lacallan D stm - lOOmebrMIII' 159&00111 7111300 m 8CK 1:21IOOO Cavalent Lithium Ply Ud Flgun1I o~•ullsti.:M Eat Qv, Uthlum Project GIid: MGAS4(50) ConNi ♦ltlot ■ llgalftant MIIIOf or PNlll'tlaiy WClb r-ln11ie-• 0 !Dim Wollca .Approyal Pralllllllly WOlla wdllAnll • • • • ~ I':""".'""• ..... _,,, COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 2.8.4 Short Range Endemics A desktop review was completed for the project disturbance envelope and surrounding areas (100 x 100 km) by Bennelongia in 2017 (Bennelongia 2017). A total of 48 species belonging to SRE groups have been recorded within the search area, however there were no records of confirmed SRE’s or listed invertebrate species. Twenty- three (47.9 %) of the species belonging to SRE Groups appear to be widespread, six (12.5 %) are unlikely (but potential) SRE species and 19 (36.9 %) are potential SREs. Potential SRE species include 15 mygalomorphs, two isopods, a pseudoscorpion and a millipede. Bennelongia, based on professional judgement, considers many of these potential SRE species are likely to be widespread, but current records are insufficient to accurately predict their distributions. No listed invertebrate species has been recorded in the search area and it is highly unlikely that any occur. Potential SRE habitat units were assessed based on the Western Wildlife (2017) and Mattiske (2017) assessments, in addition to broad-scale habitat units from Beard et al (2013) and modified based on the context of SRE species. The faunal habitats and vegetation communities were assessed for SRE habitat suitability based on the availability of moisture, soil structure, geological diversity, vegetation type and extent of shade and shelter. Six habitat units were determined and are detailed below: • Mallee woodland on clay/sandy clay soils on flats and slopes - is an amalgamation of four vegetation communities characterised by low and mid mallee woodland over sparse shrubland or heathland on red, orange and brown clays or sandy clays on flats and slopes. This habitat type covers 30% of larger project Development Envelope, and is likely to occur as part of regionally extensive vegetation associations outside the Development Envelope. Although SRE groups are likely to occur in deposits of leaf litter, this unit is of low prospectivity for SRE species due to its wide extent and good regional connectivity. • Open mallee woodland/woodland on clay/sandy clay on flats and slopes is the most common and widespread SRE habitat type, combining 15 mallee and two non-mallee open woodland communities and covering 33% of the larger Project Development Envelope. It is characterised by open mallee woodland (or less commonly open non-mallee or gimlet woodland) over sparse shrubland or heathland on grey, brown, orange, yellow and red clays and sandy clays on flats and slopes. Due to the wide extent both within and beyond the development envelope and wider region, a low degree of prospectivity for SRE species is inferred. • Open mallee woodland on lateritic clayey sand on slopes and ridges comprises a single vegetation association, W17, and covers less than 1% of the larger Project Development Envelope. However, it was not identified in the mapped area outside the Development Envelope. The separation of this habitat from other open mallee woodland units is based on the presence of lateritic surface rocks that may offer some specialist microhabitats for a range of specialist species, such as selenopid wall crab spiders, pseudoscorpions and burrowing species such as mygalomorphs and Urodacus scorpions that may favour rocky substrate. In reality, however, the absence of outcropping rock reduces the likelihood of species being restricted to this small area of habitat, with species instead being likely to utilise microhabitats present in surrounding mallee woodland. In addition, SRE Group species are likely to reside in deposits of bark and leaf litter, especially at the bases of larger trees. The significance of this small area of laterite within the local landscape is unclear, although is likely to be low on a regional scale. A moderate degree of prospectivity for SRE species is inferred for this habitat, although this may be overestimated by desktop and species from SRE Groups utilising this small pocket of habitat may also occur in surrounding mallee woodlands. • Open mallee woodland on sandy clay with pebbles on flats and slopes comprises a single vegetation community, W4, which cover 1% of the larger Project Development Envelope, although there may be some justification for its amalgamation into habitat 2. Although similar to habitat 2 in terms of vegetation, habitat 4 is separated on the basis of having some rocks (mainly ironstone and quartz pebbles), which may alter the structure of soil in such a way as to favour some specialised species that burrow in rocky substrate, at the expense of generalist burrowing species or those that prefer finer soils (such as those in habitat 2). It is also possible, although unlikely, that non-burrowing specialist species that favour rocky habitats (such as Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 25 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION some spiders and pseudoscorpions) occur in this unit. This habitat is highly likely to occur within regionally extensive and interconnected vegetation associations. Therefore, it is inferred to have a low degree of prospectivity for SRE species. • Open heathland on rocky, sandy clay with on slopes comprises a single vegetation association, H1, covering 2 ha in the southern portion of the larger Project Development Envelope. It is absent from within the development envelope and as such will not be threatened by the Proposal. Given the general lack of eucalypts or other species that would generate significant amounts of leaf litter and provide cover, this habitat is highly exposed, and few (if any) moist microhabitats are present. Rocky substrate may provide some, though probably limited, habitat for specialist species including burrowing forms and, to a lesser extent, non-burrowing rock specialists. Given the absence of regionally significant geological features and high degree of exposure, this habitat is considered to have low prospectivity for SRE species, although species from SRE Groups may occur in low abundance. • Tall shrubland on clay soils with some rocks on flats and slopes is made up of three similar vegetation associations and is characterised by tall shrubland (ranging from open to closed) over sparse heathland and shrubland on clay soils. It covers 10% within the Larger Project Development Envelope as well as occurring in externally in the mapped area and probably also in regionally extensive vegetation associations. Significant microhabitats for SRE species are unlikely to occur in this habitat, with larger trees that would provide leaf litter, bark and shade cover absent. Significant surface rocks are absent, although soils are pebbly or gravelly in places, possibly favouring burrowing species that prefer coarse media over generalists. Overall, a low degree of prospectivity is inferred. The extent of the habitats beyond the larger Project Development Envelope were assessed, as well as extent of habitat connectivity and the presence of habitat isolates, which might restrict dispersal of SRE. These units generally have low prospectivity for SRE species, although widespread species belonging SRE Groups are likely to utilise the habitats. All units extend outside the Proposal with the exception of habitat 3 (open mallee woodland on lateritic clayey sand on slopes and ridges), although in reality it is likely that this habitat also occurs regionally outside the area covered by habitat/vegetation mapping. It is also considered unlikely that habitat 3 provides truly specialised habitat usually necessary to indicate prospectivity for SRE species due to a its lack of truly distinguishing geological features, such as outcropping rock, granites or BIF. 2.8.5 Subterranean Fauna A desktop review was completed in 2018 to assess the likelihood of subterranean fauna (stygofauna and troglofauna) occurring within the project disturbance envelope (Bennelongia 2018). No stygofauna have been previously recorded within a 10,000 km2 search area centred on the project disturbance envelope, mostly due to a combination of few surveys and the generally poor prospectivity of the hydrogeological landscape within the projects area. Records of stygofauna within the Yilgarn have been confined to calcrete aquifers, and records within consolidated geologies in the Southern Yilgarn recording either no stygofauna or only depauperate communities A total of 11 species of troglofauna were recorded within the search area (10,000 km2), however all records are from Banded Iron Formation (BIF) geology at Mt Caudan in the Parker Range (60 – 70 km north). It is likely that these troglofauna species are confined to BIF of the Parker Range. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 26 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 2.9 AIR QUALITY AND NOISE There are no significant air quality or noise emissions sources in the vicinity of the minor and preliminary works disturbance envelope and, due to the remote location; the receptors of noise impacts associated with the proposed works will only be the employees of the project and resident fauna. The main contributors to air quality, specifically particulate levels are ambient wind-borne dust (from dust storms, cattle and vehicle movements) and on site diesel generators, and a range of mobile fleet vehicles. Background and cumulative emissions from other industrial activities are expected to be negligible. 2.10 SOCIAL ENVIRONMENT 2.10.1 Land Use The project is located in the Yilgarn Shire, which covers 30,720 km2. The Shire is sparsely populated. Southern Cross is the major town centre of the Shire of Yilgarn. The two major industries in the Shire are mining and agriculture. Gold, gypsum, salt and iron are mined, while grain, wool, sheep, cattle and pigs are the focus of the agricultural industry. There are no pastoral leases or associated agricultural activities occurring in close proximity to the project. The nearest towns are Marvel Loch, located 80 kilometres north of the project, and Hyden, approximately 120 km south west of the project. The Jilbadji Nature Reserve (Reserve C 24049) is located 4.5 kilometres north of the project mining tenements. The nature reserve comprises an area of 208,860 ha, situated along the Forrestania Southern Cross Road, west of Barker Lake and 20 km east-southeast of Marvel Loch. The Jilbadji Nature Reserve is on the Register of the National Estate and was registered in 1978. 2.10.2 Native Title The project is not located within any Native Title Claims under the Native Title Act 1993. 2.10.3 Aboriginal Heritage An ethnographic survey of the project area was undertaken from 28 August to 18 December 2004. The survey was completed by an anthropologist, Wayne Glendenning from Western Heritage Research Pty Ltd, and the following three Aboriginal groups: • Central West Native Title claimant group. • Gubrun People. • Ballardong Native Title claimant group. No ethnographic sites were identified by any individual or group during the ethnographic survey (Western Heritage Research, 2005). A search of the Department of Planning, Lands and Heritage (DPLH) Aboriginal Heritage Inquiry System (AHIS) was completed in July 2018. There are no registered sites in the project area. The project area does not have any registered Native Title Claims or Indigenous Land Use Agreements in place. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 27 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 2.10.4 European Heritage Searches of the following databases have been undertaken for the project: • National Heritage List • Register of the National Estate • Commonwealth Heritage List • World Heritage List • Western Australian Register of Heritage Places. The project is not within the boundaries of any gazetted heritage places. The Great Western Woodlands (GWW) are nominated as a natural place under the National Heritage List. The GWW in the semi-arid inland of Western Australia's south west are one of the largest remaining, and most intact, temperate woodlands left on Earth, covering an area of more than 16 million hectares. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 28 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 3. CHARACTERISTICS OF THE PROJECT The key characteristics of the proposed minor or preliminary works requiring a works approval are summarised in Table 6 and detailed in the following sections. The location of these works is shown in Figure 2. Additional information is provided in Section 3.1.1 in order to give context to the minor or preliminary works and pollution control measures which will be implemented. Table 6: Proposed Minor or Preliminary Works Key Characteristics Requiring a Works Approval Characteristic Description Tenements M 77/1066 Tenement Holder Montague Resources Ltd Life of Project 26 weeks Project Operational Time 24 hours per day, 7 days a week. *Total Footprint of MPW 75.1 ha Landfill Facility Footprint of Landfill 1.0 ha Height Below ground level with a minimum height 1 m safety bund around edge of excavation at surface level, with drive in ramp Covering of waste Weekly Firebreak At least 3 m in width around the boundary of the site Capacity 305 t/a * No clearing of native vegetation forms part of this footprint 3.1 KEY ACTIVITIES 3.1.1 Landfill All putrescibles and inert waste will be disposed of at purpose built facilities on site. The location of the landfill has taken into consideration factors such as visibility, wind direction, prevention of access by scavenging animals, minimisation of nuisance odour and the potential for flooding. The landfill facility is a trench design; consisting of multiple cells located approximately half way between the historic accommodation camp and processing area (this is the location of the landfill for the full Earl Grey Lithium Project – if the full project goes ahead this landfill can then be extended in its existing location). Each cell will be approximately 30 m long by 10 m wide by 4 m deep. The design length of 30 m incorporates a ramp down into the trench where waste can be deposited and then compacted prior to more waste being deposited. Each cell will be surrounded by an earthen bund of approximately 1 m in height to prevent surface water runoff entering the cell The throughput of the landfill facility at peak operation is estimated to be 305 t/a based on a calculation of 5 kg of waste produced by each individual accommodated at the camp per day and a maximum occupancy of 60 individuals for the 26 week project period plus inert waste produced during the works period. A fence will be erected around the boundary of the landfill facility to ensure an effective barrier is in place to prevent fauna (in particular feral animals) from accessing the waste material. An entrance/exit gate will be incorporated into the fence and the gates will be kept closed at all times (other than when waste is being deposited). The boundary fence also creates a wind barrier for any waste material that may be blown out of the Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 29 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION perimeter, thereby minimising the potential for littering of the surrounding environment. Any waste that is blown outside of the landfill will be returned to the tipping area at least once every month in accordance with Regulation 8 of the Environmental Protection (Rural Landfill) Regulations 2002. The landfill will be closed and rehabilitated in line with industry standard if the full Earl Grey Lithium Project is not approved within 12 months. Concrete wastes will be crushed and re-used where possible, some inert waste will be disposed of at the landfill, tyres where not re-used will be removed from site. In addition to the above waste material will be managed as follows: • Lidded bins will be used to minimise windblown waste. • Transported waste will be covered. • Waste material from the camp will generally be in bags. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 30 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 4. POLLUTION CONTROL 4.1 EMISSIONS TO AIR 4.1.1 Sources Gaseous emissions and dust generated during general construction of the landfill have potential to affect environmental values. The proposed minor and preliminary works have potential to impact on air quality through the generation of particulates via: • Construction, earthwork and maintenance activities. • Vehicle movements to and from the landfill. • Combustion emissions from earthmoving equipment and light vehicles at the landfill site. The proposed minor and preliminary works have potential to impact on air quality through generation of greenhouse gas emissions (including carbon monoxide, carbon dioxide, sulfur dioxide and nitrous oxides) via: • Engine exhausts from construction equipment and light vehicles. • Transport of materials, equipment and removal of packaging wastes. The proposed minor and preliminary works have potential to impact on air quality through the generation of odour from the landfill site. 4.1.2 Receptors The closest air quality receptors to the project are: • Fauna and flora in close association with the site. • Accommodation Camp (1.5 km). • Covalent employees and contractors. Any potential adverse impacts will be limited by the short duration and remote location of the proposed minor and preliminary works and the absence of nearby sensitive receptors being the accommodation camp. As such, the primary receptors of potential air quality issues will be Covalent employees and contractors. 4.1.3 Potential Impacts The potential impacts from gaseous emissions, dust, and particulates as a result of project implementation are: • A decrease in human and fauna health through inhalation. • A decrease in vegetation health and condition in adjacent areas due to dust covering vegetation, blocking stomata and reducing the plant’s ability to photosynthesise. • Reduction in local air quality from an increase in mobile equipment emissions from engine exhausts including particulates, carbon monoxide, carbon dioxide, sulfur dioxide and nitrous oxides. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 31 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 4.1.4 Control Measures Covalent will implement dust control measures during construction and operational stages of the proposed minor or preliminary works in order to minimise any potential adverse impacts. The following management measures will be implemented. 4.1.4.1 Dust: • Vehicles will keep to designated roads. • Vehicles will be required to travel at safe operating speeds on unsealed roads. • Dust suppression will be carried out during construction, operation and closure. 4.1.4.2 Combustion Emissions: • Euro V standard vehicles and equipment (post 2009) or appropriate quality diesel fuel will be used to minimise NOx and particulate emissions. 4.1.4.3 Odour: • The landfill will be covered on a regular basis (at least weekly) in order to minimise odours. 4.1.5 Predicted Residual Environmental Risk It is unlikely that atmospheric pollution from the proposed minor or preliminary works landfill will adversely impact the environment as: • Dust associated with construction will be short term in duration and highly localised. Standard industry practices will be implemented to minimise dust emissions. • The project area is remote. Employees and contractors located closer to dust emissions will have exposure to dust and greenhouse emissions managed according to appropriate occupational hygiene standards. • Combustion emissions will not be significant due to the small size of the operation, short duration and measures implemented to minimise emissions. • Odours will be minimised through control measures, and are unlikely to be an issue due to the distance from significant receptors. 4.2 NOISE EMISSIONS 4.2.1 Sources Potential sources of noise associated with the proposed minor or preliminary works landfill include: • Earthwork, construction, and maintenance activities. • Transport of materials, equipment and removal of wastes. 4.2.2 Receptors The closest noise receptors are: • Fauna, including species of conservation significance (Malleefowl and Chuditch). • Accommodation Camp (1.5 km). Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 32 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION • Covalent employees and contractors. Any potential adverse impacts will be limited by the short duration, remote location of the proposed minor or preliminary works and the absence of nearby sensitive receptors. As such, the primary receptors of potential noise issues will be Covalent employees and contractors. 4.2.3 Potential Impacts The potential impacts from noise emissions as a result of the proposed minor or preliminary works are: • Increased exposure to noise for fauna residing close to the landfill. • Increased exposure to noise of contractors and employees in work areas. 4.2.4 Control Measures Project design has considered exposure to noise in order to minimise adverse impacts. The following management measures will be implemented during the project: • All vehicles and plant equipment will be regularly maintained to ensure they are operating efficiently and are not excessively noisy. 4.2.5 Predicted Residual Environmental Risk It is unlikely that noise will be a significant impact as: • The proposed minor and preliminary works will be located a significant distance from receptors. • Adequate control measures will be implemented to prevent local impacts. 4.3 DISCHARGES TO SURFACE AND GROUNDWATER 4.3.1 Sources The project will not require direct discharge to surface or groundwaters. Indirect discharges to groundwater may result from: • Leachate from the landfill. 4.3.2 Receptors There are no defined watercourses within the minor and preliminary works area. Contamination of groundwater through seepage is considered unlikely due to the location of groundwater over 65 m below ground level, and the low rainfall levels experienced in the region. 4.3.3 Potential Impacts Project activities have the potential to: • Contaminate groundwater due leachate seepage from the landfill. • Surface sheet flow impacting the landfill during rainy periods. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 33 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 4.3.4 Control Measures No control measures are proposed for the landfill facility due to the unlikely contamination of groundwater through seepage. Bunds will be constructed around the landfill in order to divert surface water sheet flow around the facility. 4.3.5 Predicted Residual Environmental Risk Given the depth to groundwater and the use of the bund around the landfill there is not expected to be any impact to ground or surface water. 4.4 DISCHARGES TO LAND 4.4.1 Sources The sources of discharges to land may potentially originate from: • Inappropriate storage of waste (i.e. disposal of unpermitted material into landfill). • Inappropriate containment of waste and littering of the surrounding environment by wind. 4.4.2 Receptors A range of waste products will be produced as a result of vehicle and equipment maintenance activities. This will include waste oil, lubricants, filters, oily rags, solvents, tyres, batteries and empty containers which will be removed from site and disposed of accordingly. Waste generated during MPW activities will be either recycled, disposed of within the landfill facility or removed offsite to an appropriately licensed disposal facility. 4.4.3 Potential Impacts The proposed minor or preliminary works have the potential to: • Contaminate land and affect human health if wastes are not appropriately managed. 4.4.4 Control Measures The following management measures will be implemented: • Domestic and inert wastes will be disposed of into a purpose built onsite landfill. • The site induction will provide information on permitted waste disposal and recycling. • Waste that is blown outside of the landfill site will be returned to the tipping area at least once every week. • All infrastructure associated with the minor or preliminary works will be removed and the site will be rehabilitated, except where the areas are the subject of further approvals granted for the project. 4.4.5 Predicted Residual Environmental Risk Given the remote location of the project from receptors and the short duration of proposed works, the proposed mitigation and management measures will be sufficient to achieve a low risk of significant impact to local lands. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 34 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION 5. REFERENCES Australian Soil Resources Information System (ASRIS). 2016. Australian Soil Resource Information System. http://www.asris.csiro.au/index_ie.html (accessed September 2016). Australasian Institute of Mining and Metallurgy (AIMM). 1991. Field Geologists’ Manual. Monograph 9. 4th ed. Carlton: AIMM. Beard, J. S. 1976. Vegetation survey of Western Australia. Western Australia 1:1 000 000 vegetation series. Perth: University of Western Australia. Bennelongia. 2017. Early Grey Lithium Project SRE and Subterranean Fauna Desktop Assessment. Unpublished report prepared for Covalent Lithium. Bennelongia. 2018. Early Grey Lithium Project Subterranean Fauna Desktop Assessment. Unpublished report prepared for Covalent Lithium. Department of Parks and Wildlife (DPaW). 2016. Definitions, Categories and Criteria for Threatened and Priority Ecological Communities. http://www.dpaw.wa.gov.au/plants-and-animals/threatened-species-and- communities/wa-sthreatened-ecological-communitie (accessed 11th July 2016). Department of Water (DoW). 2008. Water Quality Protection Notice: Irrigation with nutrient-rich wastewater. https://www.water.wa.gov.au/__data/assets/pdf_file/0013/4045/82324.pdf (accessed 24 March 2017). Environmental Protection Authority (EPA). 2015. Environmental Assessment Guideline for Preparation of Management Plans Under Part IV of the Environmental Protection Act 1986. Environmental Assessment Guideline 17. Perth: EPA. Environmental Protection Authority (EPA). 2016. Statement of Environmental Principles, Factors and Objectives. Perth: EPA. Graham, G. 2001. Coolgardie 2 (COOO2 – Southern Cross subregion). In A Biodiversity Audit of Western Australia's 53 Biogeographical Subregions in 2002. Perth: Department of Parks and Wildlife. Greening Australia. 2018. Earl Grey Lithium Project Terrestrial Fauna Documentation Peer Review. Unpublished report prepared for Covalent Lithium. Groundwater Resource Management (GRM). 2017. Mount Holland Lithium Project Hydrogeological Study. Unpublished report prepared for Kidman Resources. Kidman. 2017. The geological setting, mineralogy and geochemistry of the Earl Grey lithium pegmatite. Internal Technical Report, Kidman Resources. May 2017. Mattiske Consulting Pty Ltd. 2018a. Flora and Vegetation Assessment of Banksia sphaerocarpa var. dolichostyla (T) of the Earl Grey Lithium Project. Unpublished report prepared for Covalent Lithium. Mattiske Consulting Pty Ltd. 2018b. Flora and Vegetation Targeted Assessment of the Earl Grey Lithium Project. Unpublished report prepared for Covalent Lithium. Queensland Government (QG). 2016. SILO Climate Data. https://www.longpaddock.qld.gov.au/silo/ (accessed on 12 March 2016). Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 35 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION Schoknecht, N. and Pathan, S. 2013. Soil Groups of Western Australia. In Resource Management Technical Report 380, Soil Physical Measurement and Interpretation for Land Evaluation, Australian Soil and Land Survey Handbooks Series 5, 4th ed. Perth: DAFWA. Stern, H., de Hoedt, G. and Ernst, J. 2000. Objective Classification of Australian Climates. Australian Meteorological Magazine, 49: 87-96. Tille, P. 2006. Soil-landscapes of Western Australia’s Rangelands and Arid Interior. Department of Agriculture and Food (DAFWA). Resource Management Technical Report 313. Perth: DAFWA. Western Wildlife. 2017. Level 2 Vertebrate Fauna Survey with Targeted Chuditch and Malleefowl of the Earl Grey Lithium Project. Unpublished report prepared for Covalent Lithium. Western Heritage Research Pty Ltd (2005). A Report of an Ethnographic Survey of mining Tenements at the Mounty Mine, Near Forrestania. Unpublished Report prepared for Montague Resources NL. Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx ----- 36 • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION APPENDICES -----Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx • COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION APPENDIX 1 : TENEMENT HOLDERS APPROVAL LETTERS -----Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx • KIDMAN RESOURCES NE Suite, Lvl 30, 140 Williams St, Melbourne VIC 3000 p +61 3 9671 3801 e [email protected] 26 February 2019 Dr Phil Gorey Deputy Director General of Resource and Environmental Regulation DMIRS' Resource and Environmental Compliance Division 100 Plain Street Perth WA 6004 Dear Phil, RE: Mt Holland / Earl Grey Lithium Project Mining Proposal for the Minor and Preliminary Works We write this letter in support of the mining proposal submitted to the Department of Mines, Industry Regulation and Safety pursuant to the Mining Act 1978 (WA) on or around the date of this letter (Mining Proposal) by Covalent Lithium Pty Ltd (ACN 623 090 139) (Covalent) in relation to the minor and preliminary works to be undertaken with respect to the Earl Grey lithium deposit (forming part of the Mount Holland Lithium Project). MH Gold Pty Ltd (MH Gold) and Montague Resources Australia Pty Ltd (Montague) (both wholly owned subsidiaries of Kidman Resources Limited (Kidman)) are currently the registered holders or applicants in relation to the tenements listed in the table below which are the subject of the Mining Proposal: Tenement Registered Holder M77/1066 Montague M77/1080 Montague L77/176 MH Gold L77/194 MH Gold L77/208 MH Gold M77/1065 Montague G77/129 MH Gold G77/130 MH Gold G77/131 MH Gold G77/132 Montague G77/133 Montague L77/295 MH Gold L77/296 MH Gold L77/298 MH Gold In relation to the tenements above highlighted grey, pursuant to a sale agreement dated 11 September 2017 (Sale Agreement), Kidman, Montague and MH Gold (amongst others) agreed to transfer 50% of their interests in such tenements to SQM Australia Pty Ltd (SQM). While a 50% beneficial interest in such kidmanresources.com.au I ACN: 143 526 096 tenements passed to SQM on 21 December 2017, the formal transfer of such tenements has not yet occurred. By way of an unincorporated joint venture agreement dated 21 December 2017 between MH Gold, Montague and SQM (amongst others) (JV Agreement) Covalent was appointed manager of the Mount Holland Lithium Project to develop the Earl Grey lithium deposit and has authority to apply for and carry out the Mining Proposal in relation to these tenements. In relation to the remainder of the tenements above that are not highlighted grey, Kidman and SQM are in negotiations to transfer these into the JV Agreement. Whilst these negotiations are taking place, Kidman authorises Covalent to submit the Mining Proposal and access such tenements on Kidman’s behalf to carry out the Mining Proposal. Kind regards, Martin Donohue Managing Director Page 2 of 2 20190226_KDR_COV_Letter of Consent_Mining Proposal_Prelim Works COVALENT LITHIUM PTY LTD EARL GREY LITHIUM PROJECT MINOR OR PRELIMINARY WORKS - LANDFILL WORKS APPROVAL APPLICATION APPENDIX 2 : EPA APPROVAL NOTICE FOR MPW -----Attachment 3A - Earl Grey Minor or Preliminary Works - Landfill Works Approval Application .docx • ~ Government of Western Australia ~ Department of Water and Environmental Regulation Our ref: DWERA-000302; DWERA-047264 Enquiries: Nyomi Bowers, Ph 6364 6416 Email: [email protected] Mr Mark Fones Chief Executive Officer Covalent Lithium Pty Ltd Level 18, 109 St Georges Terrace PERTH WA 6000 Dear Mr Fones NOTICE OF DECISION TO CONSENT TO MINOR AND PRELIMINARY WORKS - EARL GREY LITHIUM PROJECT Pursuant to Section 41A(3) of the Environmental Protection Act 1986, please find attached a Notice of Decision to Consent to Minor and Preliminary Works for the Earl Grey Lithium Project from the Environmental Protection Authority. Please note that no response to this correspondence is required. Yours sincerely Anthony Sutton Executive Director EPA Services I~ March 2019 Encl. Notice of Decision to Consent to Minor and Preliminary Works 168 St Geo, ges Te11 ace Western Australia 6000 Locked Bag 33 Cloisters Square Pertt, WA 6850 Telephone: 08 6364 7000 Facsimile: 08 6364 7001 l~ Environmental Protection Authority GOVERNMENT OF WESTERN AUSTRALIA Environmental Protection Act 1986 Section 41 A(3) NOTICE OF DECISION TO CONSENT TO MINOR OR PRELIMINARY WORKS PERSON TO WHOM THIS NOTICE IS GIVEN: (a ) Proponent: Covalent Lithium Pty Ltd (ACN: 623 090 139) (b) Relevant Decision-Making Authorities, see Attachment 1 PROPOSAL TO WHICH THIS NOTICE RELATES: Earl Grey Lithium Project Assessment No. 2123 Pursuant to section 41A(3) of the Environmental Protection Act 1986 (EP Act), the Environmental Protection Authority consents to the proponent undertaking the minor or preliminary works detailed in Schedule 1 . EFFECT OF THIS NOTICE: 1. The prohibition provided by sections 41(2), 41(3) and 41A(1) of the EP Act do not apply to implementing the minor or preliminary works consented to in this Notice. 2. It is an offence under s41A(1) of the EP Act, with a maximum penalty of $125,000 for a body corporate and $62,500 for an individual, to do anything to implement the proposal other than the minor or preliminary works consented to in this Notice. 3. Relevant decision-making authorities may make decisions that would cause or allow the doing of the minor or preliminary works listed in Schedule 1 of this Notice. RIGHTS OF APPEAL: There are no rights of appeal under the EP Act in respect of this consent. Dr Tom Hatton Delegate of the Environmental Protection Authority CHAIRMAN 1'( March 2019 The Atrium Level 8, 168 St Georges Terrace, Perth, Western Australia 6000. Postal Address: locked Bag 33, Cloisters Square, Western Australia 6850. Telephone: (08) 6364 7000 I Facsimile: (08) 6364 7001 I Email: [email protected] Website: www.epa.wa.gov.au Schedule 1 Authorised Minor or Preliminary Implementation Work(s) Page 2 Authorised Work(s) Location Authorised extent The following works are authorised in Figure 1 Disturbance of up to 71 .6 their entirety: ha of land, in areas of existing disturbance 1. Deconstruction and removal of within the Development historic Mt Holland structures, Envelope, during plant, equipment, debris and daylight hours. waste materials (historical infrastructure), to remove environmental and safety hazards and ensure a safe site for future employees and contractors. 2. Construction of new groundwater bores for construction purposes and dust suppression. 3. Construction of new infrastructure and upgrade of existing infrastructure required to carry out the preliminary works including: o construction of a 60-person accommodation camp (including waste water treatment plant (WWTP and sprayfield), landfill, temporary concrete batching plant and water supply infrastructure). o construction of site offices, storage and laydown areas. o upgrade of the existing power supply and communication infrastructure. o maintenance of existing roads. 4. Storage of long lead infrastructure components required for the Proposal. up until such time as the later of one of the following occurs: a. notice issued under s 45(8) of the EP Act; or b. statement issued under s45(5) of the EP Act is final (that is, after period in which to lodge an Page 3 appeal under s 100(3) has expired, or appeal decision under s109(3), in respect of an appeal lodged under s 100(3), is published). and, 5. rehabilitation of the area/s identified in Figure 1 in accordance with current EPA rehabilitation guidance, or if an implementation statement is issued for the Proposal, in accordance with any implementation conditions relating to rehabilitation. Page 4 Figure 1 Location of the Preliminary Works 7W5-00 m ,& l !YJO m iblUOU m lol!,UO m Site E.>ctcn Earl Grey lilhlum Prajecl covalent Figure 2 Ll l HI UM u,oooscd /.1w,_. ;,rd PrPI T 111,r~ Wo r,:, Page 5 Attachment 1 Relevant Decision Making Authorities 1. Minister for Environment 2. Minister for Mines and Petroleum 3. Minister for Water 4. Chief Executive Officer, Department of Water and Environmental Regulation 5. Executive Director, Resource and Environmental Compliance, Department of Mines, Industry Regulation and Safety 6. Chief Dangerous Goods Officer, Department of Mines, Industry Regulation and Safety 7. State Mine Engineer, Department of Mines, Industry Regulation and Safety 8. Chief Executive Officer, Shire of Yilgarn Page 6 m Environmental Protection Authority GOVERNMENT OF WESTERN AUSTRALIA Environmental Protection Act 1986 Section 41A(3) STATEMENT OF REASONS CONSENT TO UNDERTAKE MINOR or PRELIMINARY WORKS Proposal: Earl Grey Lithium Project Proponent: Covalent Lithium Pty Ltd Decision For the reasons outlined below, I, as a delegate of the EPA, have determined to consent to the minor or preliminary works outlined in Schedule 1 attached to this Statement of Reasons. Background On 19 May 2017, Kidman Resources Limited referred the Earl Grey Lithium Project proposal to the Environmental Protection Authority (EPA) under section 38 of the Environmental Protection Act 1986 (EP Act). Subsequent to referral of the proposal, Kidman Resources Limited entered into a joint venture with Sociedad Quimica y Minera in 2018. The newly formed joint venture company was approved as the Nominated Proponent on 21 May 2018, and the company name changed to Covalent Lithium Pty Ltd (Covalent) on 25 October 2018. The mining proposal is to develop a pegmatite-hosted lithium deposit at the abandoned Mt Holland mine site, located approximately 105 kilometres south southeast of Southern Cross in the Shire of Yilgarn. The proposal includes development of an open pit, waste rock dump, integrated waste landform, processing plant, accommodation camp, airstrip, roads and other associated mine infrastructure. The proposal would utilise existing disturbed areas, and includes new vegetation clearing. The EPA determined to assess the proposal at the level of Public Environmental Review with a 4-week review period on 14 July 2017, and released the final Environmental Review Document for public review from 11 February 2019 - 11 March 2019. In advance of a decision or agreement in relation to whether or not the proposal may be implementation under section 45 of the EP Act, the Proponent has sought the EPA's consent to undertake minor or preliminary works related to the proposal. The Atrium Level 4, 168 St Georges Terrace, Perth, Western Australia 6000. Postal Address: Locked Bag 33, Cloisters Square, Western Australia 6850. Telephone: (08) 6364 7000 I Facsimile: (08) 6364 7001 I Email: [email protected] Website: www.epa.wa.gov.au Relevant Statutory and Administrative Provisions The EPA decides to assess a proposal, and before a decision or agreement is made under s45 of the EP Act, all persons are prohibited from implementing a proposal, and relevant decision making authorities are prohibiting from making a decision which would allow the proposal to be implemented, except in relation to minor or preliminary works which the EPA has consented may be implemented - see sections 41(4) and 41 A(3) of the EP Act. The EPA has consented to the minor or preliminary works being done, however the person proposing to undertake those works may still need to obtain other authorisations from other decision making authorities. Section 3.5 of the Environmental Impact Assessment (Part IV Divisions 1 and 2) Procedures Manual 2016 guides what information the EPA requires from a person wanting to undertake minor or preliminary works. In consenting, I have considered whether the: • work is associated with the implementation of the proposal • potential environmental impacts of the work are significant • work would constitute the irreversible and substantial implementation of the proposal, and • work is justified. Materials considered in making this decision In determining to consent to the minor or preliminary works I have considered the following : 1. information provided during discussion about changes to the proposed works at the meeting held 7 February 2019 2. final application with updated proposal information provided 14 February 2019 Consideration 1. Assessment details - proposed work associated with proposal The proposed works are associated with the proposal, and would be carried out as part of the proposal following approval, in the event that the application for Minor and Preliminary works is not approved. All of the proposed works would be undertaken within the proposal Development Envelope. The proposed preliminary works do not require additional native vegetation clearing, however, in accordance with the vegetation mapping undertaken for the proposal, areas classified as "cleared" include isolated patches of degraded vegetation. The majority of the proposed preliminary works would be undertaken in existing disturbed areas, however disturbance to some sparsely vegetated areas within the proposal footprint e.g. accommodation village, and new areas in the proposal footprint e.g. landfill and borrow pit, are likely. 2 2. Details of the proposed work (a) Deconstruction and removal of historic Mt Holland structures, plant, equipment, debris and waste materials (historical infrastructure), to remove environmental and safety hazards and ensure a safe site for future employees and contractors. (b) Construction of new groundwater bores for construction purposes and dust suppression. (c) Construction of new infrastructure and upgrade of existing infrastructure required to carry out the preliminary works including: o construction of a 60-person accommodation camp (including waste water treatment plant (WWTP and sprayfield), landfill, temporary concrete batching plant and water supply infrastructure). o construction of site offices, storage and laydown areas. o upgrade of the existing power supply and communication infrastructure. o maintenance of existing roads. (d) Storage of long lead infrastructure components required for the mining proposal within existing disturbed areas. 3. Potential Environmental Impacts (a) Deconstruction and removal of historic structures, debris and waste materials This activity is not considered to be significant. The site is littered with historical infrastructure and debris. The proponent has advised that the site clean-up would identify and remove several health and safety hazards, including exposure to contamination sources and dilapidated infrastructure, and fire risk. No disturbance to significant flora or fauna habitat is required for the site clean-up. The proponent has advised that it is necessary to undertake the site clean-up to ensure that the site is safe for the future workforce, and to enable re-use of the existing disturbed areas in the Development Envelope. (b) Construction of new groundwater bores This activity is not considered to be significant. The proponent has advised that two new water bores are proposed to be constructed within the historical flooded underground. Hypersaline raw water would be required during the proposed preliminary works for dust suppression, and construction works within existing disturbed areas. The raw water would be transported via pipelines to a lined storage pond/tank close to the abstraction bores. Pipelines would not be laid within 50 metres of native vegetation. Potable water would be required for the accommodation camp, which would be trucked in and stored in temporary holding tanks located at the accommodation village, or other required locations. It is also proposed to use potable water for dust suppression in areas adjacent to the Threatened flora species Banksia sphaerocarpa 3 var. dolichostyla and Priority 1 flora species Microcorys sp. Mt Holland (D. Angus DA 2397). (c) Construction of new infrastructure and upgrade of existing infrastructure These activities are not considered to be significant. The layout for the accommodation village would avoid Threatened, Priority, range extension and new flora species, and Malleefowl mounds. Other required infrastructure would be located in existing disturbed areas, and existing roads would be used to access new areas in the proposal footprint e.g. landfill and borrow pit. Vehicle speed limits would be implemented at the site, and construction activities would only be undertaken during daylight hours to minimise the likelihood of vehicle strikes to Chuditch, and other nocturnal species. Any waste materials collected during the site clean-up, or produced onsite, would either be recycled or disposed to an offsite facility until a Works Approval for the landfill is granted. (d) Storage of long lead infrastructure components This activity is not considered to be significant. The proponent has advised that any long lead infrastructure components, such as additional accommodation village units and plant equipment/components, would be located within existing disturbed areas. 4. Proposed rectification actions The preliminary works proposal has been designed so that it could be rehabilitated to reverse any environmental impacts that may occur. The preliminary works have been designed so that no additional clearing of native vegetation is required, and measures would be implemented to minimise impacts to native fauna species. It is noted that the proposed works would be short-term and located in areas of existing disturbance. Any temporary infrastructure associated with the preliminary works would be decommissioned and removed from site upon completion. The decommissioning and rehabilitation of the preliminary works would also be addressed in the Mining Proposal and associated Mine Closure and Rehabilitation Plan. The proponent has previously advised the EPA of potential safety hazards onsite that require removal to ensure a safe workplace for the future workforce, and to enable re use of the existing disturbed areas. Additionally, should the project not proceed, the removal of the historical infrastructure and debris from the site would enable those areas to be more readily rehabilitated. 4 Schedule 1 Minor or Preliminary Works Authorised Work(s) Location Authorised extent The following works are authorised in Figure 1 Disturbance of up to 71.6 their entirety: ha of land, in areas of existing disturbance 1. Deconstruction and removal of within the Development historic Mt Holland structures, Envelope, during plant, equipment, debris and daylight hours. waste materials (historical infrastructure), to remove environmental and safety hazards and ensure a safe site for future employees and contractors. 2. Construction of new groundwater bores for construction purposes and dust suppression. 3. Construction of new infrastructure and upgrade of existing infrastructure required to carry out the preliminary works including: o Construction of a 60-person accommodation camp (including waste water treatment plant (WWTP and sprayfield), landfill, temporary concrete batching plant and water supply infrastructure). o Construction of site offices, storage and laydown areas. o Upgrade of the existing power supply and communication infrastructure. o Maintenance of existing roads. 4. Storage of long lead infrastructure components required for the Proposal. up until such time as the later of one of the following occurs: a. notice issued under s 45(8) of the EP Act; or b. statement issued under s45(5) of the EP Act is final (that is, after period in which to lodge an appeal under s 100(3) has expired, or appeal decision under s109(3), in respect of an 6 appeal lodged under s 100(3), is published). and, 5. rehabilitation of the area/s identified in Figure 1 in accordance with current EPA rehabilitation guidance, or if an implementation statement is issued for the Proposal, in accordance with any implementation conditions relating to rehabilitation. 7 Figure 1 Location of the Preliminary Works /(-,(J~Om n,rnoo m E 0 :;:, "' ...,."' "" E E C, 0 8 8 "'i i"' E 8 .."' ..oz, E 8 .....0 i E 0 .,:x,.., $ E E 0 0 8 g M i "'i 7&0500 m 761000 m 761500 m 762000 m 762500 m 0 o.s km Earl Grey lithium Pro,ect S;o , 1 l~){ Figure 2 ~-.. ,s,uu, WG,a,,~1!i'.!1 covalent sear.a : :..:m-cJ ...m p,•lld., AA L IT HIUM DroPOSM M100f li-=~;.;;,;;;,,.,;~..,....,e.,,,u,.,.,,'"·,.,.l'"1·------..L.---- and Prel.tr .11ary Works 8 Department of Water and Environmental Regulation Attachment 5 Application form: works approval, licence, renewal, amendment, or registration (v10, Nov 2018) 28 IR-F09 v10.0 ~ Government of Western Australia ~ Department of Water and Environmental Regulation Our ref: DWERA-000302; DWERA-047264 Enquiries: Nyomi Bowers, Ph 6364 6416 Email: [email protected] Mr Mark Fones Chief Executive Officer Covalent Lithium Pty Ltd Level 18, 109 St Georges Terrace PERTH WA 6000 Dear Mr Fones NOTICE OF DECISION TO CONSENT TO MINOR AND PRELIMINARY WORKS - EARL GREY LITHIUM PROJECT Pursuant to Section 41A(3) of the Environmental Protection Act 1986, please find attached a Notice of Decision to Consent to Minor and Preliminary Works for the Earl Grey Lithium Project from the Environmental Protection Authority. Please note that no response to this correspondence is required. Yours sincerely Anthony Sutton Executive Director EPA Services I~ March 2019 Encl. Notice of Decision to Consent to Minor and Preliminary Works 168 St Geo, ges Te11 ace Western Australia 6000 Locked Bag 33 Cloisters Square Pertt, WA 6850 Telephone: 08 6364 7000 Facsimile: 08 6364 7001 l~ Environmental Protection Authority GOVERNMENT OF WESTERN AUSTRALIA Environmental Protection Act 1986 Section 41 A(3) NOTICE OF DECISION TO CONSENT TO MINOR OR PRELIMINARY WORKS PERSON TO WHOM THIS NOTICE IS GIVEN: (a ) Proponent: Covalent Lithium Pty Ltd (ACN: 623 090 139) (b) Relevant Decision-Making Authorities, see Attachment 1 PROPOSAL TO WHICH THIS NOTICE RELATES: Earl Grey Lithium Project Assessment No. 2123 Pursuant to section 41A(3) of the Environmental Protection Act 1986 (EP Act), the Environmental Protection Authority consents to the proponent undertaking the minor or preliminary works detailed in Schedule 1 . EFFECT OF THIS NOTICE: 1. The prohibition provided by sections 41(2), 41(3) and 41A(1) of the EP Act do not apply to implementing the minor or preliminary works consented to in this Notice. 2. It is an offence under s41A(1) of the EP Act, with a maximum penalty of $125,000 for a body corporate and $62,500 for an individual, to do anything to implement the proposal other than the minor or preliminary works consented to in this Notice. 3. Relevant decision-making authorities may make decisions that would cause or allow the doing of the minor or preliminary works listed in Schedule 1 of this Notice. RIGHTS OF APPEAL: There are no rights of appeal under the EP Act in respect of this consent. Dr Tom Hatton Delegate of the Environmental Protection Authority CHAIRMAN 1'( March 2019 The Atrium Level 8, 168 St Georges Terrace, Perth, Western Australia 6000. Postal Address: locked Bag 33, Cloisters Square, Western Australia 6850. Telephone: (08) 6364 7000 I Facsimile: (08) 6364 7001 I Email: [email protected] Website: www.epa.wa.gov.au Schedule 1 Authorised Minor or Preliminary Implementation Work(s) Page 2 Authorised Work(s) Location Authorised extent The following works are authorised in Figure 1 Disturbance of up to 71 .6 their entirety: ha of land, in areas of existing disturbance 1. Deconstruction and removal of within the Development historic Mt Holland structures, Envelope, during plant, equipment, debris and daylight hours. waste materials (historical infrastructure), to remove environmental and safety hazards and ensure a safe site for future employees and contractors. 2. Construction of new groundwater bores for construction purposes and dust suppression. 3. Construction of new infrastructure and upgrade of existing infrastructure required to carry out the preliminary works including: o construction of a 60-person accommodation camp (including waste water treatment plant (WWTP and sprayfield), landfill, temporary concrete batching plant and water supply infrastructure). o construction of site offices, storage and laydown areas. o upgrade of the existing power supply and communication infrastructure. o maintenance of existing roads. 4. Storage of long lead infrastructure components required for the Proposal. up until such time as the later of one of the following occurs: a. notice issued under s 45(8) of the EP Act; or b. statement issued under s45(5) of the EP Act is final (that is, after period in which to lodge an Page 3 appeal under s 100(3) has expired, or appeal decision under s109(3), in respect of an appeal lodged under s 100(3), is published). and, 5. rehabilitation of the area/s identified in Figure 1 in accordance with current EPA rehabilitation guidance, or if an implementation statement is issued for the Proposal, in accordance with any implementation conditions relating to rehabilitation. Page 4 Figure 1 Location of the Preliminary Works 7W5-00 m ,& l !YJO m iblUOU m lol!,UO m Site E.>ctcn Earl Grey lilhlum Prajecl covalent Figure 2 Ll l HI UM u,oooscd /.1w,_. ;,rd PrPI T 111,r~ Wo r,:, Page 5 Attachment 1 Relevant Decision Making Authorities 1. Minister for Environment 2. Minister for Mines and Petroleum 3. Minister for Water 4. Chief Executive Officer, Department of Water and Environmental Regulation 5. Executive Director, Resource and Environmental Compliance, Department of Mines, Industry Regulation and Safety 6. Chief Dangerous Goods Officer, Department of Mines, Industry Regulation and Safety 7. State Mine Engineer, Department of Mines, Industry Regulation and Safety 8. Chief Executive Officer, Shire of Yilgarn Page 6 m Environmental Protection Authority GOVERNMENT OF WESTERN AUSTRALIA Environmental Protection Act 1986 Section 41A(3) STATEMENT OF REASONS CONSENT TO UNDERTAKE MINOR or PRELIMINARY WORKS Proposal: Earl Grey Lithium Project Proponent: Covalent Lithium Pty Ltd Decision For the reasons outlined below, I, as a delegate of the EPA, have determined to consent to the minor or preliminary works outlined in Schedule 1 attached to this Statement of Reasons. Background On 19 May 2017, Kidman Resources Limited referred the Earl Grey Lithium Project proposal to the Environmental Protection Authority (EPA) under section 38 of the Environmental Protection Act 1986 (EP Act). Subsequent to referral of the proposal, Kidman Resources Limited entered into a joint venture with Sociedad Quimica y Minera in 2018. The newly formed joint venture company was approved as the Nominated Proponent on 21 May 2018, and the company name changed to Covalent Lithium Pty Ltd (Covalent) on 25 October 2018. The mining proposal is to develop a pegmatite-hosted lithium deposit at the abandoned Mt Holland mine site, located approximately 105 kilometres south southeast of Southern Cross in the Shire of Yilgarn. The proposal includes development of an open pit, waste rock dump, integrated waste landform, processing plant, accommodation camp, airstrip, roads and other associated mine infrastructure. The proposal would utilise existing disturbed areas, and includes new vegetation clearing. The EPA determined to assess the proposal at the level of Public Environmental Review with a 4-week review period on 14 July 2017, and released the final Environmental Review Document for public review from 11 February 2019 - 11 March 2019. In advance of a decision or agreement in relation to whether or not the proposal may be implementation under section 45 of the EP Act, the Proponent has sought the EPA's consent to undertake minor or preliminary works related to the proposal. The Atrium Level 4, 168 St Georges Terrace, Perth, Western Australia 6000. Postal Address: Locked Bag 33, Cloisters Square, Western Australia 6850. Telephone: (08) 6364 7000 I Facsimile: (08) 6364 7001 I Email: [email protected] Website: www.epa.wa.gov.au Relevant Statutory and Administrative Provisions The EPA decides to assess a proposal, and before a decision or agreement is made under s45 of the EP Act, all persons are prohibited from implementing a proposal, and relevant decision making authorities are prohibiting from making a decision which would allow the proposal to be implemented, except in relation to minor or preliminary works which the EPA has consented may be implemented - see sections 41(4) and 41 A(3) of the EP Act. The EPA has consented to the minor or preliminary works being done, however the person proposing to undertake those works may still need to obtain other authorisations from other decision making authorities. Section 3.5 of the Environmental Impact Assessment (Part IV Divisions 1 and 2) Procedures Manual 2016 guides what information the EPA requires from a person wanting to undertake minor or preliminary works. In consenting, I have considered whether the: • work is associated with the implementation of the proposal • potential environmental impacts of the work are significant • work would constitute the irreversible and substantial implementation of the proposal, and • work is justified. Materials considered in making this decision In determining to consent to the minor or preliminary works I have considered the following : 1. information provided during discussion about changes to the proposed works at the meeting held 7 February 2019 2. final application with updated proposal information provided 14 February 2019 Consideration 1. Assessment details - proposed work associated with proposal The proposed works are associated with the proposal, and would be carried out as part of the proposal following approval, in the event that the application for Minor and Preliminary works is not approved. All of the proposed works would be undertaken within the proposal Development Envelope. The proposed preliminary works do not require additional native vegetation clearing, however, in accordance with the vegetation mapping undertaken for the proposal, areas classified as "cleared" include isolated patches of degraded vegetation. The majority of the proposed preliminary works would be undertaken in existing disturbed areas, however disturbance to some sparsely vegetated areas within the proposal footprint e.g. accommodation village, and new areas in the proposal footprint e.g. landfill and borrow pit, are likely. 2 2. Details of the proposed work (a) Deconstruction and removal of historic Mt Holland structures, plant, equipment, debris and waste materials (historical infrastructure), to remove environmental and safety hazards and ensure a safe site for future employees and contractors. (b) Construction of new groundwater bores for construction purposes and dust suppression. (c) Construction of new infrastructure and upgrade of existing infrastructure required to carry out the preliminary works including: o construction of a 60-person accommodation camp (including waste water treatment plant (WWTP and sprayfield), landfill, temporary concrete batching plant and water supply infrastructure). o construction of site offices, storage and laydown areas. o upgrade of the existing power supply and communication infrastructure. o maintenance of existing roads. (d) Storage of long lead infrastructure components required for the mining proposal within existing disturbed areas. 3. Potential Environmental Impacts (a) Deconstruction and removal of historic structures, debris and waste materials This activity is not considered to be significant. The site is littered with historical infrastructure and debris. The proponent has advised that the site clean-up would identify and remove several health and safety hazards, including exposure to contamination sources and dilapidated infrastructure, and fire risk. No disturbance to significant flora or fauna habitat is required for the site clean-up. The proponent has advised that it is necessary to undertake the site clean-up to ensure that the site is safe for the future workforce, and to enable re-use of the existing disturbed areas in the Development Envelope. (b) Construction of new groundwater bores This activity is not considered to be significant. The proponent has advised that two new water bores are proposed to be constructed within the historical flooded underground. Hypersaline raw water would be required during the proposed preliminary works for dust suppression, and construction works within existing disturbed areas. The raw water would be transported via pipelines to a lined storage pond/tank close to the abstraction bores. Pipelines would not be laid within 50 metres of native vegetation. Potable water would be required for the accommodation camp, which would be trucked in and stored in temporary holding tanks located at the accommodation village, or other required locations. It is also proposed to use potable water for dust suppression in areas adjacent to the Threatened flora species Banksia sphaerocarpa 3 var. dolichostyla and Priority 1 flora species Microcorys sp. Mt Holland (D. Angus DA 2397). (c) Construction of new infrastructure and upgrade of existing infrastructure These activities are not considered to be significant. The layout for the accommodation village would avoid Threatened, Priority, range extension and new flora species, and Malleefowl mounds. Other required infrastructure would be located in existing disturbed areas, and existing roads would be used to access new areas in the proposal footprint e.g. landfill and borrow pit. Vehicle speed limits would be implemented at the site, and construction activities would only be undertaken during daylight hours to minimise the likelihood of vehicle strikes to Chuditch, and other nocturnal species. Any waste materials collected during the site clean-up, or produced onsite, would either be recycled or disposed to an offsite facility until a Works Approval for the landfill is granted. (d) Storage of long lead infrastructure components This activity is not considered to be significant. The proponent has advised that any long lead infrastructure components, such as additional accommodation village units and plant equipment/components, would be located within existing disturbed areas. 4. Proposed rectification actions The preliminary works proposal has been designed so that it could be rehabilitated to reverse any environmental impacts that may occur. The preliminary works have been designed so that no additional clearing of native vegetation is required, and measures would be implemented to minimise impacts to native fauna species. It is noted that the proposed works would be short-term and located in areas of existing disturbance. Any temporary infrastructure associated with the preliminary works would be decommissioned and removed from site upon completion. The decommissioning and rehabilitation of the preliminary works would also be addressed in the Mining Proposal and associated Mine Closure and Rehabilitation Plan. The proponent has previously advised the EPA of potential safety hazards onsite that require removal to ensure a safe workplace for the future workforce, and to enable re use of the existing disturbed areas. Additionally, should the project not proceed, the removal of the historical infrastructure and debris from the site would enable those areas to be more readily rehabilitated. 4 Schedule 1 Minor or Preliminary Works Authorised Work(s) Location Authorised extent The following works are authorised in Figure 1 Disturbance of up to 71.6 their entirety: ha of land, in areas of existing disturbance 1. Deconstruction and removal of within the Development historic Mt Holland structures, Envelope, during plant, equipment, debris and daylight hours. waste materials (historical infrastructure), to remove environmental and safety hazards and ensure a safe site for future employees and contractors. 2. Construction of new groundwater bores for construction purposes and dust suppression. 3. Construction of new infrastructure and upgrade of existing infrastructure required to carry out the preliminary works including: o Construction of a 60-person accommodation camp (including waste water treatment plant (WWTP and sprayfield), landfill, temporary concrete batching plant and water supply infrastructure). o Construction of site offices, storage and laydown areas. o Upgrade of the existing power supply and communication infrastructure. o Maintenance of existing roads. 4. Storage of long lead infrastructure components required for the Proposal. up until such time as the later of one of the following occurs: a. notice issued under s 45(8) of the EP Act; or b. statement issued under s45(5) of the EP Act is final (that is, after period in which to lodge an appeal under s 100(3) has expired, or appeal decision under s109(3), in respect of an 6 appeal lodged under s 100(3), is published). and, 5. rehabilitation of the area/s identified in Figure 1 in accordance with current EPA rehabilitation guidance, or if an implementation statement is issued for the Proposal, in accordance with any implementation conditions relating to rehabilitation. 7 Figure 1 Location of the Preliminary Works /(-,(J~Om n,rnoo m E 0 :;:, "' ...,."' "" E E C, 0 8 8 "'i i"' E 8 .."' ..oz, E 8 .....0 i E 0 .,:x,.., $ E E 0 0 8 g M i "'i 7&0500 m 761000 m 761500 m 762000 m 762500 m 0 o.s km Earl Grey lithium Pro,ect S;o , 1 l~){ Figure 2 ~-.. ,s,uu, WG,a,,~1!i'.!1 covalent sear.a : :..:m-cJ ...m p,•lld., AA L IT HIUM DroPOSM M100f li-=~;.;;,;;;,,.,;~..,....,e.,,,u,.,.,,'"·,.,.l'"1·------..L.---- and Prel.tr .11ary Works 8 Department of Water and Environmental Regulation Attachment 9 Application form: works approval, licence, renewal, amendment, or registration (v10, Nov 2018) 29 IR-F09 v10.0 Industry Licensing System Appl ication Page 3 of 5 Worl Ii you are applying for a works approval you must provide the following details in accordance with Ille Environmental Protection Regulations 1987. Guidance on • calculating works approval lees is available on the DWER website. Fees relate to the cost of the works, including all capital costs (inclusive of GST) associated with the construction and establishment of the works proposed under the orks approval application. This includes, for example, costs associated with earlll works, hard stands, drainage, plant hire, equipment, processing plant, relocation oi equipment and labour hire. Costs exclude: land purchase costs • Premises Component(s) GategOfY Capacity Range Fee 89 - Putrescible Landfill Site Not applicable NIA Remove ISe lection required ·I ISe lect capacity range ·I IAdd I Total Prem ises Component(s) NIA Premises construction cost Total cost Not more than $20,000 • Calculate otal Fee Total Works Awroval Fee $609.00 Back Exit Continue (C) Copyright 2007 Department of Water aM Environmental Regulation