avatar Albemarle Catalysts Company B.V. Manufacturing
  • Location: NOORD-HOLLAND 
  • Founded: 1999-01-04
  • Website:

Pages

  • Page 1

    \\ ALBEMARLE’ 2021 Annual Compliance Assessment Report Kemerton Project Document No.: P-74211-0000-BA00-RPT-0274 È HSE i i i Rev. Date Status Prepared By Reviewed By 5 Operations VP Engineering Approval Approval Approval 1 20-Jan-21 Draft N. Croston R. Srdarev J. Day C. Harkin E. Berends 1 |21Jan21 Final N. Croston R. Srdarev J. Day C. Harkin E Betends Ze


  • Page 2

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 This page has been left blank intentionally. KEMERTON PROJECT Page ii P-74211-0000-BA00-RPT-0274


  • Page 3

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 GLOSSARY Term Definition CAR Compliance Assessment Report DoEE Department of the Environment and Energy DRF Declared Rare Flora EP Act Environmental Protection Act 1986 EPA Environmental Protection Authority EPBC Act Environment Protection and Biodiversity Conservation Act 1999 GHG Greenhouse Gas Ha Hectare KSIA Kemerton Strategic Industrial Area LiOH Lithium Hydroxide MS-1085 Ministerial Statement 1085 NC Non-compliance NPI Non-Process Infrastructure OEPA Office of the Environmental Protection Agency PMP Photographic Monitoring Point SWIS South West Interconnected System WMP Water Management Plan KEMERTON PROJECT Page iii P-74211-0000-BA00-RPT-0274


  • Page 4

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 TABLE OF CONTENTS GLOSSARY ........................................................................................................................................................... III 1 INTRODUCTION ...................................................................................................................................... 5 1.1 Project Details ........................................................................................................................... 5 1.2 Purpose of Report ..................................................................................................................... 5 1.3 Report Structure ........................................................................................................................ 6 2 SUMMARY OF PROPOSAL’S IMPLEMENTATION STATUS ....................................................................... 8 2.1 Project Milestones ..................................................................................................................... 8 2.1.1 Notice of Substantial Commencement ........................................................................ 8 2.2 Project Components .................................................................................................................. 8 2.3 Project Issues ............................................................................................................................. 9 3 STATEMENT OF COMPLIANCE .............................................................................................................. 10 3.1 Summary of Compliance Status .............................................................................................. 10 3.2 Environmental Management Plans ......................................................................................... 10 4 REFERENCES ......................................................................................................................................... 22 LIST OF TABLES Table 2-1: Summary of Key Environmental Approvals History ............................................................................8 Table 3-1: Audit Findings – Ministerial Statement 1085 – Conditions ...............................................................11 Table 3-2: Environmental Management Plans Objective’s Status .....................................................................20 LIST OF FIGURES Figure 1-1: Project Site Regional Location ............................................................................................................7 LIST OF APPENDICES Appendix A: Post Assessment Form for Statement of Compliance Appendix B: Documentary Evidence (Electronic) Appendix C: Compliance Status Definitions KEMERTON PROJECT Page iv P-74211-0000-BA00-RPT-0274


  • Page 5

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 1 INTRODUCTION 1.1 Project Details The Kemerton Lithium Plant (the Project) proposal is for the construction and operation of a lithium manufacturing plant, and associated infrastructure, within the Kemerton Strategic Industrial Area (KSIA), approximately 17 kms north-east of Bunbury, Western Australia (Figure 1-1: Project Site Regional Location). The Kemerton Lithium Plant is designed to process up to 1 million tonnes of spodumene ore concentrate, sourced from the Talison Greenbushes Operation. The ore concentrate will be processed within up to five lithium hydroxide product process trains, which are proposed to be brought online one at a time as production increases. These process trains operate using a combination of pyrometallurgical and hydrometallurgical operations to produce a total of up to 100,000 tonnes of lithium hydroxide product and up to 200,000 tonnes of sodium sulfate by-product per year. Up to 1.1 million tonnes of tailings will also be produced as a waste product. The lithium hydroxide product will be transported 155 km by road to the Port of Fremantle for export Sodium sulfate by-product will also be transported by road to either Fremantle or Bunbury for export. Tailings will be transported by road to be disposed of at an approved facility, which remains outside the scope of this report. 1.2 Purpose of Report This Compliance Assessment Report (CAR) has been prepared to meet the requirements imposed on the Project by the Western Australian Minister for Environment, through Ministerial Statement 1085 (MS-1085) and the Commonwealth Minister for Environment, through EPBC 2017/8099. Condition 4.6 of MS-1085 specifically states: “The proponent shall submit to the CEO the first Compliance Assessment Report fifteen (15) months from the date of issue of this Statement addressing the twelve (12) month period from the date of issue of this Statement and then annually from the date of submission of the first Compliance Assessment Report, or as otherwise agreed in writing by the CEO. The Compliance Assessment Report shall: 1. be endorsed by the proponent’s Chief Executive Officer or a person delegated to sign on the Chief Executive Officer’s behalf; 2. include a statement as to whether the proponent has complied with the conditions; 3. identify all potential non-compliances and describe corrective and preventative actions taken; 4. be made publicly available in accordance with the approved Compliance Assessment Plan; and 5. indicate any proposed changes to the Compliance Assessment Plan required by condition 4-1. “ KEMERTON PROJECT Page 5 P-74211-0000-BA00-RPT-0274


  • Page 6

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Condition 10 of EPBC 2017/8099 specifically states: The approval holder must prepare a compliance report for each 12 month period following the date of commencement of the action, or as otherwise agreed to in writing by the Minister. The approval holder must: a.) publish each compliance report on the website within 60 business days following the relevant 12 month period; b.) notify the Department by email that a compliance report has been published on the website within five business days of the date of publication; c.) keep all compliance reports publicly available on the website until this approval expires; d.) exclude or redact sensitive ecological data from compliance reports published on the website; and e.) where any sensitive ecological data has been excluded from the version published, submit the full compliance report to the Department within 5 business days of publication. This CAR provides the status of compliance against all audit elements prescribed under EPBC 2017/8099 and MS-1085 as well as an assessment of how implementation of the environmental management plans has met defined environmental objectives during the reporting period 26 October 2019 through 25 October 2020. Regarding Condition 10, point 5 above, there are no proposed changes to the Compliance Assessment Plan at this time. 1.3 Report Structure This CAR has been prepared in accordance with the former Office of the Environmental Protection Agency’s (OEPA) (now Department of Water and Environmental Regulation (DWER)) Post Assessment Guideline No.3, Preparing a Compliance Assessment Report (OEPA, 2012). KEMERTON PROJECT Page 6 P-74211-0000-BA00-RPT-0274


  • Page 7

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Figure 1-1: Project Site Regional Location KEMERTON PROJECT Page 7 P-74211-0000-BA00-RPT-0274


  • Page 8

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 2 SUMMARY OF PROPOSAL’S IMPLEMENTATION STATUS 2.1 Project Milestones The Kemerton Lithium Plant was environmentally assessed and approved under Part IV of the Environmental Protection Act 1986 (EP Act) by the Environmental Protection Authority (EPA) and by the Commonwealth Department of the Environment and Energy (DoEE) under sections 130(1) and 133(1) of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). A summary of Environmental approvals issued is provided in Table 2-1 below. Table 2-1: Summary of Key Environmental Approvals History Instrument Description Date Ministerial Statement 1085 Gained environmental approval, Part IV, EP Act. 26 October 2018 Works Approval Granted to the Works Approval Holder, subject to the 16 November 2018 W6154/2018/1 prescribed conditions. Granted approval for action to construct and operate a EPBC 2017/8099 26 November 2018 lithium hydroxide manufacturing plant In accordance with Condition 5 of approval EPBC 2017/8099, the date of the Commencement of the Action was 2nd January 2019. 2.1.1 Notice of Substantial Commencement Construction commenced in January 2019 and has progressed in accordance with the defined program. This status and CAR serves to demonstrate substantial commencement of the project in accordance with Condition 3-1 and 3-2 of MS-1085. 2.2 Project Components Non-Process Infrastructure (NPI) buildings comprise of a laboratory, site operations building, mess building, emergency building, wellness centre and gate houses. The processing plant comprises of five lithium hydroxide conversion trains that incorporate the following main areas: • Spodumene delivery and stockpiling. • Calcinating, acidifying and storage of acidified ore area. • Leaching, purification, filtration and tailings collection area. • Reactants delivery and storage area. • Causticizing, and Sodium Sulphate Decahydrate crystallisation. • Crude Lithium Hydroxide (LiOH) evaporation and crystallisation. • Pure LiOH evaporation and crystallisation. • Lithium hydroxide monohydrate drying, packaging and storage. • Anhydrous sodium sulphate crystallisation – Li removal. KEMERTON PROJECT Page 8 P-74211-0000-BA00-RPT-0274


  • Page 9

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 • Sodium sulphate drying, packaging and storage. • Potassium collection building. • Service plant and buildings including, boilers, cooling towers, raw and RO water, and air compressor building. • Engineering Workshop/Warehouse and diesel tanks. 2.3 Project Issues No major project issues occurred during the reporting period. Albemarle is currently constructing two of the five Kemerton lithium hydroxide trains to provide a 50,000 tonnes per year lithium hydroxide conversion capacity. The two trains are currently scheduled to be commissioned in stages starting in the first half of 2021. The timing of the remaining three trains will be based on market demand. Albemarle entered into the MARBL Lithium Operations joint venture with Mineral Resources Limited, which included sale of 40% interest in part of the Kemerton lithium hydroxide facility. Albemarle will continue to complete construction of the Kemerton lithium hydroxide facility and will then hand it over to MARBL Lithium Operations to operate. Since approval of MS-1085, Albemarle has explored various power supply options and is currently seeking approval to connect to the South West Interconnected System (SWIS). The plant will require an initial 29 MW capacity for two trains. As more trains are brought online and as production increases the power requirement of the Kemerton Plant will reach up to 60MW. A Section 45C of the EP Act has been submitted to the EPA on 17 October 2019 to address the following proposed changes: • Include construction and operation of the power station. • Reduce the authorised extent of clearing by 5.51 ha (5.33 ha of native vegetation and 0.18 ha of regenerated farmland). • Reduce the size of the Development Envelope by 5.51 hectares (ha). • Replace Figure 1-1 of Schedule 1 of MS-1085 to reflect the reduced size of the Development Envelope. An application has also been submitted under Section 46 of the EP Act on 17th October 2019 to revise Condition 10-1 and Condition 10-2 (1) of MS-1085 and reflect the changes presented in the Section 45C application. Management solutions for the Kemerton Lithium Plant by-product are yet to be finalised. Albemarle is currently negotiating with suitable waste storage providers and is actively pursuing potential waste minimisation and reuse opportunities in accordance with Condition 8-1 of MS-1085. KEMERTON PROJECT Page 9 P-74211-0000-BA00-RPT-0274


  • Page 10

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 3 STATEMENT OF COMPLIANCE Table 3-1 presents the compliance status of applicable Ministerial Conditions prescribed in MS-1085. Refer to Appendix A for the completed Post Assessment Form (Statement of Compliance) for MS-1085. No nonconformances with MS-1085 were identified for the conditions triggered during the current phase and therefore no corrective action was initiated. Findings are supported with evidence in electronic format (Appendix B). In relation to assessing conformance to approved management plan commitments, the following approach has been taken. Where a particular aspect of a management plan has not been demonstrated to be fully implemented, the management plan conditions and commitments are considered to have been complied with if sufficient evidence exists to demonstrate: • The management plan had otherwise been substantially implemented. • Non-compliant items do not present a significant environmental risk and corrective actions have been initiated. • The overall environmental objectives for that factor have been met. 3.1 Summary of Compliance Status No non-compliances MS-1085 were identified. Table 3-1 presents a summary of compliance findings and status for each Condition of MS-1085. For the purposes of this report, compliance classifications were in accordance with EPA guidelines (EPA, 2012). The definitions of each status are summarised in Appendix C: Compliance Status Definitions. 3.2 Environmental Management Plans This CAR presents a summary of how each management plan objective has been addressed and is supported by documentary evidence and data in the appended electronic evidence. The status of objectives for the Albemarle Operational Environmental Management Plans are listed below in Table 3-2. KEMERTON PROJECT Page 10 P-74211-0000-BA00-RPT-0274


  • Page 11

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Table 3-1: Audit Findings – Ministerial Statement 1085 – Conditions Audit Code Subject Requirement Evidence Phase Timeframe Status Further Information When implementing the proposal, the proponent shall not exceed the MS1085: Proposal authorised extent of the proposal as defined in Table 2 in Schedule 1, unless When implementing the The authorised extent of the proposal has not been exceeded. Overall Compliant Refer elements below M1-1 implementation amendments to the proposal and the authorised extent of the proposal have proposal. been approved under the EP Act. Post clearing survey map provided by BGC Contracting. Cleared area coordinates confirmed by Wood personnel as complying Table 2 Physical elements: Clearing of no more than 54.31ha of native with designated clearing boundaries (email: Post Clearing Survey MS1085: Proposal vegetation and 33.39ha of pine plantation within the Development Envelope of 11/06/2019 from Kristina Chandra to Quyen Dao). 48.8 ha of Construction Completed M1-1 (a) implementation 89.25ha native vegetation and 33.39 ha of pine plantation was cleared. Development site fully fenced and cleared, no further clearing required. Table 2 Operational elements: Process Plant Capacity: No more than 100,000 Initially only 2 trains out of 5 are being MS1085: Proposal tonnes of lithium hydroxide product and no more than 200,000 tonnes of Operation Compliant constructed; therefore, production will M1-1 (b) implementation sodium sulfate by-product produced per year. be well below specified limits. MS1085: Proposal Table 2 Operational elements: Tailings Capacity: No more than 1.1 million Operation Compliant As above M1-1 (c) implementation tonnes per year. The proponent shall notify the CEO of any change of its name, physical address The current official company address is in the ACT; however, or postal address for the serving of notices or other correspondence within EPA Services have been notified of the local WA address for MS1085: Contact Details twenty-eight (28) days of such change. Where the proponent is a corporation or serving notices and the intention is to amend the business Overall Within 28 days of change. Compliant M2-1 an association of persons, whether incorporated or not, the postal address is address once the onsite administration offices are complete and that of the principal place of business or of the principal office in the State. occupied. Time limit for Date of commencement 2 January 2019; as per email to DoEE on Substantial MS1085: The proposal must be substantially commenced within 5 years from the date of substantial 10 January 2019. Letter from DoEE acknowledging Construction commencement by 26 Completed M3-1 this Statement. commencement commencement sighted (ref. 2017/8099). October 2023. Substantial Time limit for The proponent must provide to the CEO documentary evidence demonstrating MS1085: Although the project has commenced there is no requirement to commencement substantial Albemarle Kemerton Plant that they have complied with condition 3-1 no later Construction Completed Refer Section 2.1.1 of this CAR. M3-2 notify the CEO of DWER until 30 days after 26 October 2023. demonstrated by 25 commencement than 30 days after expiration of 5 years from the date of this Statement. November 2023. The proponent shall prepare and maintain a Compliance Assessment Plan Compliance Assessment Plan Revision 0, 12 November 2018 July 2019 or prior to MS1085: Compliance which is submitted to the CEO at least six (6) months prior to the first CAR Pre- sighted. Email submission to DWER (Edwin Berends to Tania implementation, Completed M4-1 reporting required by condition 4- 6, or prior to implementation of the proposal, construction Liaghati) dated 13 Nov 2018 sighted. whichever is sooner. whichever is sooner. Compliance Assessment Plan Revision 0, 12 November 2018 sighted. Includes: The CAP shall indicate: a) the frequency of compliance reporting is annual 1. the frequency of compliance reporting; (Section 2.1). 2. the approach and timing of compliance assessments; b) the approach and timing of compliance assessments specified in Table 2-1 (Section 2.2). Compliance Assessment MS1085: Compliance 3. the retention of compliance assessments; Pre- Plan to be submitted by 26 Completed M4-2 reporting 4. the method of reporting of potential non-compliances and corrective c) the retention of compliance assessments defined in construction July 2019. actions taken; Section 2.3. 5. the table of contents of CARs; and d) the method of reporting of potential non-compliances and 6. public availability of CARs. corrective actions taken is defined in Section 2.4. e) the table of contents of CARs is defined in Section 2.6. f) public availability of CARs is defined in Section 2.7. KEMERTON PROJECT Page 11 P-74211-0000-BA00-RPT-0274


  • Page 12

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Audit Code Subject Requirement Evidence Phase Timeframe Status Further Information Letter received from DWER stating the CAP meets the requirements of Condition 4-2 on 21 Nov 2018 (ref. DWERA- After receiving notice in writing from the CEO that the CAP satisfies the 001586). MS1085: Compliance After receiving notice in requirements of condition 4-2 the proponent shall assess compliance with Quarterly audits undertaken to assess compliance with Overall Compliant M4-3 reporting writing from the CEO. conditions in accordance with the CAP required by condition 4-1. Ministerial Conditions throughout 2020 by Nick Croston of KASA Consulting (Exemplar registered Lead Environmental Auditor #13656). The proponent shall retain reports of all compliance assessments described in 2020 Compliance Assessment Plan. MS1085: Compliance the CAP required by condition 4-1 and shall make those reports available when Albemarle maintains copies of compliance assessments on its Overall As requested by the CEO Compliant M4-4 reporting requested by the CEO. document control system. The Compliance Assessment Plan One administrative potential non-compliance identified in 2020 MS1085: Compliance The proponent shall advise the CEO of any potential non-compliance within Within 7 days of NC being includes the requirement to report non compliance assessment (Condition M2.1) and reported to DWER Overall Compliant M4-5 reporting seven (7) days of that non-compliance (NC) being known. known compliances within 7 days as per this via the 2020 CAR. condition. The proponent shall submit to the CEO the first CAR fifteen (15) months from the date of issue of this Statement addressing the twelve (12) month period from the date of issue of this Statement and then annually from the date of submission of the first CAR, or as otherwise agreed in writing by the CEO. The CAR shall: 7. be endorsed by the proponent’s CEO or a person delegated to sign on the Albemarle submitted its first CAR (CAR 2020) on 24 January 2020 MS1085: Compliance Chief Executive Officer’s behalf; (DWERDT247870). Overall Initial CAR by 26 Jan 2020 Compliant M4-6 reporting 8. include a statement as to whether the proponent has complied with the The 2020 CAR complied with defined requirements as evidenced then annually afterwards conditions; by DWER Compliance Audit Report (DWERA-001586). 9. identify all potential non-compliances and describe corrective and preventative actions taken; 10. be made publicly available in accordance with the approved CAP; and 11. indicate any proposed changes to the CAP required by condition 4-1. Subject to condition 5-2, within a reasonable time period approved by the CEO of the issue of this Statement and for the remainder of the life of the proposal Public the proponent shall make publicly available, in a manner approved by the CEO, Approval documents, including management plans with Within a reasonable time MS1085: availability of all validated environmental data (including sampling design, sampling associated appended datasets relevant to the proposal Overall period approved by the Compliant M5-1 data methodologies, empirical data and derived information products (e.g., maps)) assessment are publicly available via the Albemarle website. CEO. relevant to the assessment of this proposal and implementation of this Statement. If any data referred to in condition 5-1 contains particulars of: 1. a secret formula or process; or Public 2. confidential commercially sensitive information; No request has been made by Albemarle to withhold any MS1085: Not required at availability of 3. the proponent may submit a request for approval from the CEO to not information relevant to the proposal assessment from being Overall As required M5-2 this stage data make these data publicly available. In making such a request the proponent publicly available. shall provide the CEO with an explanation and reasons why the data should not be made publicly available. KEMERTON PROJECT Page 12 P-74211-0000-BA00-RPT-0274


  • Page 13

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Audit Code Subject Requirement Evidence Phase Timeframe Status Further Information Albemarle ensures avoidance of direct and indirect impacts to Threatened Flora and communities through implementation of the Albemarle Kemerton Plant Flora and Vegetation Management Plan. The proponent shall ensure that the construction and ongoing operation of the Monitoring of the Banksia Woodland TEC undertaken annually proposal is undertaken in a manner that avoids direct or indirect impacts to to compare the vegetation condition, species richness and Threatened Flora and communities, including Glossy-leafed Hammer Orchid MS1085: Flora and species density at permanently established transects and For the life of the proposal (Drakaea elastica), Dwarf Bee-orchid (Diuris micrantha), Dwarf Hammer-orchid Overall Compliant Also refer to findings in Table 3-2. M6-1 vegetation Photographic Monitoring Points (PMPs). The most recent survey as approved by the CEO. (Drakaea micrantha), Banksia Woodlands of the Swan Coastal Plain and Low report from the November 2020 survey (GHD, 2020) identified lying Banksia attenuata woodlands or shrublands outside of the Albemarle no measurable or visual change in the vegetation condition of Development Envelope, as shown in Schedule 1. the monitoring or control transects, all ratings for each plot remain stable. Vegetation condition ranged from Very Good to Good condition, which was the same as the 2018 (GHD, 2018b) and 2019 (GHD, 2019a) surveys. Prior to ground-disturbing activities or as otherwise agreed by the CEO, the proponent shall prepare and submit a Flora and Vegetation Monitoring and Management Plan (the Plan) to the CEO. The Plan shall: 1. when implemented, substantiate and ensure that condition 6-1 is being met; 2. detail the proposed frequency, timing and indicative locations of Threatened Flora and Communities monitoring to be implemented during construction and operational phase of the Albemarle Plant; Flora and Vegetation Management Plan Rev.1; 30 November 3. specify management actions for potential impacts including but not limited 2018 (GHD, 2018a) sighted (available on Albemarle website). Prior to ground-disturbing MS1085: Flora and Pre- to those from weeds, Phytophthora cinnamomi (Dieback), increased fire Letter acknowledging receipt and satisfaction with the plan activities or as otherwise Completed Also refer to findings in Table 3-2. M6-2 vegetation construction risk and litter, and changes to surface water and groundwater regimes that received from Anthony Sutton Executive Director of DWER on agreed by the CEO will be implemented during construction and operations to ensure the 3 Dec 2018 (ref. DWERA-001672). management objective in condition 6-1 is achieved; 4. specify trigger criteria that will trigger the implementation of contingency actions to prevent direct or indirect impacts to Threatened Flora and Communities outside of the Development Envelope; and 5. specify management or contingency actions to be implemented in the event that the criteria identified required by condition 6-2(4) have been triggered. In the event that the monitoring specified in the Plan indicates that the criteria specified in the Plan have been triggered, the proponent shall: 1. report such findings to the CEO within 21 days of the criteria being triggered; 2. provide evidence to the CEO which allows for determination of the likely cause of the trigger criteria being reached and to identify any additional The most recent survey report from the November 2020 survey contingency actions required to prevent the criteria being triggered in the (GHD, 2020) identified no measurable or visual change in the MS1085: Flora and future; and Within 21 days of the Not required at vegetation condition of the monitoring or control transects, all Overall M6-3 vegetation 3. if the triggering of the criteria is determined by the CEO to be a result of criteria being triggered this stage ratings for each plot remain stable and no criteria had been activities undertaken in implementing the proposal, immediately triggered. implement the management and/or contingency actions specified in the FVMMP and continue implementation of those actions until the trigger criteria are met, or until the CEO has confirmed by notice in writing that it 4. has been demonstrated that the objective in condition 6-1 will continue to be met and implementation of the management and/or contingency actions is no longer required. KEMERTON PROJECT Page 13 P-74211-0000-BA00-RPT-0274


  • Page 14

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Audit Code Subject Requirement Evidence Phase Timeframe Status Further Information Pre- MS1085: Flora and Approved Flora and Vegetation Management Plan Rev.1; 30 Not required at The proponent may review and revise the FVMMP. construction As required M6-4 vegetation November 2018 (Wood, 2018a) current. this stage Construction Pre- MS1085: Flora and The proponent shall review and revise the FVMMP as and when directed by the The CEO has not requested the Flora and Vegetation Monitoring Not required at construction As notified by the CEO. M6-5 vegetation CEO. and Management Plan be reviewed. this stage Construction Following receipt in writing The CEO confirmed the FVMMP satisfied the requirements of The proponent shall implement the latest version of the FVMMP, which the from the CEO that the MS1085: Flora and condition 6-2 in a letter dated 3 Dec 2018 (ref. DWERA-001672). CEO has confirmed by notice in writing, satisfies the requirements of condition Overall latest Plan satisfies the Compliant Also refer to findings in Table 3-2. M6-6 vegetation Sighted records and monitoring reports (GHD 2019, GHD 2020) 6-2. requirements set out in demonstrate the plan was being effectively implemented. condition 6-2. The proponent shall ensure that construction and ongoing operation of the proposal is undertaken in a manner that: Monitoring undertaken in accordance with the Water Water MS1085: Management Plan Rev.1, 4 December 2018. Summary of For the life of the proposal Management • maintains the quality and quantity of off-site surface and groundwater, to Overall Compliant M7-1 compliance provided in Annual Compliance Report 2019 for as approved by the CEO. Plan the receiving environment including but not limited to the Threatened Water Management Plan (RPS, 2020). Orchid habitat. Prior to ground-disturbing activities or as otherwise agreed by the CEO, the proponent shall prepare and submit a Water Management Plan to the CEO, on the advice of the Department of Water and Environmental Regulation. The Plan shall: 1. when implemented, substantiate and ensure that condition 7-1 is being met; 2. specify management actions including but not limited to those from potential impacts from Acid Sulphate Soils, stormwater runoff and The Water Management Plan Rev.1, 4 December 2018. Water sedimentation) that will be implemented during construction and Prior to ground-disturbing MS1085: operations to ensure the management objective in condition 7-1 is Pre- Management Correspondence from DWER (ref DWERA-001671) specified the activities or as otherwise Completed M7-2 achieved; construction Plan submitted WMP was considered to have met the requirements agreed by the CEO. 3. detail the proposed frequency, timing and indicative locations of of condition 7 of MS-1085. groundwater and surface water monitoring for potential contamination; 4. specify trigger criteria that will trigger the implementation of contingency actions to prevent impacts to the receiving environment including Threatened Flora outside of the Development Envelope; 5. specify management or contingency actions to be implemented in the event that the criteria identified required by condition 7-2(4) have been triggered. KEMERTON PROJECT Page 14 P-74211-0000-BA00-RPT-0274


  • Page 15

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Audit Code Subject Requirement Evidence Phase Timeframe Status Further Information In the event that the monitoring specified in the Plan indicates that the criteria specified in the Plan have been triggered, the proponent shall: Some elevated parameters were detected during 2019 and 2020 1. report such findings to the CEO within 21 days of the criteria being monitoring programs; however, the Annual Compliance Report triggered; 2019 for Water Management Plan (RPS, 2020) specified that all the exceedances identified through routine monitoring events 2. provide evidence to the CEO which allows for determination of the likely were assessed and considered to be due to natural background cause of the trigger criteria being reached and to identify any additional variations; and therefore, criteria for notifying the CEO had not contingency actions required to prevent the criteria being triggered in the Water been triggered. MS1085: future; and Within 21 days of the Management As per the approved Water Management Plan water quality data Overall Compliant M7-3 3. if the triggering of the criteria is determined by the CEO to be a result of criteria being triggered Plan collected during the construction phase is required to further activities undertaken in implementing the proposal, immediately assess the baseline water quality at the site, particularly with implement the management and/or contingency actions specified in the regards to parameters that have not previously been monitored Plan and continue implementation of those actions until the trigger criteria at the site but are related to potential operational phase are met, or until the CEO has confirmed by notice in writing that it has impacts. The trigger values will be reviewed and set following been demonstrated that the objective in condition 7-1 will continue to be the collection of a more significant baseline dataset prior to met and implementation of the management and/or contingency actions operations commencing. is no longer required. Water Pre- MS1085: Not required at Management The proponent may review and revise the Water Management Plan. construction As required M7-4 this stage Plan Construction Water Pre- As notified by Albemarle MS1085: The proponent shall review and revise the Water Management Plan as and Not required at Management construction or as and when required M7-5 when directed by the CEO. this stage Plan Construction by the CEO. Surface and groundwater monitoring records demonstrated that quarterly groundwater and monthly surface water monitoring programs had been implemented in accordance with the WMP Following receipt in writing reports included in documentary evidence in Appendix B). Water The proponent shall implement the latest version of the Water Management from the CEO that the MS1085: In line with the approved WMP (Wood, 2018d), the interim Management Plan, which the CEO has confirmed by notice in writing, satisfies the Overall latest Plan satisfies the Compliant M7-6 trigger values are to continue to be used throughout the 2020 Plan requirements of condition 7-2. requirements set out in monitoring period and until the end of the construction phase of condition 7-2. the plant. Before operational phase monitoring commences, a new set of trigger values will be set based on the baseline dataset gathered in 2019 and 2020. Terrestrial During operation of Albemarle Lithium Plant, the proponent shall ensure that MS1085: Environment For the life of the proposal Not required at Waste was segregated and well managed all reasonable and practicable measures have been undertaken to minimise the The site is not yet operating. Operation M8-1 Quality (Waste as approved by the CEO. this stage on site. generation of waste and its discharge into the environment. management) Within 3 years of the publication of this Statement or as otherwise agreed by the CEO, the proponent shall prepare and submit a Waste Management Plan to the CEO. The Waste Management Plan shall: 1. when implemented, substantiate and ensure that condition 8-1 is being Terrestrial met; Within 3 years of the MS1085: Environment 2. specify targets to be met, and detail actions undertaken to meet those Submission of a Waste management Plan required by 26 publication of the MS Not required at Operation M8-2 Quality (Waste targets by applying principles of Waste Management Hierarchy including October 2021. Statement or as otherwise this stage management) Avoidance, Recovery and Disposal; agreed by the CEO 3. quantify the outcome/s of applying the principle of the “Recovery (re-use, reprocessing, recycling); and 4. provide evidence that all reasonable and practicable measures have been undertaken to Avoid and Recover waste. KEMERTON PROJECT Page 15 P-74211-0000-BA00-RPT-0274


  • Page 16

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Audit Code Subject Requirement Evidence Phase Timeframe Status Further Information After receiving notice in writing from the CEO that After receiving notice in writing from the CEO that the Waste Management Plan the Waste Management satisfies the requirements of condition 8-2, the proponent shall: Plan satisfies the Terrestrial 1. implement the actions in accordance with the requirements of the requirements of condition MS1085: Environment approved Waste Management Plan; and 8-2 and until the CEO has Not required at See MS1085: M8-2. Operation M8-3 Quality (Waste 2. continue to implement the approved Waste Management Plan until the confirmed by notice in this stage management) CEO has confirmed by notice in writing that it has been demonstrated that writing that it has been the targets specified in condition 8-2 have been met and therefore the demonstrated that the implementation of the actions is no longer required. targets specified in condition 8-2 have been met. Terrestrial MS1085: Environment Not required at The proponent may review and revise the Waste Management Plan. See MS1085: M8-2. Operation As required M8-4 Quality (Waste this stage management) Terrestrial As notified by Albemarle MS1085: Environment The proponent shall review and revise the Waste Management Plan as and Not required at See MS1085: M8-2. Operation or as and when required M8-5 Quality (Waste when directed by the CEO. this stage by the CEO. management) Following receipt in writing Terrestrial The proponent shall implement the latest version of the Waste Management from the CEO that the MS1085: Environment Not required at Plan, which the CEO has confirmed by notice in writing, satisfies the See MS1085: M8-2. Operation latest Plan satisfies the M8-6 Quality (Waste this stage requirements of condition 8-2. requirements set out in management) condition 8-2. Greenhouse Gas Management Plan Rev.1 – 29 November 2018 Regular vehicle inspections and maintenance were undertaken; and plant sighted on site was modern and fuel efficient. Note – There are only two controls The proponent shall manage the implementation of the proposal to meet the Examples where energy efficiency measures have been included referenced in the GGMP for the following environmental objective: in the design include: MS1085: Greenhouse gas For the life of the proposal construction phase: - The Causticization heat exchanger is an example of heat Overall Compliant M9-1 (GHG) reporting • avoid, where possible, and minimise greenhouse gas emissions as far as as approved by the CEO. Maintenance of vehicles; and recovery. practicable. Selection of low emission producing - The MVR units have intrinsic heat recovery by design. plant. - Improved water balance example is a general preference of using condensate rather than fresh RO water to produce the process water used on the belt filters. Prior to construction Prior to commencement of construction of the lithium processing plant the MS1085: Pre- commencement or as GHG reporting proponent shall prepare a Greenhouse Gas Management Plan to meet the Greenhouse Gas Management Plan Rev.1 – 29 November 2018. Completed M9-2 construction otherwise agreed by the objective required by condition 9-1. CEO The Greenhouse Gas (GHG) Management Plan shall address the following matters: 1. benchmarking against applicable standards at the time of construction of the lithium processing plant; Greenhouse Gas Management Plan Rev.1 – 29 November 2018. MS1085: Correspondence from DWER (ref DWERA-001589) indicating the For the life of the proposal GHG reporting 2. design of the proposal to minimise greenhouse gas emissions as far as Overall Completed M9-3 submitted GHG MP is considered to meet the requirements of as approved by the CEO. practicable; condition 9 of MS-1085. 3. monitoring and public reporting; and 4. opportunities for continuous improvement and minimising net emissions in the future within the existing design of the proposal. MS1085: Not required at GHG reporting The proponent may review and revise the GHG Management Plan. Albemarle is yet to revise the GHG Management Plan. Overall As required M9-4 this stage KEMERTON PROJECT Page 16 P-74211-0000-BA00-RPT-0274


  • Page 17

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Audit Code Subject Requirement Evidence Phase Timeframe Status Further Information MS1085: The proponent shall review and revise the Greenhouse Gas Management Plan CEO is yet to direct the proponent to review and revise the Not required at GHG reporting Overall As required M9-5 as and when directed by the CEO. Greenhouse Gas Management Plan. this stage Greenhouse Gas Management Plan Rev.1 – 29 November 2018. Correspondence from DWER (ref DWERA-001589) indicating the submitted GHGMP is considered to meet the requirements of condition 9.1 of MS-1085. Regular vehicle inspections and maintenance were undertaken; Construction activities do not require Until the CEO has The proponent shall continue to implement the version of the Greenhouse Gas and plant sighted on site was modern and fuel efficient. reporting as emissions do not exceed confirmed by notice in MS1085: Management Plan most recently approved by the CEO until the CEO has Examples where energy efficiency measures have been included threshold levels (estimated 20,617 t CO2- GHG reporting Overall writing that the plan Compliant M9-6 confirmed by notice in writing that the plan meets the objective specified in in the design include: e (6,774 t CO2-e diesel consumption and meets the objective condition 9-1. - The Causticization heat exchanger is an example of heat 13,843 t CO2-e loss of carbon sink from specified in condition 9-1. recovery. vegetation clearing). - The MVR units have intrinsic heat recovery by design. - Improved water balance example is a general preference of using condensate rather than fresh RO water to produce the process water used on the belt filters. The proponent shall undertake an offset with the objective of counterbalancing S46 and S45C application to change the significant residual impact to 6.37 ha of ‘low lying Banksia attenuata condition 10-1 of MS-1085 to remove woodlands or shrublands’ and 45.73 ha of foraging habitat, including 14.45 ha reference to “6.37 ha of low-lying MS1085: Albemarle to undertake offset in accordance with Offset As defined in the offset Offsets of potential breeding habitat for Carnaby’s Black Cockatoo (Calyptorhynchus Overall In progress Banksia attenuata woodlands or M10-1 Strategy upon approval under Condition 10.2. strategy latirostris), Forest Red-tailed Black Cockatoo (Calyptorhynchus banksii naso) shrublands” Has been submitted and is and Baudin’s Black Cockatoo (Calyptorhynchus baudinii) as a result of currently being assessed by the EPA implementation of the proposal. (Assessment 2232). KEMERTON PROJECT Page 17 P-74211-0000-BA00-RPT-0274


  • Page 18

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Audit Code Subject Requirement Evidence Phase Timeframe Status Further Information Email to registrar@dwer.wa.gov.au (24/10/2019) from Gavin Within twelve months of the publication of this Statement, the proponent shall Edwards, Preston Consulting. The email included the following prepare and submit an Offset Strategy to the CEO. The Offset Strategy shall: attachments: 1. identify an initially unprotected area or areas to be protected and 1. Albemarle Kemerton Plant Offset Strategy (ref- ALB-KEM- managed for conservation that contains the Priority Ecological Community PLA-01) (Preston, 2019) and appendices one, two and and foraging habitat values identified in condition 10-1; three. 2. demonstrate how the proposed offset counterbalances the significant 2. A review of the Offset Strategy identified that its content residual impact through consideration of the six principles and completion was consistent with the requirements of this condition. of the WA Offsets Template, as described in the WA Environmental Offsets 3. Unprotected area identified, and Offset report 'Lot 42 Guidelines 2014, and the Environment Protection and Biodiversity Wellesley Road North, Kemerton Offset Site Study Report’ Conservation Act 1999 Environmental Offsets Policy (October 2012) in (Ecoedge, 2018) confirms area contains Priority Ecological conjunction with the associated Offsets assessment guide; Community (Floristic Community Type 21c ‘Low lying 3. identify the environmental values of the offset area(s); Banksia attenuata woodlands and shrublands’) and 45.73ha 4. commit to a protection mechanism for any areas of land acquisition, being of foraging habitat. either the area is ceded to the Crown for the purpose of conservation, or 4. Offset report included assessment against the ‘six the area is managed under other suitable mechanisms as agreed by the principles’. CEO; 5. Environmental values identified in Offset report. MS1085: Offsets 5. if any land is to be ceded to the Crown for the purpose of conservation, 6. Offset strategy states Albemarle is proposing to undertake Construction 26 Oct 2019 In progress The Offset Strategy M10-2 the proponent will identify: a land acquisition and transferring it to conservation estate 6. the quantum of, and provide funds for, the upfront works associated with as an offset for the significant residual impact of the establishing the conservation area; Proposal. 7. the quantum of, and provide a contribution of funds for, the management 7. Detailed discussion will occur with DBCA on the offset of this area for the first 20 years after completion of purchase, and activities and costs once the EPA approve the s46. Twenty 8. an appropriate management body for the ceded land. year cost management estimate prepared by consultant (Natural Area Consulting Management Services) 'Lot 42 9. identify any threats to offset values and provide management and/or Wellesley Road North, Kemerton Offset Site 20 Year rehabilitation actions to be undertaken to address the threats including: Management Estimate’) was considered by DBCA to be 10. the objectives and targets to be achieved, including completion criteria; commensurate with DBCA’s expectations for similar 11. management and/or rehabilitation actions and a timeframe for the actions conservation areas. to be undertaken; 8. Section 8.3 of the Offset Strategy identifies management 12. funding arrangements and timing of funding for conservation activities; actions. and 9. Threats and response mechanisms are defined in Section 9 13. monitoring requirements for activities. of the Offset Strategy. 14. define the role of the proponent and/or any third parties. 10. Roles and responsibilities are defined in Section 13 of the Offsets Strategy. After receiving notice in writing from the CEO, that After receiving notice in writing from the CEO, on advice of the Department of the Offset Strategy Biodiversity, Conservation and Attractions, that the Offset Strategy satisfies the satisfies the requirements requirements of condition 10-2, the proponent shall: Albemarle Kemerton Plant awaiting response from the of condition 10-2 and until 1. implement the actions in accordance with the requirements of the Department whether the Strategy satisfies the requirements of the CEO has confirmed by MS1085: approved Offsets Strategy; and condition 10-2. DBCA have provided initial comment on the notice in writing that it has Offsets Overall In progress M10-3 2. continue to implement the approved Offset Strategy until the CEO Offset Strategy; however, the Department is not expected to been demonstrated that has confirmed by notice in writing that it has been demonstrated provide formal notice regarding the adequacy of the Offset the completion criteria in that the completion criteria in the Offset Strategy have been met strategy until the Section 45c is approved by EPA. the Offset Strategy have and therefore the implementation of the actions is no longer been met and therefore the implementation of the required. actions is no longer required. KEMERTON PROJECT Page 18 P-74211-0000-BA00-RPT-0274


  • Page 19

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Audit Code Subject Requirement Evidence Phase Timeframe Status Further Information It is acknowledged that the Strategy will MS1085: The proponent shall review and revise the Offset Strategy as and when directed The CEO has not yet directed Albemarle to review and revise the Not required at Offsets Overall As required require refining through further M10-4 by the CEO. Offset Strategy. this stage discussions with DBCA and EPA. The proponent shall implement the latest version of the Offset Strategy, which MS1085: As defined in the offset Not required at Offsets the CEO has confirmed by notice in writing, satisfies the requirements of Offset Strategy yet to be approved and implemented. Overall M10-5 strategy this stage condition 10-2. KEMERTON PROJECT Page 19 P-74211-0000-BA00-RPT-0274


  • Page 20

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Table 3-2: Environmental Management Plans Objective’s Status EMP Subject Key Objectives Target Status Comments No reportable decline of nearby Annual vegetation survey undertaken 11-13 August Endangered/ Declared Rare Flora 2020. The survey report (GHD, 2020) identified no Avoid indirect impact to known FVMMP Orchids (DRF) Drakaea elastica individuals Compliant reportable decline of nearby Endangered/ Declared threatened orchid species or habitat, attributable to the Rare Flora (DRF) Drakaea elastica individuals or Project habitat, attributable to the Project Monitoring of the Banksia Woodland TEC undertaken in August 2020 compared the vegetation condition, No reportable decline to adjacent species richness and species density at permanently areas representative of the Banksia established transects and Photographic Monitoring Avoid indirect impact to vegetation Woodlands of the Swan Coastal Points (PMPs). The survey report (GHD, 2020) and flora (Banksia Woodland TEC / Plain TEC/ Low lying Banksia identified no statistical differences (p >0.5) between Low lying Banksia attenuata FVMMP TEC/PEC attenuata woodlands or shrublands Compliant species richness or species densities between the woodlands or shrublands PEC) PEC, attributable to the Project. base survey in 2018 (GHD, 2018b) and the 2019 (GHD, outside of the Development No incidents of fire originating 2019a) or 2020 surveys at any of the monitoring Envelope. within, and spreading outside of, transects or control transects. the Development Envelope. A review of the project incident register confirmed no incidents of fire had been recorded within the development envelope. Avoid clearing or removal of vegetation and flora (Banksia No incidents of vegetation clearing Woodland TEC / Low lying Banksia No clearing undertaken during the reporting period. FVMMP Clearing outside of the approved Compliant attenuata woodlands or shrublands No further clearing anticipated. Development Envelope. PEC) outside of the Development Envelope. KEMERTON PROJECT Page 20 P-74211-0000-BA00-RPT-0274


  • Page 21

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 EMP Subject Key Objectives Target Status Comments Quarterly weed surveys have identified no discernible changes in weedy grass or herb densities and new weed species. No new Declared Weeds or Weeds No occurrences of *Gomphocarpus fruticosus of National Significance within (Narrowleaf Cottonbush), a species listed as Declared surrounding vegetation, Pest under the Biosecurity and Agriculture Prevent introduction and/or spread attributable to the Project. FVMMP Weeds Compliant Management Act 2007 have been recorded following of weeds into adjacent areas. No significant increase in weed identification and removal of two plants in 2019. cover within immediately adjacent All vehicles and mobile equipment coming to site are vegetation, attributable to the required to complete a hygiene inspection as per the Project. Vehicles, Mobile Plant and Equipment procedure (Doc. No. 606541-7400-AA00-PRO-0011). Records of inspections sighted. No evidence of new Dieback infestation identified within Quarterly Phytophthora dieback surveys have Prevent introduction and/or spread FVMMP Dieback immediately adjacent Compliant identified no signs of new occurrences of Dieback of Dieback into adjacent areas. areas/vegetation resulting from the infestations within the survey area. Project. To ensure that the quality and Quarterly groundwater monitoring program in 2020 quantity of surface water and continued to identify numerous trigger level groundwater flows from the site are To not exceed trigger values for exceedances; however, Tier 2 assessments had been Water MP Water Compliant maintained relative to pre- process related analytes. undertaken and all exceedances could be attributed development conditions, to protect to background concentrations that were not the receiving environment. associated with site activities. The minimisation of scope 1 and Green- Avoid, where possible, and minimise There will be no scope 2 emissions during scope 2 emissions arising from the Not required GHG MP house gas greenhouse gas emissions as far as construction. Construction emissions are estimated to construction phase and operation of at this stage emissions practicable. be approximately 3% of peak operational emissions. the facility. KEMERTON PROJECT Page 21 P-74211-0000-BA00-RPT-0274


  • Page 22

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 4 REFERENCES Ecoedge (2018). Lot 42 Wellesley Road North, Kemerton Offset Site Study Repor. Bunbury, Western Australia: Prepared for GHD on behalf of Albemarle, unpublished. GHD (2017). Albemarle Kemerton Plant. Environmental Management Plan, Rev 0 (November 2017). GHD (2018a). Flora and Vegetation Management Plan Rev.1; 30 November 2018. GHD (2018b). Banksia Woodland Threatened Ecological Community and Drakaea elastica Baseline Monitoring. Unpublished report prepared for Albemarle Lithium Pty Ltd, Perth. GHD (2019a). Banksia Woodland Threatened Ecological Community and Drakaea elastica First Year Monitoring (November 2019). Unpublished report prepared for Albemarle Lithium Pty Ltd, Perth. GHD (2019b). Construction Phase Environmental Services Mosquito Management Plan. Report for Wood PLC (August 2019). GHD (2020). Banksia Woodland Threatened Ecological Community and Drakaea elastica Second Year Monitoring (November 2020). Unpublished report prepared for Albemarle Lithium Pty Ltd, Perth. OEPA (2012). Post Assessment Guideline for Preparing a Compliance Assessment Report, Post Assessment Guideline No. 3. East Perth, WA: Office of the Environmental Protection Authority, Western Australia (August 2012). Preston Consulting (2019). Albemarle Kemerton Plant Offset Strategy – Ministerial Statement 1085. Prepared for Albemarle (ALB-KEM-PLA-01) 24 October 2019. RPS (2020). Annual Compliance Report for 2019 for Water Mangement Plan (EWP72723.008) Rev 0 (26 March 2020). Wood (2018a). Albemarle Kemerton Plant. Flora and Vegetation Monitoring and Management Plan, Rev 1 (November 2018). Wood (2018b). Albemarle Kemerton Plant. Greenhouse Gas Management Plan, Rev 1 (November 2018). Wood (2018c). Albemarle Kemerton Plant. Compliance Assessment Plan, Rev 1 (November 2018). Wood (2018d). Albemarle Kemerton Plant. Water Management Plan, Rev 1 (December 2018). Wood (2019a). Albemarle Kemerton Plant. Construction Environmental Management Plan, Rev 2 (January 2019). Wood (2019b). Albemarle Kemerton Plant. Emergency Management Plan, Rev 1 (March 2019). KEMERTON PROJECT Page 22 P-74211-0000-BA00-RPT-0274


  • Page 23

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 This page has been left blank intentionally. KEMERTON PROJECT Page 23 P-74211-0000-BA00-RPT-0274


  • Page 24

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 APPENDICES KEMERTON PROJECT Appendices P-74211-0000-BA00-RPT-0274


  • Page 25

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 This page has been left blank intentionally. KEMERTON PROJECT Appendices P-74211-0000-BA00-RPT-0274


  • Page 26

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Appendix A: Post Assessment Form for Statement of Compliance KEMERTON PROJECT Appendices P-74211-0000-BA00-RPT-0274


  • Page 27

    POST ASSESSMENT FORM 2 Statement of Compliance 1. Proposal and Proponent Details Proposal Title The proposal is for the construction and operation of the Albemarle Kemerton Plant and associated infrastructure, within the Kemerton Strategic Industrial Area (KSIA), approximately 17 kilometres north-east of Bunbury, Western Australia. The proposalincludes construction of up to five lithium hydroxide product process trains and associated infrastructure Statement Number 1085 Proponent Name Albemarle Lithium Pty Ltd Proponent's 618 095 471 Australian Company Number (where relevant) 2. Statement of Compliance Details Reporting Period 26/10/19 to 25/10/20 Implementation phase(s) during reporting period (please tick Y relevant phase(s)) Pre-construction Y Construction v Operation Decommissioning Audit Table for Statement addressed in this Statement of . ; : : : Section 3.2 Compliance is provided at Attachment: Were all implementation conditions and/or procedures of the Statement complied with within the reporting period? (please tick Y the appropriate box) No (please proceed to Section 3) Yes (please proceed to Section 4) Y Each page (including@itaetiment 2) mustbeinitialed by the person who signs Section 4 of this Statement of Compliance. cal


  • Page 28

    Post ASSESSMENT FORM 2 3. Details of Non-compliance(s) and/or Potential Non-compliance(s) The information required Section 3 must be provided for each non-compliance or potential non-compliance identified during the reporting period covered by this Statement of Compliance. Non-compliance/potential non-compliance 3-1 Which implementation condition or procedure was non-compliant or potentially non-compliant? Was the implementation condition or procedure non-compliant or potentially non-compliant? On what date(s) did the non-compliance or potential non-compliance occur(if applicable)? Wasthis non-compliance or potential non-compliance reported to the Chief Executive Officer, DWER? 0 ms O Reported to DWER verbally Date OO Reported to DWER in writing Date I No What are the details of the non-compliance or potential non-compliance and where relevant, the extent of and impacts associated with the non-compliance or potential non-compliance? Whatis the precise location where the non-compliance or potential non-compliance occurred(if applicable)? (please provide this information as a map or GIS co-ordinates) What was the cause(s) of the non-compliance or potential non-compliance? What remedial and/or corrective action(s), if any, were taken or are proposed to betakenin responseto the non-compliance or potential non-compliance? What measures, if any, were in place to prevent the non-compliance or potential non-compliance before it occurred? What, if any, anendments have been madeto those measuresto prevent re- occurrence? Please provide information/documentation collected and recordedin relation to this implementation condition or procedure: e inthe reporting period addressedin this Statement of Compliance; and e as outlined in the approved Compliance Assessment Plan for the Statement addressedin this Statement of Compliance. (the above information may be provided as an attachmentto this Statement of Compliance) For additional non-compliance or potential non-compliance, please duplicate this page as required. Each page i gga> 2) mustbeinitialed by the person who signs Section 4 of this Statement of Compliance.


  • Page 29

    Post ASSESSMENT FORM 2 4. Proponent Declaration I Folio M [Serene 3 lero le 17 (Ly LM neta andposition title) declare that | am authorised on behalf of .....MAbs recatpte KdiMe an.TEL. (being the person responsible for the proposal) to submit this form and that the information containedin this form is true and not misleading. TI. A L (7 < | aD Signature = alari: Date...ERE Elen Please note that: e itis an offence under section 112 of the Environmental Protection Act 1986 for a person to give or cause to be given information that to his knowledge is false or misleading in a material particular; and e the Chief Executive Officer of the DWER has powers undersection 47(2) of the Environmental Protection Act 1986 to require reports and information about implementation of the proposal to which the statement relates and compliance with the implementation conditions. 5. Submission of Statement of Compliance One hard copy and one electronic copy (preferably PDF on CD or thumb drive) of the Statement of Compliance are required to be submitted to the Chief Executive Officer, DWER, marked to the attention of Manager, Compliance (Ministerial Statements). Please note, the DWER has adopted a procedure of providing written acknowledgment of receipt of all Statements of Compliance submitted by the proponent, however, the DWER does not approve Statements of Compliance. 6. Contact Information Queries regarding Statements of Compliance, or other issues of compliance relevant to a Statement may be directed to Compliance (Ministerial Statements), DWER: Manager, Compliance (Ministerial Statements) Department of Water and Environmental Regulation Postal Address: Locked Bag 10 Joondalup DC WA 6919 Phone: (08) 6364 7000 Email: compliance@dwer.wa.gov.au 7. Post Assessment Guidelines and Forms Post assessment documents can be found at www.epa.wa.gov.au Each page aa2) must beinitialed by the person who signs Section 4 of this Statement of Compliance. MIRAS, 2


  • Page 30

    POST ASSESSMENT FORM 2 ATTACHMENT 1 Table 1 Compliance Status Terms Compliance Abbrev Definition Notes Status Terms Compliant C Implementation of the proposal This term applies to audit elements with: has been carried out in e ongoing requirements that have been accordance with the requirements met during the reporting period; and of the audit element. e requirements with a finite period of application that have been met during the reporting period, but whose status has not yet been classified as ‘completed’. Completed CLD A requirement with a finite period This term may only be used where: of application has been e audit elements havea finite period of satisfactorily completed. application (e.g. construction activities, development of a document); e the action has been satisfactorily completed; and e the DWER hasprovided written acceptance of ‘completed’ status for the audit element. Not required NR The requirements of the audit This should be consistent with the ‘Phase’ at this stage element were not triggered during column of the audit table. the reporting period. Potentially PNC Possible or likely failure to meet This term may apply where during the Non-compliant the requirements of the audit reporting period the proponenthasidentified element. a potential non-compliance and hasnot yet finalized its investigations to determine whether non-compliance has occurred. Non-compliant NC Implementation of the proposal This term applies where the requirements of has not been carried outin the audit element are not “complete” have accordancewith the requirements not been metduring the reporting period. of the audit element. In Process IP Where an audit element requires The term ‘In Process’ may not be used a management or monitoring plan for any purpose other than that stated in be submitted to the DWER or the Definition Column. another government agency for approval, that submission has The term ‘In Process’ may not be used to been made and no further describe the compliance status of an information or changes have been implementation condition and/or procedure requested by the DWER or the that requires implementation throughout the other government agency and life of the project (e.g. implementation of a assessment by the DWER or managementplan). other government agency for approval is still pending. Each page (including Att achment 2) must be initialed by the person who signs Section 4 of this Statement of Compliance. fl pai NREe ' pee


  • Page 31

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Appendix B: Documentary Evidence (Electronic) Click on the link below to access audit evidence and supporting documentation for the Albemarle 2021 CAR: Link to Evidence KEMERTON PROJECT Appendices P-74211-0000-BA00-RPT-0274


  • Page 32

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 This page has been left blank intentionally. KEMERTON PROJECT Appendices P-74211-0000-BA00-RPT-0274


  • Page 33

    2021 ANNUAL COMPLIANCE ASSESSMENT REPORT Revision 1 Appendix C: Compliance Status Definitions Compliance Definition Notes Status This term applies to audit elements with: • Ongoing requirements that have been met during Implementation of the proposal has been the reporting period; and Compliant carried out in accordance with the • Requirements with a finite period of application requirements of the audit element. that have been met during the reporting period, but whose status has not yet been classified as ‘completed’. This term may only be used where: • Audit elements have a finite period of application (e.g., construction activities, development of a document); A requirement with a finite period of • The requirement has been satisfactorily Completed application has been satisfactorily completed; and completed. • The Office of the Environmental Protection Authority (EPA Services) has provided written acceptance of ‘completed’ status for the audit element. The requirements of the audit element Not required at This should be consistent with the ‘phase’ column of were not triggered during the reporting this stage the audit table. period. This term may only be used where during the reporting period the proponent has identified a potential noncompliance and has not yet finalised its Potentially Possible or likely failure to meet the investigations to determine whether noncompliance Non-Compliant requirements of the audit element. has occurred. Where this term is used, the proponent should advise when investigations will be finalised and provide follow up advice of the outcome. Implementation of the proposal has not This term applies where the requirements of the audit Non-compliant been carried out in accordance with the element have not been met during the reporting requirements of the audit element. period and its status is not ‘completed’. Where an audit element requires a management or monitoring plan be The term ‘In process’ must only be used for the submitted to the EPA Services or another purpose stated in the definition column. government agency for approval, that ‘In process’ may not be used to describe the submission has been made and no further In Progress compliance status of an implementation condition information or changes have been and/or procedure that requires ongoing requested by the EPA Services or the other implementation throughout the life of the project government agency and assessment by (e.g., implementation of a management plan). the EPA Services or other government agency for approval is still pending. KEMERTON PROJECT Appendices P-74211-0000-BA00-RPT-0274


  • Page 34

  • View More

Get the full picture and Receive alerts on lawsuits, news articles, publications and more!