CCOOM MM MU UN NIITTYY A 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. 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. 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). 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 1 of 5 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). 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. 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. 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. 2 of 5 CAPS Inc. 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? 3 of 5 CAPS Inc. 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? If so, what has the water been used for and where? What is their draw? What are the adequacies of monitoring bores? What are the risks? 9. As part of Alcoa’s RSA9 project, networks of depressurising bores were installed. Are these bores currently in operation? What volume of water is drawn each year from this network? What is the water used for and where? What studies has the DOW and DER done on the impacts of lowering the groundwater table levels associated with the RSA9 project? Where are the reports? 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? 4 of 5 CAPS Inc. 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? 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. Proudly supported by: 5 of 5