and Environmental Regulation

Government

of

Western Australia

Department of Water

and Environmental Regulation

Annual Audit Gompliance Report Form

Environmental Protection Act 1986, Part V Division 3

Once completed, please submit this form either via email

to

info@dwer.wa.qov.au, or to the below postal address:

Department of Water and Environmental Regulation Locked Bag ¹ 0

Joondalup

DC WA

6919

L8796t2013t1 Licence file number:

BENDOTTI EXPORTERS PTY LTD WA CHIP

Lot 689 Franklin Street Manjimup WA

11112019 to

³¹

¹¹²

¹²⁰¹⁹

Did you _comply with all of your licence conditions during the reporting period?

(please tick the appropriate box)

E

Yes

-

please complete:

.

section C;

.

section D (if required); and

o

sign the declaration in Section F.

tr

^No

-

please complete:

.

section C;

.

section D (if required);

.

section E; and

o

sign the declaration in Section F.

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

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

Actual

Part 2

waste discharge quantity

lR-F14 v4.0 (February 2019)

Section

G

- Statement of actual production

Prescribed premises category Actual production quantity

Section

D

- Statement of actual Part

2

waste discharge quantity Prescribed premises category

Section A - Licence details

Licence number:

Licence holder name:

Trading as:

ACN: 099 895 904

Registered business address:

Reporting period:

Section B - ^{Statement of} compliance with licence conditions

Department

of

Water and Environmental Regulation

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

Condition no: Date(s) of non-

March 2019

Details of non-compliance:

Sampling for Smith Brook dam was not undertaken in March of 2019

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

NOTE

-

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

Minimal impact to Smith brook dam is suspected as there were no visual, aromatic, or fauna changes observed in the intervening period.

Cause (or suspected cause) of non-compliance:

The cause of this omission was misinterpretation/misunderstanding of licence amendment notice number 1 where because no reference was made to Smith Brook Dam a misunderstanding arose which lead to an

interpretation

that sampling of Smith Brook dam was not required.

All

new bores and L1 were sampled in March and all subsequent quarterly sampling for Smith Brook dam for the remainder of the reporting period was undertaken

Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the Routine quarterly samples have been programmed for the MB and WQ1 to be collected concurrently.

Was this non-compliance previously reported to DWER?

E

^{Yes, and}

!

^{Reported to} DWER verbally

fl

neported to DWER in writing

Section

E

- ^{Details of} non-compliance with licence condition

3.8.2

Date: I I

Date. I ^I

Department

of

Water and Environmental Regulation

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

January 2019 Date(s) of non-

Condition no:

Details of non-compliance:

Sampling of L1 for January was not undertaken while flowing

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

NOTE

-

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

Minimal impact as relatively low volume and infrequent flows were involved.

Cause (or suspected cause) of non-compliance:

1-

L1 flowed causing a differential of 39m3 between the closing figure for 2018 and the first reading of 2019 while the site was shut down and unattended for the Christmas, New year holiday.

2-

Low infrequent flows during the balance of January did not allow for non-contaminated samples to be taken.

Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the L1 samples are taken methodically by Bendotti Exporters. Low flows that don't allow for clean sample collection could be mechanically altered to allow for easier collection but this would increase the risk of the high-volume flows throughout the year being under-read.

Bendotti Exporters will attempt to keep the L1 outflow collection point clean for sampling but this will be a challenge due to the quantity and diversity of fauna that frequents L1 .

Was this non-compliance previously reported to DWER?

!

^{Yes, and}

!

^{Reported to} DWER verbally

E

neported to DWER in writing

Annual Audit Compliance Report Form (September 2017)

3.5.1

Date: I ^I

Date: I I

Department

of

Water and Environmenta! Regulation

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

Date(s) of non-

February 2019 Details of non-compliance:

Sampling of L1 for February 2019 was not undertaken while flowing

\A/hat was the actual (or suspected) environmental impact of the non-compliance?

NOTE

-

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

Minimal as the FP quality during January & February 2019 was good due to the large amount of time during November, December 2018 and January 2019 where there was no production, therefore, no waste water inflows were received by the ponds.

Cause (or suspected cause) of non-compliance:

The cause of the failure to take

Ll

samples during February appears to be an overload in Bendotti management combined with a misunderstanding between ourselves and West Coast Labs each believing the other had sampled L1. The Bendotti management overload is partly attributed to the organising, installation, commissioning and initial testing of the new bores in addition to the submitting details in accordance with the Amended DWER Licence. Workloads in the early months of the year are very high as export, mass new staff inductions and training prior to double shifts beoinninq and the busiest

Action taken to mitigate any adverse effects of non-compliance and prevent recurrence of the Bendotti Exporters has streamlined the beginning of year workload between 3 staff lor 2O2O as compared to 2 during 2019. January and February 2O2O samples have been collected this year.

Was this non-compliance previously reported to DWER?

E

^{Yes, and}

n

neported to DWER verbally

!

^{Reported to} DWER in writing

Section

E

- ^{Details of} non-compliance with licence condition

Condition no: 3.5.1

Date: I ^I

Date: I ^I

Department

of

Water and Environmental Regulation

1 lt is an offence under section 112 of the Envircnmental Protection Act 1986 for a person to give information on this form that to their knowledge is false or misleading in a material particular.

2 AACRs can only be signed by the licence holder or an authorised person with the legal authority to sign on behalf of the licence holder.

I / We declare that the information in this Annual Audit Compliance Report is true and correct and is not false or misleading in a material particularl.

I

/ We

consent

to the

Annual

Audit

Compliance Report being published

on the

Department of Water and Environmental Regulation's (DWER) website.

Signature2: Signature:

Name: (printed) Name: (printed)

Position: General Manager Position:

Date: 30 March 2O2O Date:

Seal (if signing under seal):

Annual Audit Compliance Report Form (September 2017)

Section

F

- Declaration