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ALLLLIIAANNCCEE FFOORR
PPOOSSIITTIIVVEE SSOOLLUUTTIIOONNSS IINNCC.. ((CCA
APPSS))
P.O Box 69, Yarloop, WA 6218
0409335011 or 0409370235
Email: caps6218@yahoo.com
Web: www.caps6218.org.au
Phone number
CAPS MEETING WITH DEPARTMENT OF WATER - 21 JANUARY 2015
Groundwater Contamination and Water Usage: Questions
1. Alcoa states in its groundwater monitoring data/reports, that groundwater contamination
at Wagerup Refinery residue storage area (RSA) is confined to superficial aquifers at the
site.
Reference: Alcoa email: From Trevor Naughton to Tom Busher: 30 December 2010.
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
Provide corroborating information to show the contaminated water is only
confined to superficial aquifers at the site and does not extend to deeper
aquifers, i.e. water monitoring results in same area in the deeper formations.
What attempts or measures have been taken to repair the damage to ROCP
1?
2. Alcoa claims that the plume of groundwater contamination is contained within the
property boundaries of the Wagerup refinery site. However, data shows movement of
alkaline groundwater from ROCP 1 to have extended to within 1.5 km of the property’s
western boundary by 2010.
Reference: Alcoa email: From Trevor Naughton to Tom Busher: 30 December 2010.
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Provide any data indicating the current (31 Dec. 2014) extent of alkaline
groundwater from ROCP 1, particularly in relation to the property’s western
boundary?
What, according to DOW and DER, is Alcoa’s boundary/footprint?
3. Part 3 et seq. of the Contaminated Sites Act 2003 (WA) provides for the classification of
sites as “contaminated – remediation required”, requiring person(s) responsible for the
contamination, to whom notice of the classification has been given, to remediate the site
(and “site” is defined by the Act to include underground water).


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Has the site been classified as “contaminated – remediation required”? If
not, why not?
If the site has been classified as “contaminated – remediation required”, has
a notice to remediate been given to Alcoa? If not, why not?
If a notice to remediate has been given to Alcoa, has Alcoa taken action to
comply with the notice? If not, why not?
Request copies of any materials or documents relating to issues concerning the site and
arising under the Act, including chemical analysis/testing on contaminated groundwater.
4. In conjunction with the movement of alkaline groundwater from ROCP 1, leakage was
known since 1992 and confirmed in 2000 that some metals (in particular, uranium) have
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Yarloop
Waroona
Hamel
Harvey
Cookernup
Wagerup
Other
Impacted
Areas
CAPS Inc.
Groundwater Contamination and Water Usage: Questions
mobilised, due to the surface expressions of contaminated groundwater in the drain to the
west of the RSAs, which now contains elevated levels (0.0014 mg/L) of uranium.
(Groundwater contamination is at all 3 Alcoa sites, Kwinana, Pinjarra and Wagerup).
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What is being done to remediate this drain?
What steps are being taken to prevent such water from leaving the drain
(i.e., leaving the Alcoa property boundary)?
What steps are being taken to control or manage the elevated levels of
uranium and iron and demobilisation of other metals?
5. Alcoa comments that uranium levels are “acceptable” for stock water.
however, no mention of acceptability of these levels for human consumption.
There is,
Reference: Alcoa email: From Trevor Naughton to Tom Busher 30 December 2010.
There are other users of water from the west drain downstream that are drawing on this
water.
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Has DOW undertaken downstream water quality testing/analysis of water
draining from the RSAs? If not, why not?
Has DOW liaised with the DOH and DER to determine if the downstream
water is fit for human consumption? If not, why not?
Request copies of any reports relating to testing/analysis of downstream
water from the RSAs?
Identify the current Western Australian safe level standards for heavy
metals?
What are the USEPA safe level standards for heavy metals?
What is DOWs and DERs view with respect to the statements in some reports that
there are no safe levels for heavy metals?
Reference: Doctors for the Environment, Australia-Submission on the proposed variation to
the Ambient Air Quality NEPM October 2014 (P 2-3).
6. Alcoa’s water monitoring data has indicated that, for many years, contaminated water
has been leaving the RSAs and migrating into the farmlands west, of the RSAs, suggesting
that eventually this water will leave the Alcoa property boundary and contaminate
surrounding properties.
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
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What strategies are in place to prevent or remediate such
contamination?
If there are no strategies in place, why not?
If there are strategies in place, what are the timeframe or trigger events
for implementing such strategies?
7. To date, we’re unaware of any action being taken to stop Alcoa from contaminating
groundwater area: why is this?
8. With regard to the issue of contaminated water leaking from ROCP 1, Alcoa estimates
that, due to the increase of water flowing into ROCP 1, the pond is now unable to manage
a 1:100 year, 72-hour storm event.
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Groundwater Contamination and Water Usage: Questions
 Given that such storm events are projected to occur on a more regular basis
due to climate change, what is the DOW and DER doing to address the
increased chance that the ROCP 1 overflows and contaminates surrounding
farmlands beyond Alcoa’s boundary?
Reference: Alcoa W.A. Residue Operations, Wagerup Residue RSA 9/ROCP 3 WG
000159 (P.4).
9. Based on Alcoa’s reported modelling, the ROWS pond is currently only just able to cope
with a 1:100 year, 72-hour storm event. Alcoa’s modelling indicates that the ROWS pond
has insufficient capacity to cope with the annual net accumulation of ROW, given the
increase in the rate of accumulation as a result of RSA 9 and also the future RSA 10
coming online.

Given that there is an increased likelihood of loss of containment of
contaminated water from the residue area into properties beyond the
Alcoa boundary and could result in severe environmental harm, what are
the DOW and the DER doing to address the capacity of the ROWS pond?
References:
Alcoa Wagerup ROWS Pond Capacity (P1): 2 of December 2009.
WG0236-Wagerup Cooling Efficiency Upgrade Solutions Analysis Workshop 3 (P1):
29 October 2012.
Hatch Report: Alcoa Wagerup ROWS Pond Project. WG 0159, ROWS Pond
Capacity (P.A1)16 November 2010.
10. Given that both loss of containment issues associated with the ROCP 1 and ROWS
pond would breach Alcoa’s licence conditions, what is DOW and the DER doing to ensure
that Alcoa is able to operate the residue area with sufficient capacity to manage ROW or a
1:100 year, 72-hour storm event.
Water usage
1. What is the sustainable yield in relevant aquifers in Kwinana, Pinjarra and Wagerup?
2. How close are the total extraction rates in each aquifer to the maximum perennial yield?
3. How much of the current yield of such aquifers is Alcoa permitted to extract (percentage
of total industry and commercial farming extractions)?
4. What is the trend in levels of groundwater quality and quantity in the area?
5. What measures has DOW adopted to reflect the effects of climate change on water
availability (e.g., assuming a further 20% reduction in rainfall)? Will there be a need to
revisit water extraction licences in the future?
6. What is the current total Alcoa Wagerup water usage, including the Willowdale mine
site?
7. What is the total number Alcoa Wagerup water licences, including groundwater
licences?
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Groundwater Contamination and Water Usage: Questions
8. In 2011, Alcoa applied for permits to install and operate 4 production bores. Are these
being operated currently?
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If so, what has the water been used for and where?
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What is their draw?

What are the adequacies of monitoring bores?
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What are the risks?
9. As part of Alcoa’s RSA9 project, networks of depressurising bores were installed.
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Are these bores currently in operation?
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What volume of water is drawn each year from this network?
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What is the water used for and where?
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What studies has the DOW and DER done on the impacts of lowering
the groundwater table levels associated with the RSA9 project?
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Where are the reports?
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How will this impact the dairy and vegetable farmers/landholders in the
area (i.e. the food bowl)?
10. Alcoa has engaged a consultant to undertake a preliminary desktop assessment of the
site to describe the extent and behaviour of water pollution, and we understand this
report will be available end of year 2014. Has DOW been provided with a copy of this
report and any copies of drafts of this report?
11. CAPS requests access to this preliminary report in 3 months and including third-party
critical reviews from Department of Water and Department of Health.
12. Is the DOW liaising with the DER contaminated sites branch or the Contaminated Sites
Committee established under s33 of the Contaminated Sites Act regarding any of the
site contamination issues?
13. In view of projected impacts of climate change and Alcoa’s current and projected use of
water:

How does the DOW intend to manage the demands for water among various
users in a fair and equitable way, and in order to ensure that human
consumption and agricultural use remains the priority for supply?

Is the DOW liaising with Harvey Water regarding Alcoa’s use of agricultural
irrigation water for commercial purposes?
14. What is the total water allocation quota for:

Alcoa

Farmers/landholders.
15. Between Alcoa and farmers/landholders, who has precedence in water rights during
drought seasons?

What is the cost per kilolitre for each of these groups?
16. What are DOW and Alcoa’s contingency plans for extreme weather occurrences?
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Groundwater Contamination and Water Usage: Questions
17. What evidence do the DOW and DER have to support Alcoa’s claim that the depressurising
bore field will not have long-term impacts?

Was drawdown modelling undertaken?
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By whom? What were the outcomes?

Where is the report?
18. How does Alcoa intend to manage the degradation of the RSAs’ liner system to prevent
failures that would lead to soil, surface water and groundwater contamination?
19. Do the DOW and DER undertake regular inspections of Alcoa’s RSAs whilst in
construction to ensure compliance with WA conditions? If not, why not?
Recycled Water
1. What is the amount of in-house recycled water used by Alcoa, as a percentage of the
total amount of water used by all three of Alcoa’s refineries combined?
2. What percentage of water used at each of these refineries (Kwinana, Pinjarra,
Wagerup), is recycled water?
3. Why does Alcoa not use recycled water from other sources such as Perth, Mandurah or
Bunbury for its industrial purposes, rather than scarce and precious resource (fresh
water)?
4. Could Alcoa/Industry build a desalination plant to provide water for processing from
Wellington Dam or the Indian Ocean? Using some cost sharing arrangement with the
State Government, Dept of Water?
Yours Sincerely
Vince Puccio
Merv McDonald, AFSM
Co-Chairs: Community Alliance for Positive Solutions Inc.
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