Basic Assessment Report and Environmental Management Programme Report

BASIC ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).

NAME OF APPLICANT: Tawana Investment Holdings (Pty) Limited

TEL NO: 011 782 4322

FAX NO: 011 782 3401 POSTAL ADDRESS: PO Box 48477, Roosevelt Park, 2129 PHYSICAL ADDRESS: Tawana Investment Holdings, 11 Beyers Naude Drive, Montgomery Park, Johannesburg, 2129

FILE REFERENCE NUMBER SAMRAD: NC30/5/1/1/2/12148PR

IMPORTANT NOTICE In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as amended), the Minister must grant a prospecting or mining right if among others the mining “will not result in unacceptable pollution, ecological degradation or damage to the environment”.

Unless an Environmental Authorisation can be granted following the evaluation of an Environmental Impact Assessment and an Environmental Management Programme report in terms of the National Environmental Management Act (Act 107 of 1998) (NEMA), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological degradation or damage to the environment.

In terms of section 16(3)(b) of the EIA Regulations, 2014, any report submitted as part of an application must be prepared in a format that may be determined by the Competent Authority and in terms of section 17 (1) (c) the competent Authority must check whether the application has taken into account any minimum requirements applicable or instructions or guidance provided by the competent authority to the submission of applications.

It is therefore an instruction that the prescribed reports required in respect of applications for an environmental authorisation for listed activities triggered by an application for a right or a permit are submitted in the exact format of, and provide all the information required in terms of, this template. Furthermore please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the Regulation and will lead to the Environmental Authorisation being refused.

It is furthermore an instruction that the Environmental Assessment Practitioner must process and interpret his/her research and analysis and use the findings thereof to compile the information required herein. (Unprocessed supporting information may be attached as appendices). The EAP must ensure that the information required is placed correctly in the relevant sections of the Report, in the order, and under the provided headings as set out below, and ensure that the report

is not cluttered with un-interpreted information and that it unambiguously represents the interpretation of the applicant.

OBJECTIVE OF THE BASIC ASSESSMENT PROCESS The objective of the basic assessment process is to, through a consultative process─ (a) determine the policy and legislative context within which the proposed activity is located and how the activity complies with and responds to the policy and legislative context;

(b) identify the alternatives considered, including the activity, location, and technology alternatives;

(d) through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which focused on determining the geographical, physical, biological, social, economic, heritage , and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on the these aspects to determine:

(i) the nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and (ii) the degree to which these impacts— (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be managed, avoided or mitigated; (e) through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will impose on the sites and location identified through the life of the activity to— (i) identify and motivate a preferred site, activity and technology alternative; (ii) identify suitable measures to manage, avoid or mitigate identified impacts; and (iii) identify residual risks that need to be managed and monitored.

PART A SCOPE OF ASSSSMENT AND BASIC ASSESSMENT REPORT

1. Contact Person and correspondence address a) Details of the EAP

Prime Resources (Pty) Ltd EAP: - Jonathan van de Wouw

Prime Resources has affiliations- / is registered Professional affiliation / registration: with: SACNASP, ECSA and SAIMM

Contact person (if different from N/A EAP):

Company: Prime Resources (PTY) Ltd

The Workshop, No. 70 – 7th Ave, Parktown Physical address: North, Johannesburg, 2193

Postal address: PO Box 2316, Parklands

Postal code: 2121 Cell:

Telephone: 011 447 4888 Fax: 086 604 2219

E-mail: [email protected] b) Expertise of the EAP i) The qualifications of the EAP (with evidence)

Prime Resources is a specialist Environmental Consulting Firm providing environmental and related services, which was established in 2003. Prime Resources was founded by Peter Theron (PrEng, SAIMM), the Managing Director and Principal Environmental Consultant of the firm, who has a GDE Environmental Engineering from the University of Witwatersrand and over 30 years’ experience in the field of environmental science and engineering.

Jonathan van de Wouw, a Principal Environmental Scientist and Project Manager, has a BSc(Hons) Microbiology and Biotechnology (cum laude) from the University of Witwatersrand and 10 years’ experience in the field of environmental science.

Claire Kennedy, an Environmental Consultant has a BSc (Civil Engineering) from the University of Cape Town and an MSc (Environmental Engineering) from the University of Strathclyde, and 4 years’ experience in the field of civil and environmental engineering.

Itumeleng Morosele, an Environmental Consultant has a B.Sc. (Hons) Geography (cum laude) from the University of Johannesburg and is a M.Sc. Environmental Management candidate. She has experience in geographic information systems and has been involved in conducting compliance audits.

Key Prime Resources Personnel CVs are attached as Appendix 1.1. ii) Summary of the EAP’s past experience (in carrying out the Environmental Impact

Assessment procedure)

The EAP’s past experience is fully described in the Prime Resources Company Profile (attached as Appendix 1.2) when read together with the personnel CVs in Appendix 1.1.

2. Location of the overall activity

FARM NO PTN NO PROPERTY OWNER TITLE DEED NO 21 DIGIT CODE DESCRITPTION 1 Farm York 279 Portion L1 (A portion of Portion 1) Hotazel Manganese Mines (Pty) Ltd. T2426/2010 C04100000000027900001 2 Farm Hotazel 280 Portion L1 (A portion of Portion 1) Hotazel Manganese Mines (Pty) Ltd. T3049/2010 C04100000000028000000

See table above for details of the farm names entailed in Farm Name this application.

The prospecting area on Farm York 279 is 28.7 ha Application area (Ha) The prospecting area on Farm Hotazel 280 is 114 ha The total prospecting area is 142.722 hectares in extent

The prospecting area is situated within the Joe Morolong Magisterial district Local Municipality and the Magisterial District of John Taolo Gaetsewe, Northern Cape.

Distance and direction from The proposed prospecting area is located approximately nearest town 1km south-east of Hotazel.

21 digit Surveyor General Code for See table above for the Surveyor General Code for each farm each farm portion portion.

a) Locality map (show nearest town, scale not smaller than 1:250000)

Figure 1: Locality map showing the area considered in the Prospecting Rights Application and proximity to the nearest town, Hotazel 6

3. Description of the scope of the proposed overall activity (provide a plan drawn to a scale acceptable to the competent authority but not less than 1: 10 000 that shows the location, and area (hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site) a) Listed and specified activities

AERIAL WASTE APPLICABLE EXTENT OF LISTED MASNAGEMENT NAME OF ACTIVITY LISTING NOTICE THE ACTIVITY ACTIVITY AUTHORISATION

Prospecting Right Application (without bulk sampling): 142.722 ha X GN 983 Activity 20: N/A

Phase 1 (Non-invasive): 142.722 ha Not listed N/A - Literature Review / Desktop studies / Geological monitoring - Geographical mapping of the exposed ore - Review and validation of previous boreholes Phase 2 (Insignificantly invasive): 142.722 ha Not listed N/A - Geophysical survey to confirm structural continuity, using ground magnetics and ground gravity techniques - Soil Sampling - Laboratory testing and analysis of samples Phases 3 – Drilling Programme (invasive) (If Phase 1 and 2 determine it is necessary, 15 infill boreholes are proposed) - In-fill drilling of up to 15 diamond drill holes, to depths between 30 metres and 90 metres, if required after initial studies

- Access track to drill sites – existing access tracks are likely to be Not listed N/A used (allowance for additional 150m in terms of financial provision for rehabilitation). 2 - A drillers laydown area for Est. 400 m Not listed N/A o a temporary storage shed o a water tanker o chemical toilet o a mobile bowser

AERIAL WASTE APPLICABLE EXTENT OF LISTED MASNAGEMENT NAME OF ACTIVITY LISTING NOTICE THE ACTIVITY ACTIVITY AUTHORISATION

- Sampling to be performed in an accredited laboratory N/A Not listed N/A

- Drilling water will be sourced from the municipality from the N/A Not listed N/A Town of Hotazel, unless existing supply is available on site. No abstraction boreholes will be drilled to avoid triggering a water use. The estimated use of water per day is 5 000 liters per diamond drill rig

Phase 4 (Non-invasive): - Completion of economic study. 142.772 ha Not listed N/A - Preparation of mining right application plant

b) Description of the activities to be undertaken (describe Methodology or technology to be employed, including the type of commodity to be prospected/mined and for a linear activity, a description of the route of the activity)

Tawana Investment Holdings (Pty) Ltd (TIH) has submitted an application for a Prospecting Right for Manganese (Mn) and Manganese bearing minerals as well as Iron (Fe) and Iron bearing minerals including haematite, goethite, speccularite and limonite to the Department of Mineral Resources (DMR), which was accepted on 12 April 2018. The application covers portions of two farms within the Joe Morolong Local Municipality in the Northern Cape Province; Hotazel and York. The Prospecting Right Area (PRA) is located approximately 1 km south-east of Hotazel (refer to Figure 1) on a historically opencast-mined site. Exploration activities within the PRA were undertaken previously by South 32 through its subsidiary, Hotazel Manganese Mines, which included the drilling of 17 prospecting boreholes, however the information acquired from these exploration activities needs to be reviewed and validated. TIH also intends to undertake surface sampling of the exposed geological material. Based on the results the desktop studies and geophysical surveys, it will then be determined if additional infill boreholes will be required, including final numbers and locations.

The overall objective of the prospecting program is to identify the nature and extent of the target mineralisation which can potentially be economically mined in future. The prospecting activities will take place in the form of initial non-invasive prospecting activities, followed by invasive prospecting should the outcomes of the non-invasive activities warrant such.

Non-Invasive Activities

Desktop Studies - The geological literature review and desktop studies will involve assessing all available geological literature with respect to the prospecting area. Extensive prospecting and exploration activities have previously been undertaken over both Farms making up the PRA. TIH will acquire all existing exploration results and data obtained in this regard. This data, together with any other available information will be evaluated in terms of developing a detailed geological model for each mineral forming part of the application.

Geographical Mapping of the Exposed Ore – A geologist will conduct a study of the site, inspecting the areas of exposed ore and produce a map depicting these areas and detailing geological features.

Review and Validation of Previous Boreholes – Historic studies done on the site will be obtained and assessed to determine the extent of information available and whether it is of sufficient quality and quantity, from which a decision to undertake further infill borehole drilling will be made.

Geophysical survey - to confirm structural continuity, ground magnetics and ground gravity techniques will be used.

Soil Sampling - If required grab and soil sampling will be undertaken. Grab sampling and soil sampling surveys will be designed in accordance with the findings of the desktop studies. Soil samples will be taken at prescribed intervals or at points of exposed geological material. Such soil sampling entails a

geologist walking the area with a soil auger. The impacts of this activity are insignificant and hence regarded as non-invasive.

Invasive Activities - Drilling Activities

The main invasive activity during the prospecting period will be the drilling of boreholes if required. Currently it is expected that drilling of core (diamond) drill holes will be performed. Extensive prospecting and exploration activities have previously been undertaken over both portions of the farms; York 279 (Portion L1) and Hotazel 280 (Portion L1). TIH will seek to acquire all existing exploration results and data obtained in this regard and intends on utilising the initial “non-invasive prospecting” period to complete an evaluation of this data and thereafter decide whether any further confirmation drilling (to validate the previous results) will be necessary.

At this early stage, allowance has been made for 15 infilll boreholes to be drilled at a depth of 30 to 90 m. Water for use in drilling activities will be obtained from the municipality in the town of Hotazel, or if available from existing sources on site.

Drilling activities will utilise biodegradable and environmentally acceptable drill fluids and activities will take place using tarps and plastic sheeting to line surfaces and sumps. Portable (chemical) ablutions will be used. Separate closed wheelie bins will be provided for temporary storage and handling of waste, to be removed for disposal by the drilling contractor at licenced facilities as – and when necessary

On the completion of drilling activities each borehole will be plugged or properly covered, to prevent animals and people from injuring themselves. The cleared areas will be allowed to revegetate naturally.

All core assays will be submitted to an accredited laboratory for analysis.

Since the exploration program is results driven, updated final drill position plans and drill information will be submitted to DMR after conclusion of the non-invasive exploration activities by way of the required MRDA Regulation 8 progress reports.

c) Policy and legislative context HOW DOES THIS DEVELOPMENT COMPLY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT The Mineral and Petroleum Resources Development Act, No. 28 of An integrated application in An application for a Prospecting Right was 2002 (MPRDA) is the key legislation governing mining activities within terms of the MPRDA and submitted to the DMR for which an acceptance South Africa. It details the requirements and processes which need to be NEMA is being undertaken. letter was issued on 12 April 2018. Approval for followed and adhered to by mining companies. The Department of Mineral The NEMA process for the extension of submission of the BAR and EMP was Resources (DMR) is the competent authority that deals with all mining proposed project is described given on 3 July 2018 for submission on 17 August related applications. below. 2018. The National Environmental Management Act, No. 107 of 1998 (NEMA) is enabling legislation intended to provide a framework for integrating environmental management into all developmental activities to promote co-operative environmental governance with regard to decision making by state organs on matters affecting the environment. The Environmental impact Assessment (EIA) Regulations of GNR982, This Basic Assessment December 2014 as amended in 2017 serve to regulate the procedure and Report (BAR) and According to the EIA Regulations (GNR982, 2014) criteria for submitting, processing and considering decisions for applications Environmental Management the following will be submitted in support of the for Environmental Authorisation. These Regulations provide details on the Programme (EMP) has been application for Environmental Authorisation: process to be followed for the consultation of stakeholders and IAPs, the prepared to meet the BAR / EMP (this document) together with the identification of the Competent Authority, and the various timeframes and requirements of the EIA results of consultation with Interested and application requirements for Environmental Authorisation. A further three Regulations (GNR982 of Affected Parties (IAPs) and State Departments, Regulations, GNR983, GNR984, and GNR985 (all of 2014 as amended in 2014). which must be submitted to the DMR within 90 2017), provide lists of activities for which Environmental Authorisation, Refer to Section 3(a) of the days (by 17 August 2018). either in the form of a Basic Assessment or Scoping and EIA is required BAR for the listed activities before the activity can commence. applicable to the proposed Since the enactment of the “One Environmental System” on 8 December project. 2014, the Environmental Authorisation process in terms of the NEMA must be followed for any mining activities requiring a right or permit in terms of the MPRDA to fulfil the requirements of Section 5A(a) of the Act. In instances where Environmental Authorisation is required for a mining project, the DMR is identified as the Competent Authority. The National Environmental Management Air Quality Act, No. 39 of 2004 (NEMAQA) has placed the responsibility for air quality management No listed activities in terms of the NEMAQA are on local authorities that will be tasked with baseline characterisation, Refer to Section 5(a) where triggered by the proposed project. Therefore, no management and operation of ambient monitoring networks, licensing of the current air quality in the AEL is required. project area is characterised. listed activities, and emissions reduction strategies. GN893 of 2013 provides Activities associated with the proposed project are the list of activities in terms of Section 21(1)(a) for which licensing is unlikely to result in exceedances in the air quality required in terms of Chapter 5 of the Act. This notice further establishes 11

HOW DOES THIS DEVELOPMENT COMPLY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT minimum emission standards for the listed activities. standards. The ambient air quality standards (GN1210 of 2009) were determined based on international best practice for PM10 (particulates with an aerodynamic diameter of 10 micron), dust-fall, sulphur dioxide (SO2), nitrogen dioxide (NO2), ozone (O3), carbon monoxide (CO), lead (Pb), benzene and recently PM2.5. The PM2.5 standards were published in GN486 of 2012. Section 32 of NEMAQA allows for the promulgation of measures to control and monitor dust. The National Dust Control Regulations (GNR827 of 2013) prescribe general measures for the control of dust in all areas, including residential and light commercial areas. The purpose of the National Environmental Management: Biodiversity Although TIH falls within the greater Kathu Act, No. 10 of 2004 (NEMBA) is to provide for the management and Bushveld footprint, (an ecosystem which is listed conservation of South Africa’s biodiversity within the framework of the as Least Threatened), the extent of this NEMA. This includes, among others, the protection of species and ecosystem on-site has been completely ecosystems. transformed due to historic mining activities. Section 52 of the Act provides for listing of threatened or protected The PRA is not situated in close proximity to well ecosystems, in one of four categories: Critically Endangered (CR), protected areas or areas earmarked for protected Endangered (EN), Vulnerable (VU) or Protected. The main purpose of listing area expansion. threatened ecosystems is to reduce the rate of ecosystem and species Species of conservation concern which are extinction and includes the prevention of further degradation and loss of Refer to Section 5(a) where typically associated with the Kathu Bushveld structure, function and composition of threatened ecosystems. Threatened the current biodiversity in ecosystem are the Camel Thorn, Shepherds Tree, terrestrial ecosystems have been delineated based on the South African the project area is Ground Pangolin, African Wild Cat, Tawny Eagle, Vegetation Map, national forest types and priority areas identified in a characterised. Secretary Bird, Rock Monitor, Giant Bullfrog, provincial systematic biodiversity plan. Horned Baboon Spider and the Starburst Baboon Chapter 4, Part 2 of the Act provides for listing of species as threatened or Spider, however habitat for these species within protected. If a species is listed as threatened, it should be further classified the project site are limited due to the disturbed as critically endangered, endangered or vulnerable (GNR151 of 2007). The nature thereof. Permits may be required in terms Act also defines restricted activities in relation to a specimen of a listed of NEMBA in the unlikely event that species of threatened or protected species (GNR152 of 2007). conservation concern have habituated within the mining footprint at any desired drilling location. Potential drilling sites (if necessary) will, however, target already disturbed areas.

The Northern Cape Nature Conservation Act (No. 9 of 2009) (NCNCA) Refer to commitments in the Should it arise that invasive drilling is required, came into effect on the 1st of January 2012. The Northern Cape Department EMP (Section 4 - Part B of the ECO will survey any areas where clearance is of Environment and Nature Conservation are responsible for the this document) required to confirm that indigenous or protected species are absent (likely considering the

HOW DOES THIS DEVELOPMENT COMPLY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT implementation of the NCNCA. transformed nature of the site). If identified nonetheless, the precise location and spatial The NCNCA provides measures for the sustainable utilisation of wild animals layout of the drill site in question will be evaluated (including the restriction of activities involving protected animals and to seek to avoid the physical disturbance or limit hunting), controlling activities involving aquatic biota, providing for the it to the greatest degree possible. If not sustainable use of plants, control of invasive species, prohibiting acts avoidable, the necessary permits will then be involving endangered wild fauna and flora and providing the powers and sought from the Northern Cape Department of functions of nature conservations in the Province. Environment and Nature Conservation accordingly Further to the above, and of specific relevance to this project, no person for the removal / relocation of any such species. may pick or otherwise remove an indigenous plant subsequent to the It must however be noted that due to the provisions of Section 51 without a permit (common indigenous species are disturbed state of the property in question, listed in Schedule III to the Act). Furthermore, Section 49 restricts activities the presence of indigenous and protected pertaining to the specially protected species listed in Schedule I to the Act species is unlikely / highly limited without a permit.

The National Forests Act (No. 84 of 1998) is enabling legislation The species Vachellia (acacia) erioloba and Boscia providing for sustainable forest use and management and provides special albitrunca may be present in the Kathu Bushveld measures to protect trees and forests by prohibiting the destruction of ecosystem. These species are listed as Schedule A natural forests, protecting areas and individual tree species and further species in GNR 690 of 2017. A licence is thus providing measures to control and remedy deforestation. The Department required to disturb or move these species. As per of Agriculture, Fisheries and Forestry (DAFF) are the custodians of the Chapter 5, Section 16 of GNR 466 of 2009, a National Forests Act. The list of protected tree species is contained in licence must be sought from the DAFF before any Regulation GNR690 of 2017 to the Act. declared protected tree species may be removed. It is noted, however, that the ecosystem on The Act applies to the aspects proposed project pertaining to land clearance site has been completely transformed due to in that that no person may cut, disturb, damage or destroy any protected Refer to commitments in the historic mining activities and the occurrence tree or possess, collect, remove, transport, export, purchase, sell, donate or EMP (Section 4 - Part B of hereof on-site is highly unlikely. Nonetheless in any other manner acquire or dispose of any protected tree or any forest this document) should invasive drilling require any areas to be product derived from a protected tree, except under a licence or exemption cleared, such areas will be surveyed by the ECO granted by the Minister to an applicant and subject to such period and prior to drilling to determine whether any conditions as may be stipulated. protected tree species are affected. If present, the precise location and spatial layout of the drill site in question will be evaluated to seek to avoid the removal of the tree species to the greatest degree possible. The necessary licence will then be sought from the DAFF only if avoidance is not possible. This is considered highly unlikely. The National Environmental Management Waste Act, No. 59 of 2008 N/A No listed activities in terms of the NEMWA are

HOW DOES THIS DEVELOPMENT COMPLY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT (NEMWA) serves to reform the laws regulating waste management in order triggered by the proposed project. Therefore, no to protect public and environmental health by providing measures for the Waste Management Licence (WML) is required. prevention of pollution and ecological degradation and to provide defining Activities associated with the proposed project are requirements for the licensing and control of waste management activities. unlikely to result in exceedances in the thresholds GN921 of 2013 provides definitions for activities which require a waste for waste storage. management licence and identifies the relevant environmental authorisations which are further required for said activities. It is however noted that any minimal waste produced on site should be transferred to the The storage of waste above the specific thresholds (in excess of 100 m3 of nearest licenced waste disposal facility. general waste or 80 m3 of hazardous waste) triggers a Category C activity which requires registration in terms of- and compliance with the National Norms and Standards for the Storage of Waste (GN926 of 2013). The National Heritage Resources Act, No. 25 of 1999 (NHRA) serves to protect and manage South African heritage and cultural resources, which include places, buildings, structures and equipment of cultural significance, historical settlements and townscapes, archaeological and paleontological sites, graves and burial grounds. The Act protects any heritage resources from damage by developments by stipulating in Section 38 that any person intending on undertaking any form of development which involves the activities listed below must, at the earliest stage of initiation, notify the South African Heritage Resources Association (SAHRA) specifically the Northern Cape Heritage Resources Authority: A. the construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or barrier exceeding 300 m in Refer to Section 5(a) where None of the listed activities in terms of the NHRA length; the current heritage are triggered by the proposed project as the B. the construction of a bridge or similar structure exceeding 50 m in landscape in the project area prospecting activities will not transform the length; is characterised. character of the already disturbed site. C. any development or other activity which will change the character of a site— i. exceeding 5 000 m2 in extent; or ii. involving three or more existing erven or subdivisions thereof; or iii. involving three or more erven or divisions thereof which have been consolidated within the past five years; or iv. the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority;

HOW DOES THIS DEVELOPMENT COMPLY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT D. the re-zoning of a site exceeding 10 000 m2 in extent; or E. Any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority. The National Water Act, No. 36 of 1998 (NWA) regulates all matters There are no watercourses or wetlands within the relating to inland water resources. It thus operates as a management Refer to Section 5(a) where PRA, however there may be some depressions or instrument with the lead authority being the Department of Water and the current water resources water within old excavations on site. Sanitation (DWS). This Act provides mechanisms for the prevention of the in the project area are pollution of water resources to support the management of water as a characterised. None of the potential infill boreholes that may be renewable resource. Section 21 of the Act lists water uses for which developed will be in proximity to a watercourse or authorisation is required from the DWS. It has been included as a wetland, thus no listed activities in terms of the commitment in the EMP NWA are triggered by the proposed project. Regulation GN704 of 1999 provides regulations for the use of water for (Section 4 - Part B of this mining and related activities and is aimed to further protect water document) that no Drilling water will be obtained from the resources. These regulations describe how mining activities should be prospecting activities must municipality in the town of Hotazel. No abstraction managed to protect water resources. The Act thus plays a crucial role in the take place within 500 m of a boreholes will be drilled to avoid triggering a mining process as many mining-related activities use water as listed in wetland. water use. Section 21, thereby requiring approval from DWS. The Mine Health and Safety Act, No. 29 of 1996 (MHSA) and the Regulations thereto provide for protection of the health and safety of staff and other persons at mines and, for that purpose to promote a culture of health and safety; to provide for the enforcement of health and safety measures; to provide for appropriate systems of employee, employer and A commitment to abide by State participation in health and safety matters; to establish representative the Act and Regulations has The Applicant will ensure that operations are in tripartite institutions to review legislation, promote health and enhance been included in the EMP line with the requirements of the Act and properly targeted research; to provide for effective monitoring systems and (Section 4 - Part B of this Regulations. inspections, investigations and inquiries to improve health and safety; to document). promote training and human resources development; to regulate employers' and staff' duties to identify hazards and eliminate, control and minimise the risk to health and safety; to entrench the right to refuse to work in dangerous conditions; and to give effect to the public international law obligations of the Republic relating to mining health and safety. The Integrated Development Plan (IDP) of the Joe Morolong Local Refer to the social baseline Municipality (2017/2018) provides the regional socio-economic context in Section 5(a). This has also of the project area. The IDP states that the Joe Morolong Local Municipality been taken into The IDP has been taken into account in has a total surface area of 20 172 km2 that accommodates a population of consideration in determining determining the need and desirability of the 89 377 (as per Census 2011). There are 146 villages and 2 small towns in of the need and desirability project. the district surrounded by privately owned commercial farms and of the project, refer to government farms. There are Tribal authorities in the municipal jurisdiction Section 3(d).

HOW DOES THIS DEVELOPMENT COMPLY WITH AND APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED RESPOND TO THE LEGISLATION AND POLICY CONTEXT with 8 Paramount Chiefs. The IDP includes Key Performance Areas (KPAs) for the wards and for the municipality which cover 1) Basic Service Delivery, 2) Local Economic Development (LED), 3) Municipal Transformation and Organizational Development, 4) Municipal Finances and Financial Viability, and 5) Good Governance and Community participation. Ward specific KPAs focus on KPA 1 and 2; municipal KPAS include KPAs 3, 4 and 5. Agriculture, mining and community services are the primary economic sectors. Most of the municipal service projects implemented within the area in the past two years were funded through government grants and Social Labour Plan (SLP) money from the mining houses. There are 12 740 economically active people in the municipality (employed or unemployed but seeking work). Poverty alleviation projects in the past two years were implemented in 15 villages, employing 224 people. Groundwater is a major source of water and factors affecting the quality include agricultural activities and environmental issues. The municipality embarked on refurbishing the current water infrastructure. The project is not yet finalized. There are 11423 households that are below the RDP standard for sanitation. Approximately 95% of the roads in the municipality are gravel roads, funding for road construction used to be sourced from SLP projects, however the IDP states that due to unfavourable economic conditions in the mining sector, no allocation will be received from the mines for road construction for the 2017-18 Financial Year. The Northern Cape Provincial Spatial Development Framework From the PSDF Composite Spatial Vision, the TIH (PSDF) (2012) provides the framework for building a prosperous, PRA falls within an area classified as the sustainable growing provincial economy to eradicate poverty and improve Gamagara corridor, a mining belt focussing on the social development. The TIH PRA falls within the Joe Morolong Local This has been taken into mining of manganese and iron. Municipality and the Magisterial District of John Taolo Gaetsewe. Kuruman is consideration in determining Based on GIS data on land use and land cover the the administrative capital of the John Taolo Gaetsewe District Municipality the need and desirability of proposed site is mining or mining related and this area is referred to as the Kalahari ‘macro-region’. The Gamagara the project, refer Section infrastructure including mines and mining corridor comprises the mining belt of the John Taolo Gaetsewe and Siyanda 3(d). buildings over majority of the land. Other pockets districts and runs from Lime Acres and Danielskuil to Hotazel in the north. comprise of bare non-vegetated land, grassland, The corridor focuses on the mining of iron ore and manganese. low shrubland and thickets/bush

d) Need and desirability of the proposed activities (motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location)

Need

 The prospecting activities being applied for are required in order to investigate the presence of suitable mineralisation and, if so, whether this mineralisation can be economically and feasibly mined in future which, in turn, presents various socio-economic benefits to the region.

Desirability

 Previous open cast mining of the PRA have successfully abstracted the desired minerals of manganese and iron. There are also confirmed remnant pillars that were left behind during previous mining activities. Previously drilled boreholes indicate that there is a mix of high grade ore and lower grades.

 From the PSDF, the TIH PRA falls within an area defined as the Gamagara Corridor, an area comprising the mining belt of the John Taolo Gaetsewe and the Siyanda districts. It runs from Lime Acres and Danielskuil to Hotazel in the north and focuses on the mining of iron and manganese. According to the industrial areas spatial vision, the site is located within industrial areas and in close proximity to mining focus areas

 Access to the area is good, consisting of paved main roads and secondary gravel roads.

 The site boundaries are within previously disturbed (mined) land and do not overly and are not within close proximity to any sensitive environmental features, therefore, limiting the potential for negative environmental impacts.

 Although the site is within close proximity to communities and residences the historical use of the land may negate the need to drill boreholes therefore, limiting the potential for negative social impacts.

 Should prospecting activities indicate that mining in the area is feasible it will contribute in alleviating unemployment in the area. Poverty alleviation in the area is needed as the official unemployment rate of the District Municipality is 29.7%, and the youth unemployment rate is 37.2%.

 Potential future mining activities would further allow for the proper and beneficial rehabilitation of areas previously affected by mining activities which have not been rehabilitated to reflect the surrounding land-use or a suitable alternative. e) Motivation for the overall preferred site, activities and technology alternative

The site has been selected for its potential geological features in terms of mineralisation based on extensive historical data for the area. No alternative site locations were therefore assessed. The

proposed location is an already disturbed, historically mined area and the site selection is based on the expected mineral resources located within that area.

The entire site and any potential further boreholes that may be drilled are not in proximity to any sensitive environmental features, therefore, limiting the potential negative environmental impacts.

It is furthermore noted that the requirements for additional invasive prospecting activities within the identified site will be limited due to the extent of pre-existing mineralogical data obtained during previous exploration and mining activities.

f) Full description of the process followed to reach the proposed preferred alternatives within the site (NB!! – this section is about the determination of the specific site layout and the location of infrastructure and activities on site, having taken into consideration the issues raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout) i) Details of the development footprint alternatives considered (with reference to the site plan provided and the location of the individual activities on site, provide details of the alternatives considered with respect to: (a) the property on which or location where it is proposed to undertake the activity; (b) the type of activity to be undertaken; (c) the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity)

 The site has been selected for its potential geological features in terms of mineralisation.  The type of activity is limited based on the geology but this activity is in line with the development plans and is the historic land use of the site.  This BAR takes into consideration the full extent of the PRA as the layout at present has not identified the need for -and position of- additional exploration boreholes. The non-invasive prospecting (desktop studies, geophysical surveys and verification and validation of historic data) will identify additional or alternative candidate drill sites.  The technology involved in prospecting is limited to tried and tested drilling techniques being percussion and diamond drilling. Other techniques (such as trenching for example) are not suitable for the minerals being prospected for.  Prospecting site alternatives are limited to the location of the mineral resources. Therefore, the sites of the proposed drill holes will be based on the potential for economically feasible minerals to be present in these areas. However, alternative drilling sites may be determined once the desktop studies and geophysical surveys have been completed.  There are no alternatives to the type of activity (prospecting activities) as prospecting is required to characterise the mineral resources in the area. 18

 If the project does not go ahead, the area is likely to remain in its present state of historically degraded land. Alternative development may be possible, but the Applicant is unaware of any such proposals at present.

4. Details of the Public Participation Process followed (describe the process undertaken to consult interested and affected parties including public meetings and one on one consultation. NB the affected parties must be specifically consulted regardless of whether or not they attended public meetings. (Information to be provided to affected parties must include sufficient detail of the intended operation to enable them to assess what impact the activities will have on them or on the use of their land)

Initial public participation was undertaken from 29 May 2018 to 28 June 2018, during which the following activities were undertaken:

Landowner Notices

The current landowner of the farm portions subject to the Prospecting Rights Application (South 32 – Hotazel Manganese Mines) were provided with written notification of the project on 30 May 2018 (refer to Appendix 2.1).

Public Notification

Public notices (attached as Appendix 2.2) were placed in three highly visible locations namely; Hotazel Library, OK Hotazel and KLK Hotazel, refer to Figure 2. The notices provided indicated that TIH had submitted an application for a Prospecting Right to the DMR, the location of the project, legislative context, and gave details whereby Interested and Affected (IAPs) could indicate their interest in the project, register on the IAP database or otherwise request additional information and provide comment. The timeframe of the commenting period (30 days from 29 May to 28 June 2018) was also indicated.

Media Notice

A media notice (in English) containing the same information as the site notices was published in the Kathu Gazette on 2 June 2018 (attached as Appendix 2.3).

Background Information and Notification Letters

Notification letters (attached as Appendix 2.4) were sent out to the identified State Departments and Stakeholders (including the Dept. of Agriculture (Kimberley), the Dept. of Agriculture and Rural Development (Kuruman), the Dept. of Environmental Affairs (Kimberley), the Dept. of Rural Development and Land Reform (Kimberley), the Dept. of Water and Sanitation (Kimberley), the Dept. of Mineral Resources (Kimberley), the Dept. of Public Works (Kimberley), Land Claims, SAHRA (Cape Town), SANRAL (Bellville), Eskom (Kimberley), South 32 (Hotazel), Transnet (Bloemfontein), Transnet (Hotazel), the John Taolo Gaetsewe District Municipality (Kuruman), KLK Landbou BPK (Hotazel), Kudumane Manganese Resources and Agri Kuruman). These letters indicated that THI had submitted an application for a Prospecting Right to the DMR, the activities proposed, the location of the project, the legislative context

and the request to submit comment within the specified timeframe (30 days, concluding on the 28 June 2018). IAP Registration

A database was prepared and maintained for the duration of the initial public commenting period which included representatives from all of the relevant State Departments, other Stakeholders, landowners and any IAPs requesting to register in response to the above or who otherwise provided comment. Any person responding to any of the abovementioned notifications was added to the IAP database. (attached as Appendix 2.5). All comments received and responses thereto or other representations made were also recorded.

Follow-up public consultation will now be undertaken which will entail providing all registered IAPs, stakeholders and State Department representatives with a copy of this BAR and EMP for review and comment. Any additional IAPs, State Department representatives or other stakeholders identified who were not previously consulted with will also be added to the IAP database and provided with the BAR / EMP for comment.

Commenting Period

The BAR / EMP will be provided in the requested format (digitally or hard copy, as requested) as well as on the Prime Resources website (www.resources.co.za), for a period of 30 days (16 July 2018 to 15 August 2018).

Comments and Response Report

A Comments and Response Report has been compiled which reflects the outcomes of the total public participation process - refer to the table in Section i below. Copies of all comments received, responses thereto and any other representations during public participation are included in this table. This comments and responses report will be further updated following the forthcoming 30-day public consultation period.

Figure 2: Locality of the public notices placed in the town of Hotazel, in close proximity to the site

i) Summary of issues raised by IAPS (complete the table summarising comments and issues raised, and reaction to those responses)

INTERESTED AND AFFECTED PARTIES SECTION AND

PARAGRAPH REFERENCE LIST THE NAMES OF PERSONS DATE EAPS RESPONSE TO ISSUES AS IN THIS REPORT WHERE CONSULTED IN THIS COLUMN, AND COMMENTS ISSUES RAISED MANDATED BY THE APPLICANT THE ISSUES AND OR MARK WITH AN X WHERE THOSE WHO RECEIVED RESPONSE WERE MUST BE CONSULTED WERE IN FACT INCORPORATED CONSULTED AFFECTED PARTIES Landowner/s This BAR / EMP is provided to the landowner for Request for Prospecting Work X Notified via comment for a period of 30- Programme, the EA application or granted Meeting held with South 32/HMM on Mr Alex Mooya general letter sent to E-mail response days as requested. EA, mitigation/proposed measures on 25 May 2018 (Minutes of meeting South 32 Dated: 19/06/2018 taking over environmental liability, financial attached as Appendix 2.6) May 30 2018 Quantum for rehabilitation- guarantees related financial provision – see Section 5 X Notified via general letter sent to Meeting held with South 32/HMM on Mr Dennis Chinasamy South 32 Dated: 25 May 2018 May 30 2018 X Notified via general letter sent to Meeting held with South 32/HMM on Ms Sylvia Makoele South 32 Dated: 25 May 2018 May 30 2018 Lawful occupier/s of the land – South 32 / Hotazel Manganese Mines – see above Landowners or lawful occupiers on adjacent properties Public notices were posted in the town of Hotazel (in close X Public notices and An IAP database was maintained during public participation and comments from the community are included in this report under the proximity to the site) at media notices “Interested Parties” section KLK Hotazel, Hotazel Library and OK Hotazel. This BAR / EMP is provided to the adjacent landowner for Mr Jacobus Pretorius comment for a period of 30- days as requested.

INTERESTED AND AFFECTED PARTIES SECTION AND

X Notified vial letter Dated: May 30 2018 Mr Klaas Teise This BAR / EMP is (Director: Planning provided to the and Development, Joe No comments received Local Municipality Morolong Local for comment for a Municipality) period of 30-days as requested.

Organs of state (Responsible for infrastructure that may be affected Roads Department, Eskom, Telkom, DWA Email Response Requested a site layout plan for proposed X Notified via Figure 1 of this report 14/06/2018 from project highlighting the location of the Site layout provided by TIH as SANRAL (Bellville) general letter provides details of site Ms Nicole proposed project and the nearest national requested on 26/06/2018 Dated: May 30 2018 location and national roads. Abrahams road Mr Frank Olyn X Notified via letter (Operations Manager No comments received Dated: May 30 2018 Transnet - Hotazel) X Notified via Transnet - general letter No comments received Bloemfontein Dated: May 30 2018 Notification that 8 Overhead Lines and 1 Letter dated Substation traverse the proposed mining Conditions as required must be X Notified via 11/06/2018 area, No objections provided that Eskoms accepted, signed and returned to Eskom (Kimberley) general letter received via rights and services are acknowledged and N/A Eskom before undertaking activities Dated: May 30 2018 email from Mr respected. Conditions of letter must be on-site Khahliso Makale accepted in writing before development or construction Communities Media notice X Media notices IAPs were invited to register and send comments via email, fax, telephonically or post. Comments received from IAPs are included in

INTERESTED AND AFFECTED PARTIES SECTION AND

PARAGRAPH REFERENCE LIST THE NAMES OF PERSONS DATE EAPS RESPONSE TO ISSUES AS IN THIS REPORT WHERE CONSULTED IN THIS COLUMN, AND COMMENTS ISSUES RAISED MANDATED BY THE APPLICANT THE ISSUES AND OR MARK WITH AN X WHERE THOSE WHO RECEIVED RESPONSE WERE MUST BE CONSULTED WERE IN FACT INCORPORATED CONSULTED Management) E-mail response X Notified via Further locality maps Dept of Public Works 11/06/2018 from TIH provided locality map by email general letter request for map details indicated in Figure 1 in this (Kimberley) Ms Faizal dated 25 June 2018. Dated: May 30 2018 report. Paulsen X Notified via SAHRA (Cape Town) general letter No comments received Dated: May 30 2018 OTHER AFFECTED PARTIES IAP duly registered and will be provided with this BAR / EMP for review and comment. Measures to manage potential impacts regarding Request to register as an IAP and to The proposed non-invasive soil / groundwater receive all info in the matter and locality techniques will not cause contamination, dust and map. Mr GJ Hoon disturbances to the environment. If noise are dealt with in the Letter dated Concerns: Groundwater yield and (Chairman of Agri invasive exploratory boreholes are to following Sections 6 and 7 of 26/06/2018 susceptibility to contamination, dust and Kuruman) be drilled, no groundwater the BAR and Section 4 of the noise generation through prospecting abstraction will occur, nor is noise EMP activities, sufficient and acceptable above prescribed levels to be mitigation of agricultural land, rehabilitation exceeded. Measures are in place to Aspects of rehabilitation are prevent contamination of soils and to dealt with in Section 6. deal with dust. The PAR is not within agricultural land use areas. Mr Danie Botes (KLK Notified via letter Landbou BPK - Dated: 4 June 2018 Hotazel) Ms Tshifhiwa Letter dated Query 30 day response period dates, Nemakhavhani 7/06/2018 IAP duly registered and will be Notified via letter register as a IAP, request all Kudumane received from provided with this BAR / EMP for Dated: 4 June 2018 documentation and information relating to Manganese Ms Nomadlozi review and comment. PRA Resources Mashinini INTERESTED PARTIES

5. The environmental attributes associated with the alternatives (the environmental attributes described must include socio-economic, social, heritage, cultural, geographical, physical and biological aspects)

The description below is applicable to the entire PRA and therefore applicable to all potential exploration drill hole sites and any alternative sites which may be identified in future. a) Baseline environment i) Air Quality In accordance with Section 15(2) of the NEM:AQA, the Northern Cape Department of Environment and Nature Conservation developed an Air Quality Management Plan (AQMP). The following information was obtained from the AQMP for the Northern Cape: Air Quality Baseline Assessment Report developed by uMoya-NILU (Final, December 2017).

The Northern Cape is generally hot and dry. Maximum summer temperatures often exceed 40°C. During winter, the average daytime temperatures are mild and night time temperatures may drop below 0°C. There are four climatic zones in the Northern Cape: hot desert, cold semi-arid, cold desert and hot semi- arid. Hotazel (the closest town to the project area) is classed as a cold semi-arid area. Rainfall data from the South African Weather Stations (SAWS), Winton and Milner Stations, indicate an MAR between 330 mm and 361 mm. Due to the semi-arid nature of the area evaporation levels exceed annual rainfall. Wind direction near Hotazel is predominantly from the north east.

The main sources of air pollution in the Northern Cape are biomass burning and mining, followed by industry and motor vehicles. Biomass burning is a major contributor of carbon monoxide (CO) whereas mining contributes particulate matter (PM10, PM2.5) and total suspended particles (TSP). Long range atmospheric transport of air pollutants from the industrialised Highveld and biomass burning in southern and central Africa may influence ambient air quality over parts of the Northern Cape. Emissions within the Northern Cape in 2015 are summarised in Table 1.

Table 1: Estimated emissions (tons/annum) during 2015 in the Northern Cape (uMoya-NILU, 2017)

PM10 PM2.5 TSP SO2 NOX CO VOC Industrial sources 1452 133 289 333 79 24 Mining 32248 22315 61453 Residential fuels 42 2 6 315 Biomass burning 15978 695 3917 115525 Motor vehicles 517 253 6574 15433 3067 Airports 3 11 9988 158 Total 34259 22315 77564 1242 10841 141340 3249

Site-specific air quality and emissions data is not available for the TIH PRA area or the town of Hotazel, however, baseline conditions are expected to be reflective of those experienced at the provincial level due to similar sources, drivers and landscapes.

ii) Palaeontology, Heritage and Geology The following information was obtained from

 J. Almond and John Pether (2009). Palaeontological Heritage of the Northern Cape, SAHRA Palaeotechnical Report  J van Schalkwyk (2010). Heritage impact assessment for the Proposed Gravenhage Manganese Project, John Taolo Gaetsewe District Municipality, Northern Cape Province

There are no UNESCO World Heritage Sites in the vicinity of the project area. The SAHRIS Palaeontology (fossil) sensitivity map was used in determining the requirements for the level of study required for the region (refer to Figure 3). The map indicates that the area is of moderate sensitivity and therefore only a desktop study is required.

The climatic conditions (semi-arid to arid) of the Northern Cape are ideal for the exposure of fresh, unweathered rocks at surface and fossils related to them. The Northern Cape spans a wide range of geology.

On a regional scale, the project area is located on the relatively young Kalahari Group. Rock types of the Kalahari include fluvial gravels, sands, lacustrine and pan mudrocks, evaporites, aeolian sands, pedocretes. Due to the arid conditions, which began approximately 15 million years ago (Miocene Epoch), the region only has sparse fossilised areas and these areas are usually ancient pans, lakes and river systems. Late Cretaceous to Paleogene fluvial and lacustrine sediments towards the base of the succession contain such fossils, but these fossils are rarely exposed. Arid-adapted fossils include land snails, ostrich eggs, plant root casts as well as pockets of lake sediments with molluscs, diatoms and freshwater stromatolites. The palaeontological significance of the Kalahari Group is low, in terms of a recommended action for projects in the region, the SAHRA Palaeotechnical Report recommends that no action is required, however any fossil finds should be reported.

Locally, within the bounds of the PRA, only the Hotazel Formation and overlying Kalahari Group Sediments are preserved, with all three manganese units (UB, Middle Body and LB) present; refer geological map in Figure 4. The PRA is unique in that both ore types of the Kalahari Manganese field (i.e. Wessels Type and Mamatwan Type) appear to be present. There are also numerous fractures and potential faults which have allowed for deleterious ferruginization (replacement of manganese by iron).

From a cultural perspective, occupation of the region took place during the Early Stone Age and centres in the areas where there are hills, e.g. to the east and south (in the vicinity of Kathu). Later Stone Age sites are less obvious but occur in the larger region, with Cape Coastal pottery in the period 100 BC to AD 1900.

Tswana-speaking people were the earliest that settled in the region to the north and west of Kuruman. With the annexation of the Tswana areas by the British in 1885, a number of reserves were set up for people to stay in. In 1895 the Tswana-speakers rose up in resistance to the British authority as

represented by the government of the Cape Colony, their land was taken away, divided up into farms and given out to white farmers to settle on.

Early explorers, hunters, traders and missionaries travelled through the area on their way to Kuruman on what became known as “Missionary Road”.

The cultural and archaeological significance and importance of the TIH PRA area itself is, however, considered negligible due to the existing transformed nature of the area and extent of disturbance due to past mining practises which would have either unearthed or destroyed any potential significant artefacts. In addition, no individual graves or graveyards are located within the PRA area.

Figure 3: Palaeosensitivity map (SAHRIS, 2017)

Figure 4: Geological map

iii) Noise The TIH PRA area is located in close proximity to the town of Hotazel. The typical noise rating in the area is expected to be that for rural districts / suburban districts with little road traffic. According to SANS 10103:2008, the continuous noise rating level is thus likely between 35 dB(A) at night to 45 /50 dB(A) during the day. iv) Surface Water The following information was obtained from:

 Water Research Commission. The South African Mine Water Atlas (WRC Project No. K5/2234/3)  Department of Water and Sanitation. 2014. A Desktop Assessment of the Present Ecological State, Ecological Importance and Ecological Sensitivity (PESEIS) per Sub Quaternary Reaches for Secondary Catchments in South Africa  MS Basson and JD Rossouw, 2003. Lower Vaal Water Management Area: Overview of Water Resources Availability and Utilisation.  The online DWS Resource Quality Information Services (RQIS) (http://www.dwa.gov.za/iwqs/)

Catchment Description and Surface Water Resources

The project area is located in quaternary catchment D41K, within the Lower Vaal River Water Management Area (WMA) (refer to Figure 5) and Drainage Basin D (Orange River basin). The Lower Vaal WMA is located downstream of the Bloemhof Dam and upstream of Douglas Weir. It extends to the headwaters of the Harts, Molopo and Kuruman River in the north and the Vaal River Downstream of Bloemhof in the south. The Lower Vaal WMA covers a catchment area of 51,543 km2.

The Lower Vaal WMA can be subdivided into three sub-catchments; Harts, Vaal downstream of Bloemhof and Molopo. The D41K quaternary catchment is located within the Molopo sub-area. Due to the low rainfall, flat topography and sandy soils over much of the WMA, little usable surface runoff is generated in the water management area. The runoff is highly variable and intermittent. Although occasional runoff occurs in the upper reaches of the Molopo River, no record exists of flow having reached the Orange River (according to the Overview of Water Resources Availability and Utilisation, 2003). The estimated runoff for the Molopo sub area is 197 million m3/a.

As displayed in Figure 5, the PRA does not contain rivers within its boundaries, and is located approximately 5 km away from the nearest river course, i.e. Ga-Mogara River (Gamagara elsewhere). Within the quaternary catchment, the Witleegte, Ga-Mogara and Vlermuisleegte Rivers are present, these are however at a distance greater than 5km from the site boundaries. (See also Figure 11)

Figure 5: Water Management Area (WMA) and quaternary catchment map

v) Groundwater The following information was obtained from

 Water Research Commission. The South African Mine Water Atlas (WRC Project No. K5/2234/3)  Development of Internal Strategic Perspectives (ISP): Groundwater Overview for the Lower Vaal Catchment Management Area (prepared for Directorate Water Resource Planning, 2003)  Internal Strategic Perspectives (ISP) for the Lower Vaal Management Area (WMA No 10, 2004)  The online DWS Resource Quality Information Services (RQIS) (http://www.dwa.gov.za/iwqs/)  MS Basson and JD Rossouw, 2003. Lower Vaal Water Management Area: Overview of Water Resources Availability and Utilisation.

Aquifer systems

In general, there are 4 major aquifer systems in the Vaal WMA:

 Karst aquifers with borehole yields >5.0 l/s, supporting fresh dolomite springs  Intergranular and fractured aquifers with boreholes yields between 0.1 and 2.0 l/s  Fractured aquifers with borehole yields between 0.1 and 2.0 l/s, highly variable water quality  Intergranular/ alluvial aquifers with borehole yields between 0.1 and 2.0 l/s, multi layered aquifer systems (fresh upper aquifers, underlain by brackish to hyper saline groundwater).

Most of the groundwater abstraction that takes place in the Molopo sub-area (which includes the D41K catchment) is in the vicinity of dry sandy riverbeds. A substantial part of the recharge of groundwater is also assumed to be from these watercourses.

To the east of the project area, in quaternary catchment D41L, an extensive dolomitic aquifer is hosted in the Ghaap Plateau dolomites.

Groundwater Use in the Region

The ISP categorises the supply of water to the town of Hotazel as coming from both groundwater sources and from the Vaal-Gamagara pipeline. As the 2011 Census, 15.6% of households in the local municipality rely on borehole water.

Groundwater Quality

There is a large amount of groundwater data available for the Lower Vaal WMA. There are over 13000 borehole locations in Region D that have data available via the DWS Resource Quality Information Services (RQIS). Only one borehole is located within the project area that is included in the database as shown in Figure 6.

Poorer groundwater is a natural feature of the western portion of the Lower Vaal WMA within the Kalahari group primary (sand/gravel) aquifers and clay formations, where relatively high nitrite concentrations may occur due to agricultural activities in the region. 33

Figure 6: Boreholes with available data in the National Groundwater Database

vi) Socio Economic The following information was obtained from the 2017/2018 Integrated Development Plan of the Joe Morolong Local Municipality (adopted by the Council on 30 March 2017) as well Census 2011 data and Community Survey 2016 data, provided by Statistics South Africa (Stats SA).

Provincial context

The Northern Cape is the largest of the South African provinces, covering an area of 372 889 km2. The province is also the least populous of the country’s provinces, with a total population of only 1 193 780 (Community Survey 2016). Only 2.1% of the country’s total households reside in the Northern Cape.

The capital city of the province is Kimberley. Other important towns include Upington, Springbok, Kuruman and De Aar.

Mining and agriculture are the primary economic sectors of the province. There are alluvial diamonds, iron ore, copper, asbestos, manganese, fluorspar, semi-precious stones and marble resources which have been mined in the region.

The province has fertile agricultural land in the Orange River Valley where grapes and fruit are cultivated intensively. Sheep farming takes place in the interior Karoo. Wheat, fruit, peanuts, maize and cotton are also produced at the Vaalharts Irrigation Scheme near Warrenton.

The Northern Cape is subdivided into five district municipalities: Francis Baard, John Taolo Gaetsewe, Namakwa, Pixley Ka Seme and ZF Mgcawu. The PRA is located in the John Taolo Gaetsewe District Municipality.

Regional context

The John Taolo Gaetsewe District Municipality (previously Kgalagadi) is located to the north east of the province and borders Botswana. It is comprised of three local municipalities: Gamagara, Ga-Segonyana and Joe Morolong. Joe Morolong is the largest of these municipalities in terms of area.

There are 186 towns and settlements, of which the majority (approximately 80%) are villages.

The District has an established rail network from Sishen South and between Black Rock and Dibeng. It is characterised by a mixture of land uses, of which agriculture and mining are dominant.

The population of the District Municipality was 242 264 (Community Survey 2016), of which 63.3% were aged between 15 and 64 years and 31.9% of the population was under the age of 15. The official unemployment rate of the District Municipality is 29.7%, while the youth unemployment rate is 37.2%.

Local context

The prospecting area is situated within the Joe Morolong Local Municipality (JMLM), Ward 4.

JMLM is mostly rural, with virgin land surface comprising about 60% of the surface. Agriculture, mining and community services are the primary economic sectors. JMLM has three main nodes where relatively higher economic activity takes place, namely Vanzylsrus, Hotazel and Blackrock. Mining is the predominant economic activity in Hotazel and Blackrock. Vanzylsrus operates as service centre for the surrounding area.

According to 2011 Census data, there are 12 740 people that are economically active (employed or unemployed but looking for work), and of these, 38.6% are unemployed. Of the 6 323 economically active youth (15–34 years) in the area, 49.5% are unemployed.

According to the 2011 Census, JMLM has a total population of 89 530 people. The majority of the population in the municipality are black African (96.4%), 2.0% are coloured, with the other population groups making up the remaining 1.6%.

Setswana is the most prevalent language spoken in the community with 90.1% of people listing it as their first language. Afrikaans and English are the first languages of 3.6% and 1.9% of the population respectively.

Of the population aged 20 years and older, 5.2% have completed primary school, 27.8% have some secondary education, 13.4% have completed matric, 4.1% have some form of higher education and 22.9% have no form of schooling.

There are 168 schools, 4 police stations, 24 clinics and 3 community health centres located in JMLM. There is no hospital in JMLM. According to the IDP, there are 23 707 households with a population growth of - 0.9%. The average household size is 3.4 persons per household.

JMLM does not own any land in their jurisdiction. Most of the land either belongs to the state or falls under the jurisdiction of the Tribal leaders.

AS per the IDP, JMLM itself is not responsible for the implementation of electrification projects. The Municipality acts as a project coordinator for projects implemented by ESKOM and Department of Energy. Within JMLM, 81.8% of households have access electricity and use it for lighting while 16.1% still use candles for lighting. Wood is used for heating in 51.2% and for cooking in 39.3% of households.

Currently, most of the communities within JMLM receive water for free. Of all households, only 6.6% have access to piped water either in their dwelling or in the yard. As per the 2011 Census, 71.7% sourced water from a water services provider (municipality or other), 15.6% used borehole water and 5.8% received water via a water truck. Vanzylsrus and Hotazel are the only areas that have water borne system in JMLM. According to the IDP, there are 24 villages that are without access to piped water. They receive water by means of truck delivery or through a windmill equipped with a tap. The IDP identified the following as challenges to the provision of water:

 Community disruptions caused some projects to lag the programme of works  Vandalism of infrastructure equipment  Insufficient funding  Illegal water connections

Due to the shortage or lack of water supply, JMLM is unable to provide adequate sanitation to their communities. The majority of the population uses pit toilets (40.3% with ventilation and 36.7% without ventilation), 10.3% of the population have no access to toilet facilities and 6% are connected to a sewerage system.

JMLM collects refuse in Hotazel and Vanzylsrus, serving 1 144 households in the two areas. According to the 2011 Census, this service is provided for 6.1% of households, while 79.8% of households provide their own refuse dump and 11.4% do not have access to rubbish disposal.

JMLM conducts Environmental Awareness campaigns in all of the wards annually. The communities are given information on issues that need to be taken care of in their respective environmental areas. The most challenging issue of environmental management in JMLM is veld fires and to minimize that the municipality has entered into an agreement with Working on Fire through Expanded Public Works Programme. vii) Soil Information for this section has been sourced from:

 The Soil and Terrain (SOTER) database developed by ISRIC World Soil Information  M.V. Fey (2010). A short guide to the soils of South Africa, their distribution and correlation with World Reference Base soil groups. 19th World Congress of Soil Science, Soil Solutions for a Changing World.

The Soil and Terrain (SOTER) database developed by ISRIC World Soil Information provide data on key soil and terrain properties. According to the database, regional soils for the TIH PRA are ferralic arenosols (refer to Figure 7), however it is noted that any such soil resources were previously stripped and removed from the TIH PRA area during historic opencast mining activities. Any remaining soil resources would be those stockpiled intermittently around the opencast mine void. The description given below specifically applies to any such stockpiled or the limited remaining in-situ soil resources.

Arenosols develop during the weathering of quartz-rich material. The soils have a loamy sand or coarse- grained texture and occur at a depth of at least 50 cm from the surface. The soil typically has less than 35% rock fragments by volume. The soil type is generally suitable for extensive stock grazing but could be used for arable crops if well irrigated.

Quartz and feldspars are the dominant minerals in arenosols with lesser micas, pyroxenes, amphiboles, olivines, and heavy minerals (such as zircon, garnet, tourmaline, etc). Arenosols generally lack structure, they are not sticky when wet and loose grains when dry. A cemented layer may occur at some depths.

Arenosols is a World Reference Base soil type, in terms of South African classification, arenosols would classify as ‘plinthic’, ‘oxidic’ or ‘cumulic’ soil groups. As per the distribution of these soil types, oxidic and cumulic soils are known to occur in the project region, with oxidic soils generally being in greater abundance. Cumilic soils are generally young soils with an orthic topsoil but weakly developed subsoil and formed in colluvial, alluvial or aeolian environments. Oxidic soils are generally iron enriched through weathering with an orthic topsoil layer.

The soils within the PRA region can be broadly categorised into groupings associated with the different types of vegetation (Mucina and Rutherford, 2006). The Kathu Bushveld vegetation type are hosted on aeolian red sand, surface calcrete and deep (>1.2m) sandy soils of Hutton and Clovelly soil forms.

Figure 7: Soil types in the project area

viii) Terrestrial Ecology The greater project area falls within the Savanna Biome, within the Eastern Kalahari Bushveld Bioregion and the Inland Saline Vegetation Bioregion. Only one vegetation type is associated with the project area, namely the Kathu Bushveld vegetation type, which is listed as Least Threatened in terms of Section 52 of NEMBA (refer to Figure 8). The Ecosystem protection levels in Kathu Bushveld ecosystems are not protected as depicted in Figure 9 (less than 5% of the biodiversity target is met in formal protected areas). The proposed prospecting area is located in the Griqualand West Centre of Endemism. It must be noted, however, that the ecosystem within the TIH PRA area has been completely transformed as a result of historic land-use practise (opencast mining).

CBA’s are terrestrial and aquatic features in the landscape that are critical for retaining biodiversity and supporting continued ecosystem functioning and services. CBA’s need to be maintained in a natural or near-natural state in order to ensure the continued existence and functioning of species and ecosystems and the delivery of ecosystem services. Ecological support areas (ESA’s) are areas that are not essential for meeting biodiversity representation targets/thresholds but which nevertheless play an important role in supporting the ecological functioning of critical biodiversity areas and/or in delivering ecosystem services that support socio-economic development, such as water provision, flood mitigation or carbon sequestration. There are no CBA’s or ESA’s within the PRA area – the surrounding areas are classified as “Other Natural Areas” (refer to Figure 9) while the PRA area itself is bare / transformed by historic mining activities as per the Land Use and Land Cover images (discussed further in below).

According to the Mining and Biodiversity Guidelines (2013), there is no classification of biodiversity importance for the PRA site.

Species Composition

The project area falls within the greater Kathu Bushveld vegetation type classification (Mucina & Rutherford, 2006) that itself is characterised by medium-tall tree layer with the trees Acacia erioloba (Camel Thorn) and Boscia albitrunca (Shepherds Tree) as prominent trees interspersed with Schmidtia spp. and Stipagrostis spp. The shrub layer is generally most important with A.mellifera, Diospyros lycioides and Lycium hirustum. The grass layer is variable in cover. The land incorporated in the PRA area has however been completely transformed as a result of historical mining activities with little natural vegetation, especially trees. It is mostly grass and shrubs, see Figure 14 for site photos of the area.

Species of Conservation Concern

Floral species of conservation concern (SCC) which can occur in the Kathu Bushveld habitat include Acacia erioloba (Camel Thorn) and Boscia albitrunca (Shepherds Tree) which are classified as of least concern, however, the likelihood of occurrence hereof is considered highly unlikely due to the lack of remaining habitat features due to the pre-existing transformed nature of the site.

Similarly, faunal species of conservation importance which are associated with the Kathy Bushveld ecosystem include mammals (Ground Pangolin and African Wild Cat), birds (Tawny Eagle and Secretary Bird), reptiles (Rock Monitor), amphibians (Giant Bullfrog) and invertebrates (Horned Baboon Spider and

the Starburst Baboon Spider), however, the lack of ecosystem habitat features within the PRA area limit the potential for these species to occur

Environmental Sensitivity

The Kathu Bushveld ecosystem is considered to be Least Threatened. According to the Northern Cape Critical Biodiversity Areas assessment (2016), No ESA and CBAs (areas of conservation importance) are present within the project area. The overall transformed nature of the project area and lack of remaining ecosystem features on-site renders the overall sensitivity very low.

Figure 8: Vegetation Types/ Ecosystems associated with the project area

Figure 9: Ecosystem Protection Levels associated with the project area

Figure 10: Northern Cape Critical Biodiversity Areas

ix) Wetlands There are no wetlands situated within the bounds of the PRA, with the nearest wetland located approximately 5 km away (refer to Figure 11). The only occurrence of water on the site is in the historical opencast void (classified as permanent mine water) (see Figure 13).

Figure 11: Wetlands associated with the PRA

b) Description of the current land uses

Land use is defined as the operations that are occurring on land, as carried out by humans, with the intention to obtain products and/or benefits through using land resources. Land use therefore refers to the purpose the land serves, such as recreation, natural or agriculture. From Google Earth satellite imagery, ground-truthed during a site-visit undertaken on 04/07/2018, the land use associated with the PRA is historic opencast mining evidenced by the remaining void and stockpiles of residue material (Figure 12). No mining was currently taking place on the site and the mine has been disused for a number of years (See Figure 14)

Land cover is defined as the physical coverage on the earth’s surface, such as the vegetation (natural or cultivated) or man-made constructions (buildings, etc.) which occur on the earth surface. Land cover data for the proposed project area was obtained from the SANBI GIS Land Cover Map 2015. The land cover associated with the proposed PRA is classified mostly as mine area with pockets of shrubland, grassland and thicket/bush. There is some mining infrastructure that partially falls within the site bounds, however the majority is outside, represented by Figure 13.

Figure 12: Land Uses associated with the project area

Figure 13: Land Cover associated with the project area

Figure 14: Photos from the site visit showing the state of the site (04/07/2018)

c) Description of specific environmental features and infrastructure on the site

The Kathu Bushveld ecosystem type which is represented on the regional scale, is considered to be Least Threatened, however, features of the ecosystem are underrepresented on-site due to extensive transformation due to historical mining activities. According to the Northern Cape Critical Biodiversity Areas assessment (2016), no ESA and CBAs are present within the project area. There are no water courses or wetlands on the site. There is low likelihood that certain indigenous species may be present within the project area.

In terms of infrastructure, the R380 and the R31 roads run in close proximity to the site. There is also a small section of historic mining infrastructure and gravel roads located within the PRA. d) Environmental and current land use map (show all environmental, and current land use features)

Figure 15 below, provides an indication of what the land uses are for the TIH PRA site. The site reflects that it is mined and has some gravel roads. There are no areas of environmental concern.

Figure 15: Environmental and current land use map

6. Impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts (provide a list of the potential impacts identified of the activities described in the initial site layout that will be undertaken, as informed by both the typical known impacts of such activities, and as informed by the consultations with affected parties together with the significance, probability, and duration of the impacts. Please indicate the extent to which they can be reversed, the extent to which they may cause irreplaceable loss of resources, and can be avoided, managed or mitigated)

The potential impacts of the planned invasive prospecting activities (drilling) are listed below. Non-invasive prospecting activities are not expected to result in any environmental or socio-economic impacts.

Vegetation clearing for drill hole areas and access tracks as well as minor earth moving activities may result in the following impacts:

 Dust generated from activities.  Damage to buried archaeological or paleontological resources of significance.

Leaks from vehicles and machinery on site, inadequate hydrocarbon handling and storage, inadequate waste management and spills from ablutions may result in the following impact:

 Contamination of remaining in situ soil resources (limited potential, soil resources previously stripped during opencast mining activities).

The presence of vehicles and machinery as well as personnel on site for drilling activities may result in the following impacts:

 Noise.  Compaction of remaining in situ soil resources and subsequent negative impact on future vegetation re-establishment.  Disturbance of flora and fauna which have subsequently re-established in the historic mine void.

Refer to Section 6(g) below for an indication of the significance of the potential impacts and extent to which they can be avoided, managed or mitigated.

Refer to Appendix 3 for a detailed assessment of the significance of the potential impacts considering their magnitude, scale, duration and probability; as well as the extent to which they can be reversed, the extent to which they may cause irreplaceable loss of resources, and extent to which they can be avoided, managed or mitigated. a) Methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks (describe how the significance, probability, and duration of the

aforesaid identified impacts that were identified through the consultation process was determined in order to decide the extent to which the initial site layout needs revision)

The Prime Resources impact ranking tool is a quantitative manner of investigating, assessing and evaluating the potential impacts / risks resulting from the activities associated with the proposed activity on the receiving environment; i.e. the biophysical, socio-economic and cultural heritage environment.

The methodology encompasses an assessment of the nature, extent, duration, probability and significance of the identified potential environmental, social and cultural impacts of the mining operation, including the cumulative environmental impacts. The significance of both positive and negative potential impacts will be determined through the evaluation of impact consequence and likelihood of occurrence.

The following risk assessment model has been used for determination of the significance of impacts.

SIGNIFICANCE = (MAGNITUDE + DURATION + SCALE) X PROBABILITY

The maximum potential value for significance of an impact is 100 points. Impacts can therefore be rated as high, medium or low significance on the following basis:

 High environmental significance 60 – 100 points  Medium environmental significance 30 – 59 points  Low environmental significance 0 – 29 points

MAGNITUDE (M) DURATION (D) 10 – Very high (or unknown) 5 – Permanent 8 – High 4 – Long-term (ceases at the end of operation) 6 – Moderate 3 – Medium-term (2-4 years) 4 – Low 2 – Short-term (0-1 years) 2 – Minor 1 – Immediate SCALE (S) PROBABILITY (P) 5 – International 5 – Definite (or unknown) 4 – National 4 – High probability 3 – Regional 3 – Medium probability 2 – Local 2 – Low probability 1 – Site 1 – Improbable 0 – None 0 – None b) The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected (provide a discussion in terms of advantages and disadvantages of the initial site layout compared to alternative layout options to accommodate concerns raised by affected parties)

The overall site selection is located on a disturbed piece of land where open-cast mining has previously taken place and the selection is based on the location of the known mineral resources. If necessary 15 infill boreholes will be drilled however the necessity, addition and locations will be known post the Phase 1 (non-invasive) activities.

From responses received during the initial public participation undertaken, no comments or concerns were received pertaining to the location or environmental sensitivity of the area (comments received from IAPs mostly pertained to requests for further information {Department of Public Works, SANRAL, South 32 HMM, Kudumane Manganese and Agri-Kuruman} and to notify of concerns relating to groundwater yield and contamination potential, dust and noise generation, agricultural land and rehabilitation (Agri- Kuruman) All comments received and responses thereto as well as the location where issues raised are addressed in this BAR and EMP are indicated in Section 4 (i) Summary of issues raised by IAPS.

Considering the above, no changes have yet been required in terms of alterative locations or technologies due to concerns raised by IAPs. c) The possible mitigation measures that could be applied and the level of risk (with regard to the issues and concerns raised by affected parties provide a list of the issues raised and an assessment/ discussion of the mitigations or site layout alternatives available to accommodate or address their concerns, together with an assessment of the impacts or risks associated with the mitigation or alternatives considered)

PROPOSED ALTERNATIVE / ISSUE / CONCERN RAISED RESPONSE MITIGATION AND ASSESSMENT THEREOF No ground water abstraction will take place for the purposes of prospecting. Non-invasive techniques will be used initially that will not lead to contamination. If additional exploration boreholes are to be drilled, measures are prescribed to Concerns associated with prevent contamination of soil and Groundwater yield and groundwater contamination (i.e. Use N/A susceptibility to contamination of liners / tarps in sumps under drilling machinery and equipment that has the potential for hydrocarbon spills. Procedures for waste handling and management prescribed. Drilling activities will utilise biodegradable and environmentally acceptable drill fluids.) Non-invasive prospecting will not lead to an increase in noise levels. Concern over dust and noise Invasive drilling will not generate N/A generation through prospecting noise in excess of the baseline conditions per SANS 10103:2008 for rural / semi-urban districts Sufficient and acceptable Agricultural land does not form part N/A mitigation of agricultural land, of the proposed PRA area If drilled, boreholes will be plugged and affected areas rehabilitated in Rehabilitation terms of measures prescribed herein. N/A Further rehabilitation measures are not required at this stage.

d) Motivation where no alternative sites were considered

No alternative site locations have been considered to-date as the site selection is based on the expected mineral resources likely to occur within a known and historic mining environment. The site is also of low environmental impact due to its historic used and degraded status. e) Statement motivating the alternative development location within the overall site (provide a statement motivating the final site layout that is proposed)

If necessary, the location of additional exploration boreholes to be drilled will come to light post the Phase 1 (non-invasive prospecting) activities. The site does not overlap any sensitive environmental features or any CBA and ESA areas, therefore, limiting the potential negative environmental impacts of any future drilling sites within the PRA (drilling locations will nonetheless be assessed in terms of measures provided in this document to confirm the presence / absence of any hitherto unknown sensitive features or species). Requisite permits in terms of the NFA and NCNCA will be obtained if necessary for the clearance of indigenous and protected flora (currently considered unlikely). It is considered unlikely that potential impacts will occur to surrounding landowners or land use practises which would otherwise warrant pursuing further alternative investigation. f) Full description of the process undertaken to identify, assess and rank the impacts and risks the activity will impose on the preferred site (in respect of the final site layout plan) through the life of the activity. (Including (i) a description of all environmental issues and risks that were identified during the environmental impact assessment process and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures)

The potential impacts which may arise as a result of the planned exploration drilling activities are considered typical of these activities and were determined by considering the nature of the activity, the equipment and materials utilised, the type of waste generated, common incidents which lead to impacts, and the known timeframes and the proximity in relation to the environmental features of the site. The Prime Resources (Pty) Ltd Impact Assessment Methodology and rationale (described in Section 6[a]) above was used to assess the significance of the potential impacts. Refer to Section 6 above for the list of potential impacts identified, and refer to Appendix 3 for the detailed assessment of their significance and the extent to which they can be mitigated.

g) Assessment of each identified potentially significant impact and risk (this section of the report must consider all the known typical impacts of each of the activities including those that could or should have been identified by knowledgeable persons and not only those that were raised by registered interested and affected parties - the supporting impact assessment conducted by the EAP must be attached as an appendix)

The potential impacts of the planned invasive prospecting activities (exploration drilling) have been assessed and summarised in the table below, non-invasive prospecting activities are not expected to result in any environmental or socio-economic impacts. The supporting impact assessment conducted by Prime Resources is attached as Appendix 3.

PHASE SIGNIFICANCE ASPECTS IN WHICH SIGNIFICANCE NAME OF ACTIVITY POTENTIAL IMPACT IF NOT MITIGATION TYPE AFFECTED IMPACT IS IF MITIGATED MITIGATED ANTICIPATED Loss of vegetation - Where possible available access (possible plant species of tracks will be used conservation concern) - Drill sites should be evaluated by from clearing or harvesting Low the ECO prior to any clearing Low by personnel or activities in order to determine uncontrolled fires set by the presence of any sensitive, - Clearing access personnel protected or indigenous species track and drill sites and to advise permitting - Demarcation of drill requirements. pad Operational - When visiting drill sites the ECO - Temporary drillers Biodiversity (Phase 2 - will take a before photo that will laydown Drilling) be compared with an after photo - Temporary core Loss of animal species as a that the ECO will take once yard for cutting and result of collisions with drilling has been completed. processing drilling Low Low vehicles or hunting and - Avoid all plant species of - Diamond drilling trapping by personnel conservation concern (in the unlikely event that they are present) by changing the location/ extent / spatial layout of sites accordingly prior to clearing - Where avoidance is not possible,

PHASE SIGNIFICANCE ASPECTS IN WHICH SIGNIFICANCE NAME OF ACTIVITY POTENTIAL IMPACT IF NOT MITIGATION TYPE AFFECTED IMPACT IS IF MITIGATED MITIGATED ANTICIPATED the necessary permits / licenses must be sought before any clearance activities are permitted (NCNCA, NFA and NEMBA) - Areas to be cleared will be limited to the minimum extent possible - Avoid clearing trees where possible - No hunting and harvesting of plants or animals must be allowed - No uncontrolled fires must be allowed - Intervening by planting indigenous vegetation in disturbed areas should natural revegetation prove unsuccessful - Maintaining equipment and Noise from drilling Noise; machinery in good working order activities may result in Socio- Low Low - Switching off equipment when not nuisance economic in use Damage to buried Heritage; archaeological or or - Implement a chance finds Socio- Low Low paleontological resources procedure as detailed in Table 2 economic of significance - Areas to be cleared will be limited Air quality; to the minimum extent possible Dust generated may result Socio- Low - Wet suppression must be Low in nuisance impacts economic implemented where dust plumes are noted Heavy vehicles and - Implementing spill prevention machinery on site may measures such as handling and result in potential Soil Low storing hydrocarbons on Low hydrocarbon leaks which impermeable surfaces may in turn pollute the soil - Adequately maintaining vehicles

PHASE SIGNIFICANCE ASPECTS IN WHICH SIGNIFICANCE NAME OF ACTIVITY POTENTIAL IMPACT IF NOT MITIGATION TYPE AFFECTED IMPACT IS IF MITIGATED MITIGATED ANTICIPATED and machinery to prevent leaks - Plastic lining of sumps - Cleaning any spills immediately Heavy vehicles and machinery on site may - Minimising areas to be disturbed result in soil compaction by vehicle and machinery, Soil Low Low subsequently impacting - Ripping and profiling compacted vegetation re- soil establishment - Cleaning any spills immediately Waste spills may result in Stores and ablutions Soil Low - Implementing adequate waste Low pollution of soil management practices

h) Summary of specialist reports (this summary must be completed if any specialist reports informed the impact assessment and final site layout process and must be in the following tabular form - attach copies of specialist reports as appendices)

SPECIALIST REFERENCE TO RECOMMENDATIONS APPLICABLE SECTION THAT HAVE BEEN OF REPORT WHERE LIST OF RECOMMENDATIONS OF SPECIALIST REPORTS INCLUDED IN THE EIA SPECIALIST STUDIES UNDERTAKEN REPORT RECOMMENDATIONS (Mark with an X where HAVE BEEN INCLUDED. applicable) N/A N/A N/A N/A

No specialist studies were commissioned considering the nature of the activities to be undertaken, the availability of suitable information from available resources and the sensitivity of the project area..

7. Environmental impact statement a) Summary of the key findings of the environmental impact assessment

Potential impacts which cannot be adequately mitigated (i.e. those with a significance rating of Medium (significance value ≥ 31) or above after the implementation of mitigation measures), are considered key findings of the environmental impact assessment.

Due to the limited extent of the areas to be cleared, limited temporary infrastructure required, temporary nature of the activities, the fact that there are no areas of environmental significance located within the PRA, and the fact that there are no water resources in close proximity to the site all of the potential impacts are considered to be of low significance before the implementation of mitigation measures. Therefore, none of the potential impacts are considered key findings.

The uncertainty as to the necessity or location of any boreholes does not influence the risk due to the current state of the area as already disturbed and classified land use as mining. Mitigation measures will be applicable the drilling sites identified as a result of Phase 1 prospecting activities and will therefore still ensure that the significance of the potential impacts remains low by, for e.g. having plastic lining to ensure that there is no surface impact from the drilling program in the form of hydrocarbon spills on the soil. Drilling activities will also utilise biodegradable and environmentally acceptable drilling fluids. b) Final site map (provide a map at an appropriate scale which superimposes the proposed overall activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers)

There are no areas of environmental sensitivity on the site or areas that should be avoided and their buffer zones. Refer to Figure 15 c) Summary of the positive and negative impacts and risks of the proposed activity and identified alternatives

Negative impacts

The potential impacts of the planned invasive prospecting activities (drilling) are listed below.

Vegetation clearing and minor earth moving activities for drill hole areas and access tracks may result in the following impacts:

 Dust generated from activities.  Damage to buried archaeological or paleontological resources of significance (limited potential as it is assumed that all such features have already been removed or destroyed during previous mining activities).

Leaks from vehicles and machinery on site, inadequate hydrocarbon handling and storage, inadequate waste management and spills from ablutions may result in the following impact: 5

 Contamination of soil (limited potential as soil resources have largely been stripped from the site during historical mining activities).

The presence of vehicles and machinery as well as personnel on site for drilling activities may result in the following impacts:

 Noise.  Compaction of soil and subsequent negative impact on vegetation re-establishment.  Disturbance of flora and fauna.

Positive impacts

The prospecting activities being applied for are required in order to investigate the presence of suitable mineralisation and, if so, whether this mineralisation can be economically and feasibly mined in future which, in turn, presents various socio-economic benefits to the region as well as the potential to suitably rehabilitate the areas affected by opencast mining in the past.

8. Proposed impact management objectives and the impact management outcomes for inclusion in the EMPr (based on the assessment and where applicable the recommendations from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation)

Refer to Section 4 of the EMP (Part B of this document) for the proposed impact management objectives and the impact management outcomes.

9. Aspects for inclusion as conditions of Authorisation (any aspects which must be made conditions of the Environmental Authorisation)

 The terms and conditions for surface access to the PRA between the Applicant and affected landowners must be finalised prior to the commencement of invasive prospecting activities.  The commitments as per this EMP (Part B) must be adhered to.  Rehabilitation and closure must be undertaken as per the Closure Plan (refer to Appendix 4).

10. Description of any assumptions, uncertainties and gaps in knowledge (which relate to the assessment and mitigation measures proposed)

 Information to characterise the baseline environment was obtained from available desktop sources in the public domain and evidenced during a site visit. It is assumed that this information accurately reflects the current conditions of the PRA, aside from those aspects where information is outdated and is stated as such in the baseline description. It is, however, not considered that this data will alter the findings or outcomes of any potential impact identified nor the management measures proposed.

11. Reasoned opinion as to whether the proposed activity should or should not be authorised a) Reasons why the activity should be authorized or not

The findings of the impact assessment indicate that prospecting activities will not result in any significant social or environmental impacts. No fatal flaws were identified; therefore, no reasons why the activities should not be authorized were identified. b) Conditions that must be included in the authorisation

None aside from those listed under Section 9 above, as all the relevant aspects have been included as commitments in this EMP (Part B of this document) as well as within the Closure Plan (refer to Appendix 4). c) Period for which the Environmental Authorisation is required

The period for which authorisation is required will be from the year 2018 to the year 2022.

12. Undertaking (confirm that the undertaking required to meet the requirements of this section is provided at the end of the EMPr and is applicable to both the Basic assessment report and the Environmental Management Programme report)

The undertaking in the EMP is applicable to both the BAR (this section, Part A) and the EMP (Part B).

13. Financial Provision (state the amount that is required to both manage and rehabilitate the environment in respect of rehabilitation)

As per Regulation 6(3) of the NEMA Regulations on Financial Provision (GNR1147 of 2015) the determination of the quantum for rehabilitation-related financial provision has been included in the EMP (Part B - 5(a)(v)).

The total financial provision for the invasive prospecting activities proposed for the TIH Project, is therefore R 23,331 (value as per date of assessment - 2018). a) Explain how the aforesaid amount was derived

Regulation 6 of the NEMA Regulations on Financial Provision (GNR1147 of 2015) states that a holder must determine the financial provision through a detailed itemisation of all activities and costs required for final rehabilitation, decommissioning and closure of the operations.

The Guideline for Evaluation of the Quantum for Closure-Related Financial Provision compiled by the then Department of Minerals and Energy (DME) (now DMR) was used to inform the itemised breakdown. The guideline rates were however adjusted using contractor rates to provide actual, present-day costs for decommissioning and rehabilitation. The rates utilised are based on contractor rates which have been

escalated by Consumer Price Index (CPI) of 5.26% for 2017. Refer to Section 5(a)(v) in the EMP - Part B of this document for further information.

From the methodology for calculation of Financial Provision for a new development in the draft financial provisioning regulations (GNR1228 of 2017), the costing for final rehabilitation, decommissioning and closure, must reflect the total cost to remediate disturbances that will occur in Year O and must reflect actual market related costs based on prevailing rates exclusive of VAT. The costing for residual environmental impacts which will occur in the future must reflect the Net Present Value (NPV) based on prevailing rates of future residual environmental impacts due to disturbance of Year O. This is the Year O cost for residual environmental impacts. Total 1 for final rehabilitation, decommissioning and mine closure and Total 2 for residual environmental impacts which may occur in the future are then added to obtain the Total Financial Provision. b) Confirm that this amount can be provided for from operating expenditure (confirm that the amount, is anticipated to be an operating cost and is provided for as such in the Mining work programme, Financial and Technical Competence Report or Prospecting Work Programme as the case may be)

2) Financial Provision is provided for as a regulatory cost, totalling R 50 000 (under the rehabilitation cost category) in the Prospecting Work Programme.

14. Specific Information required by the Competent Authority a) Compliance with the provisions of sections 24(4)(a) and (b) read with section 24 (3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998) the report must include the:- i) Impact on the socio-economic conditions of any directly affected person (provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any directly affected person including the landowner, lawful occupier, or, where applicable, potential beneficiaries of any land restitution claim, attach the investigation report as an appendix)

There are no communities in proximity to the PRA. The land is privately owned. Correspondence from the Chief Director: Land Restitution Support – Northern Cape, dated 3 July 2018 indicates that a claim appears on the databases for claims up to 31 / 12 / 1998 and between 1 / 07 /2014 and 27 / 07 / 2016 against the property in question, but does not provide any further information in this regard (see Appendix 5). At present, the landowner (South 32 / Hotazel Manganese Mines) would therefore be the only directly affected party. It is required that a suitable agreement will be drawn up between the Applicant and the landowner for the activities proposed.

Due to the nature of the site, the proposed activities and the proximity to surrounding stakeholders, potential socio-economic impacts due to the undertaking of the activity are considered highly limited. ii) Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act (provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) with the exception of the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act, attach the investigation report as an appendix and confirm that the applicable mitigation is reflected herein)

Sites of archaeological or or paleontological significance are unlikely to be present in the area (having either been exposed, destroyed or otherwise removed during historical mining activities). However, there is always a chance that buried artefacts may be unearthed during vegetation clearing and minor earth moving activities. The potential impact is only applicable during vegetation clearing and earth moving activities. The potential impact can be mitigated by implementing a chance finds procedure (as detailed in Table 2 in the EMP - Part B of this document) to prevent damage to buried resources which may be of significance, in the unlikely event that they are unearthed. The significance of the potential impact on buried artefacts is low prior to and after the implementation of the recommended mitigation measure. b) Other matters required in terms of sections 24(4)(a) and (b) of the Act (the EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in sub-regulation 22(2)(h), exist)

Motivation for why alternatives were not considered has been included in Section 3(f). This BAR addresses the following requirements in terms of sections 24(4)(a) and (b) of the Act:

SECTION DESCRIPTION OF HOW THE CONTENTS OF NEMA ASPECT HAS BEEN ADDRESSED Section 24(4)(a) Procedures for the investigation, assessment and communication of the potential consequences or impacts of Refer to Section 6(a) for the 24(4)(a) activities on the environment – methodology used for the assessment must ensure, with respect to every of impacts. application for an environmental authorisation— Coordination and cooperation between The BAR / EMP will be made available organs of state in the consideration of to all the relevant organs of state: local 24(4)(a)(i) assessments where an activity falls under and district municipality, Northern the jurisdiction of more than one organ of Cape Department of Environment and state; Nature Conservation; Northern Cape

SECTION DESCRIPTION OF HOW THE CONTENTS OF NEMA ASPECT HAS BEEN ADDRESSED Department of Agriculture Land Reform and Development; Department of Mineral Resources; Department of Water and Sanitation; Department of Agriculture, Fisheries and Forestry for comment during public participation processes. The DMR remains the Competent Authority. That the findings and recommendations flowing from an investigation, the general objectives of integrated environmental The general objectives and the management laid down in this Act and the principles of environmental 24(4)(a)(ii) principles of environmental management management were addressed in the set out in section 2 are taken into account EMP - Part B of this document. in any decision made by an organ of state in relation to any proposed policy, programme, process, plan or project; That a description of the environment Refer to Section 5(a) for a detailed likely to be significantly affected by the 24(4)(a)(iii) description of the baseline environment proposed activity is contained in such likely to be affected by the project. application; Investigation of the potential consequences for or impacts on the Refer to Section 3(g) for the 24(4)(a)(iv) environment of the activity and assessment of the potential impacts. assessment of the significance of those potential consequences or impacts; and Public information and participation procedures which provide all interested and affected parties, including all organs of state in all spheres of government that Refer to Section 4 which details the 24(4)(a)(v) may have jurisdiction over any aspect of public participation process followed. the activity, with a reasonable opportunity to participate in those information and participation procedures; and Where environmental impact assessment has been identified as the environmental Basic Assessment has been identified instrument to be utilised in informing an 24(4)(A) as the environmental instrument application for environmental therefore (4)(b) is applicable. authorisation, subsection (4)(b) is applicable Section 24(4)(b) Must include, with respect to every 24(4)(b) application for an environmental authorisation and where applicable— Investigation of the potential consequences or impacts of the Motivation for why alternatives were alternatives to the activity on the not considered, as well as the options 24(4)(b)(i) environment and assessment of the of not implementing the activity have significance of those potential been addressed in Section 3(f). consequences or impacts, including the option of not implementing the activity; Investigation of mitigation measures to Mitigation measures for potential 24(4)(b)(ii) keep adverse consequences or impacts to impacts have been identified. Refer to

SECTION DESCRIPTION OF HOW THE CONTENTS OF NEMA ASPECT HAS BEEN ADDRESSED a minimum; Section 4 of the EMP - Part B of this document. Investigation, assessment and evaluation of the impact of any proposed listed or The NHRA has been taken into account specified activity on any national estate (refer to Section 5(a)) where the referred to in section 3(2) of the National current heritage landscape in the 24(4)(b)(iii) Heritage Resources Act, 1999 (Act No. 25 project area is characterised) and the of 1999), excluding the national estate project does not trigger any activities contemplated in section 3(2)(i)(vi) and as listed therein (refer to Section 3(c)). (vii) of that Act; Reporting on gaps in knowledge, the adequacy of predictive methods and The gaps have been identified. Refer to 24(4)(b)(iv) underlying assumptions, and uncertainties Section 10 of the EMP - Part B of this encountered in compiling the required document. information; Management and monitoring measures have been specified in the EMP - Part B Investigation and formulation of of this document. Implementation and arrangements for the monitoring and suitability of the EMP will be audited management of consequences for or every second year as required by 24(4)(b)(v) impacts on the environment, and the Regulation 55 of the MPRDA as well as assessment of the effectiveness of such per the frequency indicated in the arrangements after their implementation; Environmental Authorisation as per of Regulation 34 of the NEMA EIA Regulations, 2014. Consideration of environmental attributes identified in the compilation of information 24(4)(b)(vi) and maps contemplated in subsection (3); and Refer to Section 5(a) for maps The Minister, or an MEC with the indicating geographical areas, including concurrence of the Minister, may compile the sensitivity, extent, interrelationship information and maps that specify the and significance of such attributes attributes of the environment in particular informed by maps compiled by relevant 24(3) geographical areas, including the departments. sensitivity, extent, interrelationship and significance of such attributes which must be taken into account by every competent authority. Listed activities for the project have been identified. Refer to Section 3(a). Basic Assessment has been identified as the environmental instrument in terms of NEMA. An AEL is not required Provision for the adherence to as per NEMAQA. A WML is not required requirements that are prescribed in a as per NEMWA. Permits may be 24(4)(b)(vii) specific environmental management Act required as per NEMBA in the unlikely relevant to the listed or specified activity in event that species of conservation question. concern are identified and require relocation should avoidance through locating alternative drill sites not be possible. The area does not fall within a protected area as per NEMPAA. A WUL is not required in terms of NWA.

PART B ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

1. Details of the EAP (confirm that the requirement for the provision of the details and expertise of the EAP are already included in PART A, section 1(a) herein as required)

The details and expertise of the EAP are already included in Part A, Section 1(a) herein as required. Key Prime Resources Personnel CVs are attached as Appendix 1.1. The Prime Resources Company Profile is attached as Appendix 1.2.

2. Description of the aspects of the activity (confirm that the requirement to describe the aspects of the activity that are covered by the draft environmental management programme is already included in PART A, section (1)(h) herein as required)

The aspects of the activity that are covered by the EMP are already included in detail in Part A, Section (1)(h) herein as required.

3. Composite map (provide a map at an appropriate scale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that any areas that should be avoided, including buffers) There are no areas of environmental sensitivity on the site or areas that should be avoided and their buffer zones. Refer to Figure 15

4. Description of Impact management objectives including management statements a) Determination of closure objectives (ensure that the closure objectives are informed by the type of environment described)

The main objective will be to rehabilitate- and return the borehole drill areas, access tracks and any areas affected as a result of invasive prospecting activities (including temporary infrastructure) to resemble the surrounding landscape with no remaining infrastructure or potential hazards to people or the environment.

Further environmental objectives include:

. Ensure that no temporary infrastructure is left on-site and ensure environmental and safety risks are minimised; . Rehabilitate areas disturbed by prospecting activities (drill sites and access roads);

. Rehabilitated drill sites and access paths must not pose a safety hazard to humans and animals; . Limit to the greatest extent possible the clearing of vegetation during prospecting activities; . Establish a self-sustaining and stable vegetation cover over the area disturbed by the prospecting activities, if necessary by ripping and re-seeding using an appropriate indigenous seed-mix to promote the rehabilitation of the affected area to coincide with the surrounding landcover; . Minimise the further establishment of alien vegetation at rehabilitated drill sites; . Ensure the rehabilitated drill sites are free draining; and . Ensure adherence to local, provincial and national regulatory requirements.

The Closure Plan (Appendix 4) provides specific goals for each of the above-mentioned aspects to achieve the main closure objective. b) Volumes and rate of water use required for the operation

The estimated water use required per day is approximately 5 000 litres per diamond drill rig per day. The Applicant will make use of water obtained from municipal services in the town of Hotazel and brought to site in a water tanker. c) Has a water use licence has been applied for?

A water use licence is not required for the project as:

 The Applicant will make use of water obtained from a legal source and not commission a new abstraction point;  No waste or water containing waste will be disposed in a manner which may result in pollution;  No waste or water containing waste will be discharged into the environment; and  No activities which may result in pollution will take place within a regulated area of a watercourse.

d) Impacts to be mitigated in their respective phases (measures to rehabilitate the environment affected by the undertaking of any listed activity)

SIZE AND COMPLIANCE TIME PERIOD FOR ACTIVITIES POTENTIAL IMPACT PHASE SCALE OF MITIGATION MEASURES WITH IMPLEMENTATION DISTURBANCE STANDARDS - Where possible available Permits may be access tracks will be used required as per - Drill sites should be NCNCA, NFA and evaluated by a the ECO NEMBA in the - Access track Loss of vegetation prior to any clearing unlikely event to drill sites (possible plant species of activities in order to that species of (assumed conservation concern) determine the presence of conservation existing from clearing or any sensitive, protected or concern are tracks will harvesting by personnel indigenous species and to identified and be used but or uncontrolled fires set advise permitting require relocation 150m x 2m by personnel requirements in terms of should avoidance - Clearing access track of additional the NFA, NCNCA or NEMBA. through locating and drill sites tracks - When visiting drill sites the alternative drill - Demarcation of drill allowed for) ECO will take a before sites not be pad - Demarcation Operational photo that will be possible. Operational - Temporary drillers of drill pad (Phase 3 - compared with an after (Phase 3 - laydown (10 m x 10 Drilling) photo that the ECO will Drilling) - Temporary core yard m) per pad take once for cutting and (x15 pads) - Re-evaluate spatial extent processing drilling - A and layout of proposed - Diamond drilling contractor’s drill-site in order to avoid laydown Loss of animal species as plant species of (10m x a result of collisions with conservation concern (in 10m) N/A vehicles or hunting and the unlikely event that they - Diamond trapping by personnel are present) drilling (15 - Where avoidance is not holes) possible, the necessary

permits / licenses must be sought in terms of the NFA / NCNCA / NEMBA before any clearance activities are

SIZE AND COMPLIANCE TIME PERIOD FOR ACTIVITIES POTENTIAL IMPACT PHASE SCALE OF MITIGATION MEASURES WITH IMPLEMENTATION DISTURBANCE STANDARDS permitted. - Areas to be cleared will be limited to the minimum extent possible - Avoid clearing trees - No harvesting of plants or hunting and trapping of animals must be allowed - No uncontrolled fires must be allowed - Intervening by planting indigenous vegetation in disturbed areas should natural revegetation prove unsuccessful Ambient noise - Maintaining equipment and levels unlikely to Noise from drilling machinery in good working increase above activities may result in order the typical rating nuisance - Switching off equipment level for rural when not in use districts (SANS 10103:2008) In the unlikely event that Damage to buried artefacts are - Implement a chance finds archaeological or or unearthed they procedure as detailed in paleontological resources must be dealt Table 2 of significance with according to the provisions of the NHRA - Areas to be cleared will be Dust generated limited to the minimum likely to fall Dust generated may extent possible below the result nuisance impacts - Wet suppression must be threshold as per implemented where dust the NEMAQA plumes are noted National Dust

SIZE AND COMPLIANCE TIME PERIOD FOR ACTIVITIES POTENTIAL IMPACT PHASE SCALE OF MITIGATION MEASURES WITH IMPLEMENTATION DISTURBANCE STANDARDS Control Regulation Standards for residential areas - Implementing spill prevention measures such as handling and storing hydrocarbons on Heavy vehicles and impermeable surfaces machinery on site may - Adequately maintaining result in potential vehicles and machinery to N/A hydrocarbon leaks which prevent leaks may in turn pollute soil - Cleaning any spills immediately - Plastic lining of sumps to capture the biodegradable drilling fluid Heavy vehicles and - Minimising areas to be machinery on site may disturbed by vehicle and result in soil compaction machinery, N/A subsequently impacting - Ripping and profiling vegetation re- compacted soil establishment - Cleaning any spills immediately Waste spills may result in Stores and ablutions - Implementing adequate N/A pollution of soil waste management practices

e) Impact management outcomes (a description of impact management outcomes, identifying the standard of impact management required for the aspects contemplated)

PHASE IN ASPECTS WHICH STANDARDS TO BE ACTIVITIES POTENTIAL IMPACT MITIGATION MEASURES AFFECTED IMPACT IS ACHIEVED ANTICIPATED Loss of vegetation from - Where possible available clearing or harvesting by access tracks will be used personnel or uncontrolled - Drill sites should be fires set by personnel evaluated by the ECO prior to any clearing activities in order to determine the presence of any sensitive, protected or indigenous species and to advise permitting requirements in - Clearing access track terms of the NFA, NCNCA or and drill sites NEMBA. Prevent loss of plant - Demarcation of drill - When visiting drill sites the species of conservation pad ECO will take a before photo Operational concern and minimise - Temporary drillers that will be compared with an Biodiversity (Phase 3 - disturbance to habitat laydown Loss of animal species as a after photo that the ECO will Drilling) and fauna as per the - Temporary core yard result of collisions with take once management plan in for cutting and vehicles or hunting and - Avoid all indigenous species, Section 4(f) below processing drilling trapping by personnel protected trees and other - Diamond drilling plant species of conservation concern by changing the spatial layout / extent of drill sites accordingly prior to clearing - Where avoidance is not possible, the necessary permits / licenses must be sought in terms of the NFA / NCNCA / NEMBA before any clearance activities are

PHASE IN ASPECTS WHICH STANDARDS TO BE ACTIVITIES POTENTIAL IMPACT MITIGATION MEASURES AFFECTED IMPACT IS ACHIEVED ANTICIPATED permitted. - Areas to be cleared will be limited to the minimum extent possible - Avoid clearing trees - No harvesting of plants or hunting and trapping of animals must be allowed - No uncontrolled fires must be allowed - Intervening by planting indigenous vegetation in disturbed areas should natural revegetation prove unsuccessful and/or as per landowner agreements Avoid disturbance of surrounding residents by - Maintaining equipment and implementing measures machinery in good working Noise from drilling activities Noise; as per the management order may result in nuisance Social plan in Section 4(f) - Switching off equipment below; noise likely to be when not in use in line with standards (SANS 10103:2008) Prevent damage to archaeological resources by implementing measures as per the Damage to buried - Implement a chance finds management plan in archaeological or or Heritage; procedure as detailed in Section 4(f) below; in the paleontological resources of Social Table 2 unlikely event that significance artefacts are unearthed they must be dealt with according to the provisions of the NHRA

PHASE IN ASPECTS WHICH STANDARDS TO BE ACTIVITIES POTENTIAL IMPACT MITIGATION MEASURES AFFECTED IMPACT IS ACHIEVED ANTICIPATED Prevent excessive dust by implementing measures as per the management - Areas to be cleared will be plan in Section 4(f) limited to the minimum below; dust generated Dust generated may result in Air quality; extent possible likely to fall below the nuisance impacts Social - Wet suppression must be threshold as per the implemented where dust NEMAQA National Dust plumes are noted Control Regulation Standards for residential areas - Implementing spill prevention measures such as handling and storing hydrocarbons on Soil; Prevent contamination of Heavy vehicles and machinery impermeable surfaces Biodiversity; soil by implementing on site may result in potential - Plastic lining sumps Surface water; measures as per the hydrocarbon leaks which may - Adequately maintaining Wetlands; management plan in in turn pollute the soil vehicles and machinery to Groundwater Section 4(f) below prevent leaks - Cleaning any spills immediately - Minimising areas to be disturbed by vehicle and Prevent or repair machinery, compaction of soil by Heavy vehicles and machinery - Ripping and profiling implementing measures on site may result in soil compacted soil as per the management compaction subsequently Soil - Intervening by planting plan in Section 4(f) below impacting vegetation re- indigenous vegetation in to ensure that there are establishment disturbed areas should no negative impacts of natural revegetation prove vegetation re- unsuccessful and /or as per establishment landowner agreements - Cleaning any spills Prevent contamination of Waste spills may result in Stores and ablutions Soil immediately soil by implementing pollution of soil - Implementing adequate measures as per the

PHASE IN ASPECTS WHICH STANDARDS TO BE ACTIVITIES POTENTIAL IMPACT MITIGATION MEASURES AFFECTED IMPACT IS ACHIEVED ANTICIPATED waste management practices management plan in Section 4(f) below

f) Impact management actions (a description of impact management actions, identifying the manner in which the impact management objectives and outcomes contemplated in paragraphs (c) and (d) will be achieved)

TIME PERIOD FOR MITIGATION COMPLIANCE WITH ACTIVITY POTENTIAL IMPACT IMPLEMENTATION TYPE STANDARDS

Loss of vegetation (possible - Where possible available access plant species of conservation tracks will be used concern) from clearing or - Drill sites should be evaluated by harvesting by personnel or the ECO prior to any clearing uncontrolled fires set by activities in order to determine the personnel presence of any sensitive, protected or indigenous species and to advise permitting in terms of NFA, NCNCA or NEMBA. - When visiting drill sites the ECO will Prevent loss of plant take a before photo that will be species of compared with an after photo that conservation concern the ECO will take once and minimise - Clearing access track and drill - Avoid all indigenous species, disturbance to habitat sites protected trees and other plant and fauna as per the - Demarcation of drill pad species of conservation concern by Operational (Phase 3 - management plan in - Temporary drillers laydown changing the spatial layout / extent Drilling) Table 2 below. Permits - Temporary core yard for Loss of animal species as a result of drill sites accordingly prior to to be obtained from cutting and processing drilling of collisions with vehicles or clearing NFA, NCNCA and - Diamond drilling hunting and trapping by - Where avoidance is not possible, the NEMBA as required for personnel necessary permits / licenses must clearing or moving be sought in terms of the NFA / indigenous / protected NCNCA / NEMBA before any species. clearance activities are permitted. - Areas to be cleared will be limited to the minimum extent possible - Avoid clearing trees - No harvesting of plants or hunting and trapping of animals must be allowed - No uncontrolled fires must be allowed

TIME PERIOD FOR MITIGATION COMPLIANCE WITH ACTIVITY POTENTIAL IMPACT IMPLEMENTATION TYPE STANDARDS

- Intervening by planting indigenous vegetation in disturbed areas should natural revegetation prove unsuccessful Avoid disturbance of surrounding residents by implementing - Maintaining equipment and measures as per the Noise from drilling activities may machinery in good working order management plan in result in nuisance to landowners - Switching off equipment when not in Table 2 below; noise use standards (SANS 10103:2008) must be met Prevent damage to archaeological resources by implementing measures as per the Damage to buried archaeological management plan in - Implement a chance finds procedure or or paleontological resources of Table 2 below; in the as detailed in Table 2 significance unlikely event that artefacts are unearthed they must be dealt with according to the provisions of the NHRA Prevent excessive dust by implementing measures as per the - Areas to be cleared will be limited to management plan in the minimum extent possible Table 2 below; dust Dust generated may result in - Wet suppression must be generated likely to fall nuisance impacts implemented where dust plumes are below the threshold as noted per the NEMAQA National Dust Control Regulation Standards for residential areas

TIME PERIOD FOR MITIGATION COMPLIANCE WITH ACTIVITY POTENTIAL IMPACT IMPLEMENTATION TYPE STANDARDS

- Implementing spill prevention measures such as handling and Prevent contamination Heavy vehicles and machinery storing hydrocarbons on soil by implementing on site may result in potential impermeable surfaces measures as per the hydrocarbon leaks which may in - Adequately maintaining vehicles and management plan in turn pollute soil machinery to prevent leaks Table 2 below - Plastic lining sumps - Cleaning any spills immediately Prevent or repair - Minimising areas to be disturbed by compaction of soil by vehicle and machinery, implementing Heavy vehicles and machinery - Ripping and profiling compacted soil measures as per the on site may result in soil - Intervening by planting indigenous management plan in compaction subsequently vegetation in disturbed areas should Table 2 below to impacting vegetation re- natural revegetation prove ensure that there are establishment unsuccessful and /or as per no negative impacts of landowner agreements vegetation re- establishment Prevent contamination of soil by - Cleaning any spills immediately Waste spills may result in implementing Stores and ablutions - Implementing adequate waste pollution of soil measures as per the management practices management plan in Table 2 below

The table below details the management plan to be implemented to manage the potential impacts of the proposed prospecting activities. An Environmental Control Officer (ECO) must be appointed to ensure that the various management measures detailed herein are implemented and that the necessary auditing and reporting is conducted.

Table 2: Management plan

RESPONSIBLE MANAGEMENT AREA ASPECT MANAGEMENT MEASURE PARTY Environmental awareness training must be implemented as per the environmental Soil; awareness plan (as per Section 7 of the EMP Part B of this document) educating Biodiversity; personnel and contractors on how to interact with the environment and landowners. Surface water; As part of environmental awareness training, personnel and contractors must be Awareness Wetlands; ECO Groundwater; educated regarding the possible presence of subterranean archaeological and/or Heritage; paleontological sites, features or artefacts and be advised of the penalties associated Social with the unlawful removal of these artefacts, as set out in the NHRA as well as of this chance finds procedure. If any buried archaeological or palaeontological findings are discovered during clearing activities, the excavation must stop and the ECO must be notified immediately. The ECO ECO / SAHRA must then contact SAHRA to investigate the findings. The ECO must contact an archaeologist and/or palaeontologist, depending on the nature of the find, to assess the importance and rescue them if necessary (with the relevant Chance finds procedure Heritage SAHRA permit). No work may be resumed in this area without the permission from the ECO/ ECO and SAHRA. Under no circumstances shall any artefacts be removed, destroyed or Archaeologist / interfered with. Palaeontologist Any mitigation or management measures recommended by the specialist, after assessment of the find, must be implemented. Air quality; Vegetation clearing must be limited to the smallest extent possible. Vegetation clearing Biodiversity; Where possible available access tracks must be used. Soil Dust Air quality Wet suppression must be implemented where dust plumes are noted. When excavating separate pits for waste water, grease and oil polluted water, any ECO Topsoil Clearing Soil topsoil and subsoil must be stored separately. Once TIH has confirmed the location of any drill-sites, access tracks or exploration Floral species of Biodiversity boreholes, the ECO must survey all potential areas to be for the presence of any conservation concern indigenous or protected plant or animal species, including protected trees, from those

RESPONSIBLE MANAGEMENT AREA ASPECT MANAGEMENT MEASURE PARTY described in the baseline environmental section of this report. The site team will then evaluate the potential to minimise or avoid the disturbance of any indigenous or protected species by altering the exact position and spatial layout for that drill site. Should it still be required that species must be removed, the ECO should seek assistance from a botanical specialist knowledgeable of the NCNCA and the NFA to confirm any preliminary findings and to assist. TIH is to apply for the necessary permits for the removal of any indigenous vegetation or protected species which cannot be avoided, from the relevant Department. No ground clearance activities can be commissioned without such prior evaluation and the necessary permits being obtained in terms of the NCNCA, the NFA and the National Environmental Management: Biodiversity Act, No. 10 of 2004. Trapping of fauna No trapping or hunting of any faunal species must be allowed. Fires Uncontrolled fires must not be allowed. Natural revegetation will likely occur. Where drill sites have been denuded, the surface shall be ripped or ploughed. Access tracks shall be ripped or ploughed. Disturbed areas Rehabilitation must be inspected after a growing season has passed and should natural revegetation prove unsuccessful areas must be revegetated using indigenous vegetation species. Timing of revegetation / reseeding to be agreed on in landowner agreement. Handle and store hydrocarbons on impermeable surfaces. Hydrocarbons must be stored in a bunded area with a capacity to contain 110 % of the total volume stored. Implement systematic maintenance of all forms of equipment and vehicles to prevent leaks. Hydrocarbon Refuel machinery and vehicles over drip trays. management Conduct any machinery and vehicle maintenance on impermeable surfaces. Pits for waste water, grease and oil polluted water must be plastic lined to prevent pollution. Upon completion of drilling, the contents of the pit (including the spent plastic liner) must be disposed of at a licensed disposal facility. Soil Ensure that an adequate number of waste bins are available on site. Waste must be stored in a manner that it cannot be washed or blown into the environment. The active drill site must be cleaned daily and litter removed and deposited in the bins provided. Waste management No waste is permitted to be buried or burned on site. Waste must be collected and disposed of at a licensed disposal facility. Portable toilets are to be provided and maintained in a manner which prevents spills. Under no circumstances may ablutions occur outside of the provided facilities. Spills Clean any spills immediately according to the MSDS using spill kits which must be kept 3

RESPONSIBLE MANAGEMENT AREA ASPECT MANAGEMENT MEASURE PARTY on site. Soil; Minimise areas to be disturbed by vehicles and machinery. Compaction Biodiversity Rip and profile any areas of compacted soil. Air quality Low vehicle speeds must be enforced on unpaved surfaces to minimise dust.

Limit idling and switch off equipment when not in use. Vehicles and machinery Noise; Social Implement systematic maintenance of all forms of equipment and vehicles to minimise noise. Introduce a mechanism whereby complaints from stakeholders can be received and Complaints responded to. Prior to any activities being undertaken on any property entailed in the Prospecting Right Social Application, TIH must be in possession of a landowners agreement with South 32 / Agreements Hotazel Manganese Mines Adhere to agreements made with landowners. Health and safety Ensure that operations are in line with the requirements of the MHSA and Regulations.

5. Financial Provision

a) Determination of the amount of Financial Provision

Section 24(P)(1) of NEMA states that an Applicant for an environmental authorisation relating to mining or related activities on a mining area must make the prescribed financial provision for the rehabilitation, management and closure of environmental impacts, before the Minister responsible for mineral resources issues the environmental authorisation.

In order to ensure that the Applicant provides sufficient funds for the total quantum to cover the rehabilitation, management and remediation of negative residual environmental impacts, the quantum for closure-related financial provision in terms of Regulation 4 of the NEMA Regulations on Financial Provision (GNR1147 of 2014) has been determined.

i) Describe the closure objectives and the extent to which they have been aligned to the baseline environment described under the Regulation

CLOSURE OBJECTIVES EXTENT TO WHICH ALIGNED TO BASELINE ENVIRONMENT  The topography of rehabilitated drill sites will be shaped to be fee draining to represent the baseline state. Developing a landform that is  Natural revegetation will likely occur. free draining, with established,  Disturbed areas must be inspected after a growing season has self-sustaining vegetation passed and should natural revegetation prove unsuccessful areas must be revegetated using indigenous vegetation species.  Alien vegetation must be removed. Rehabilitate and return the drill  Natural revegetation will likely occur. hole areas to a capability that is  Disturbed areas must be inspected after a growing season has in line with the surrounding passed and should natural revegetation prove unsuccessful areas landscape. must be revegetated using indigenous vegetation species.

Rehabilitated areas do not pose a  Backfilling of any excavations safety hazard to humans and  No temporary infrastructure is to be left on-site. animals.  All waste will be removed.

The Closure Plan has been prepared which further details the closure objectives, strategy, measures and relinquishment criteria; refer to Appendix 4.

ii) Confirm specifically that the environmental objectives in relation to closure have been consulted with landowner and interested and affected parties

No detailed comments on rehabilitation have been received, only a request that consideration to rehabilitation be taken and that the details be provided.

iii) Provide a rehabilitation plan that describes and shows the scale and aerial extent of the main mining activities, including the anticipated mining area at the time of closure

The Closure Plan (Appendix 4) includes a rehabilitation plan.

iv) Explain why it can be confirmed that the rehabilitation plan is compatible with the closure objectives

The rehabilitation measures in the Closure Plan (Appendix 4) were compiled to meet the specific closure objectives as described in Section 5(a)(ii) above.

v) Calculate and state the quantum of the financial provision required to manage and rehabilitate the environment in accordance with the applicable guideline

The Guideline for Evaluation of the Quantum for Closure-Related Financial Provision compiled by the then Department of Minerals and Energy (DME) (now DMR) was used to inform the itemised breakdown. The guideline rates were however adjusted using contractor rates to provide actual costs (contractor rates) for decommissioning and rehabilitation. The rates utilised are based on contractor rates which have been escalated by CPI of 5.26% for 2017. Refer to Section 5(a)(v) in the EMP - Part B of this document for further information.

From the methodology for calculation of Financial Provision for a new development in the draft financial provisioning regulations (GNR1228 of 2017), the costing for final rehabilitation, decommissioning and mine closure, must reflect the total cost to remediate disturbances that will occur in Year O and must reflect actual market related costs based on prevailing rates exclusive of VAT. The costing for residual environmental impacts which will occur in the future must reflect the Net Present Value (NPV) based on prevailing rates of future residual environmental impacts due to disturbance of Year O. This is the Year O cost for residual environmental impacts. Total 1 for final rehabilitation and Total 2 for residual environmental impacts which may occur in the future are then added to obtain the Total Financial Provision.

Identification of areas of disturbance - areas, volumes and lengths of possible disturbances and developments and each applicable closure component were identified and calculated using the proposed invasive prospecting plan. The closure plan currently includes the cost for the rehabilitation of the following:  15 drill pads (10m x 10m each, 1500 m2 in total)  Contractor laydown (4000 m2)  Access tracks – existing access tracks will be used where possible but provision is made for the rehabilitation of a further 150m x 2m of general gravel tracks (300 m2)

The total financial provision for the invasive prospecting activities proposed for the TIH PRA, is therefore R 23,331 (value as per date of assessment - 2018). This amount comprises the financial provision for

decommissioning and rehabilitation as well as the remediation of latent or residual environmental impacts. Refer to the Closure Plan (Appendix 4) for further detail.

According to the requirements of GN1147, 2015, this total financial provision forecast over a period of ten years forthwith (escalated by an estimated CPI of 6%), equals R 39 417, which must be provided by TIH. This amount is in accordance with the rehabilitation amount indicated in the cash flow provided in the Prospecting Works Programme.

vi) Confirm that the financial provision will be provided as determined

Financial provision will be provided for as determined through a financial vehicle as prescribed in the NEMA Financial Provision Regulations (GNR1147 of 2015) namely a financial guarantee alone or a financial guarantee for the financial provision for decommissioning and rehabilitation and a contribution to a trust fund to secure funds for remediation of latent or residual environmental impacts.

6. Mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon, including: a) Monitoring of impact management actions b) Monitoring and reporting frequency c) Responsible persons d) Time period for implementing impact management actions e) Mechanism for monitoring compliance

MONITORING AND REPORTING IMPACTS REQUIRING FUNCTIONAL REQUIREMENTS FOR ROLES AND RESPONSIBILITIES FREQUENCY AND TIME PERIODS SOURCE ACTIVITY MONITORING MONITORING FOR IMPLEMENTING IMPACT PROGRAMMES MANAGEMENT ACTIONS As no significant environmental or social impacts are expected to be Performance assessments of exerted as a result of the EMP in terms of the MPRDA To ensure compliance with the EMP Invasive prospecting the prospecting to be undertaken every two and to determine the continued activities - Phase 3 activities monitoring ECO years and environmental audits appropriateness and adequacy of drilling programmes have not of the EMP in terms of NEMA as the EMP been recommended. per the frequency stated in the Therefore, only Environmental Authorisation compliance with the EMP requires monitoring

a) Indicate the frequency of the submission of the performance assessment/ environmental audit report

MPRDA Regulation 55(1) (of the MPRDA Regulations GNR527 of 2004) stipulates the requirements for performance assessments of the EMP (in sub-regulation [3]) to be undertaken every two years, to ensure compliance with the EMP and to determine the continued appropriateness and adequacy of the EMP.

NEMA also makes provision for environmental audits of the EMP, as per Regulation 34 of the NEMA EIA Regulations (GNR982 of 2014), which must be conducted to determine whether the programme sufficiently provides for the avoidance, management and mitigation of environmental impacts. Regulation 35 of the NEMA EIA Regulations requires an Environmental Audit Report to be submitted to the Competent Authority at the frequency specified within the Environmental Authorisation. The Environmental Authorisation will also specify the frequency of updating the EMP and Closure Plan.

It is anticipated that the performance assessment report (as required by the MPRDA) and the Environmental Audit Report (as required by NEMA) will be submitted as a single report, at least once every two years. This report will meet the requirements of both sets of legislation.

7. Environmental Awareness Plan a) Manner in which the applicant intends to inform his or her employees of any environmental risk which may result from their work

All personnel (including permanent employees as well as contractors) will undergo environmental awareness training as per this Environmental Awareness Plan. Environmental awareness training will be conducted as part of induction prior to the commencement of work, and relevant aspects of the EMP should be extracted for use by contractors. The Environmental Awareness Plan also provides for periodic awareness training throughout operations. Adherence to the Environmental Awareness Plan as well as provision of periodic environmental awareness training will be monitored and enforced by the ECO throughout operations. The contents of the Environmental Awareness Plan are detailed below:

Objectives

 All personnel must be made aware of the environmental management requirements;  All personnel, as a minimum, will undergo general environmental awareness training, which will highlight the environmental responsibility of all personnel; and  Those personnel whose functions may have a significant impact on the environment will receive the appropriate specialised training, so that they may perform their designated tasks adequately.

Training Requirements

The agenda for the environmental awareness course must consist of the following:

 A definition of what the environment is;  Environmental rights;  Constitutional rights;  NEMA, and the rights of a whistle blower;  Why we must look after the environment;  How we should look after the environment;  Details of working areas;  The possible presence of subterranean archaeological and/or paleontological sites, features or artefacts, the penalties associated with the unlawful removal of these artefacts, as set out in the NHRA as well as of the chance finds procedure as detailed in Table 2;  Avoidance of streams, rivers and wetlands;  Management of biodiversity including: o The importance of biodiversity; o The different habitats in the area; o Threatened, protected or otherwise sensitive species of plants and animals that must be avoided (namely the Camel Thorn, Shepherds Tree, Ground Pangolin, African Wild Cat, Tawny Eagle, Secretary Bird, Rock Monitor, Giant Bullfrog, Horned Baboon Spider and the Starburst Baboon Spider); o The habitats that the teams must avoid; o Reasoning why species should not be harvested or used as firewood; o Speeding and the impacts on biodiversity; o Alien invasive species; o Incentives for reporting any instances of speeding, harvesting, hunting and trapping etc; o Avoidance (and not destruction) of feared species such as snakes; and o Contacts for snake removals;  Details regarding smoking and fires;  Management of petrol, oil and diesel;  Dust management;  Ablution facilities;  Waste management;  Traffic and road safety;  Emergency procedures and numbers; and  Appropriate manner of interacting with neighbouring landowners and communities.

Frequency of Training

All new employees, as well as contractors, will be expected to undergo environmental awareness training as part of their induction. This induction will occur within the first two weeks of employment.

This programme will include any required competencies associated with that employee’s environmental management role, and the means and timeframe by which this competency is meant to be achieved.

Adherence to this programme will be monitored. The employee will be required to successfully complete the programme. b) Manner in which risks will be dealt with in order to avoid pollution or the degradation of the environment

The EMP details commitments in order to avoid pollution or the degradation of the environment. Compliance with the EMP commitments will form part of the contractors’ contract. Employees will also be briefed regarding the EMP commitments prior to the commencement of operations. The ECO will monitor that the commitments are being adhered to by the contractors and employees.

8. Specific information required by the Competent Authority (among others, confirm that the financial provision will be reviewed annually)

The Applicant commits to reviewing the Financial Provision on an annual basis as per the requirements of Section 24(P)(3) of NEMA, which states that every holder must annually assess his or her environmental liability and, if circumstances so require, must adjust his or her financial provision to the satisfaction of the Minister responsible for mineral resources.

In addition the Applicant commits to conduct EMP performance assessments as required in terms of Regulation 55 of the MPRDA on a biennial basis and external environmental audits of the EMP and Environmental Authorisation as per the NEMA EIA Regulations, 2014 according to the frequency indicated in the Environmental Authorisation.

The Competent Authority has not requested any specific information to date.

APPENDIX 1.1

CVS OF ENVIRONMENTAL ASSESSMENT PRACTIONER

Jonathan van de Wouw – Principal Environmental Consultant; Project Manager

Present Appointment Principal Environmental Consultant; Project Manager

Period February 2008 - present

Nationality South African (English Speaking)

Highest Education BSc (Hons.) with distinction, Microbiology and Biotechnology, University of the Witwatersrand

Jonathan is a Principal Environmental Consultant with considerable experience executing and managing projects in the mining, industrial and waste management sectors, including: mine closure and rehabilitation planning and financial quantum evaluations, environmental considerations for mine residue planning, integrated waste and water management planning, environmental and social impact assessments and management planning and environmental compliance auditing. Jonathan has a detailed knowledge of environmental law and precedents, both locally and internationally.

Project History:

Mining Projects

• Koornfontein Mines 4-seam expansion project and EMP consolidation, Mpumalanga, South Africa • Shiva Uranium Dominion Reefs Uranium Mine EMP consolidation, North West Province, South Africa • Zanaga Iron Ore Mine Environmental opportunities and constraints report, Republic of Congo • Anglo American Platinum, EIA and EMP for the chromite recovery plant at Waterval Platinum Mine, North West Province, South Africa • Anglo American Platinum, EIA and EMP for tailings backfill project, Dishaba Mine, Limpopo Province, South Africa • Anglo American Platinum, EMP Consolidation for Amandelbult Mine, Limpopo Province, South Africa • Main Street 800 / Siyanda Resources, EIA, EMP and Water Use License Application (WULA) for the KaNgwane opencast anthracite mine, Mpumalanga Province, South Africa • HolGoun Energy / Canyon Springs Investments, EIA, EMP and WULA for the Canyon Springs opencast coal mine, Mpumalanga Province, South Africa • Mbila Resources, EIA, EMP and WULA for the Mbila and Msebe opencast and underground anthracite mines, KwaZulu-Natal Province, South Africa

• Samancor Chrome, EIA, EMP and WULA for the Scheiding opencast chrome mine, Limpopo Province, South Africa • African Exploration Mining and Finance Corporation, EIA, EMP and WULA for the T-Project Colliery, Mpumalanga, South Africa • ESIA for the Vale Fertil Lucunga opencast phosphate mine, Zaire Province, Angola • ESIA for the Mongo Tando Limited Cacata opencast phosphate mine, Cabina Province, Angola • Integrated Waste and Water Management design, geochemical characterisation, liner selection and WULA for the Samancor Chrome Haakdoorndrift opencast Chrome Mine, Limpopo • Residue management plan, barrier selection and geochemical classification for the Vale Fertil phosphate calcination plant, Angola • Water Use License Application and Integrated Waste and Water Management Plan for the Continental Coal Africa opencast coal mine, Mpumalanga, South Africa • Bulk water supply / reconnaissance studies for the proposed HolGoun Mining – Springbok Flats projects • Internal guideline for managing cross-discipline EMP amendment projects for Anglo American Platinum • Environmental sensitivity analysis and risk assessment for Steamboat Resources graphite project situated in the Limpopo Province • Water Use License compliance audit for the Modikwa Platinum Mine, Limpopo Province

Due Diligence and Risk Assessments

• High level review of environmental preliminary feasibility study for proposed Sekoko Coal, Waterberg Coal Project, Limpopo Province, South Africa • High level environmental risk assessment of the Duyker Eiland phosphate prospect, St. Helena Bay, Western Cape Province, South Africa • Waste and water management component of a due diligence exercise for a proposed manganese mine and smelter plant in the Northern and Eastern Cape Provinces, South Africa • Environmental risk assessment and gap analysis for the proposed Siyanda Resources, KaNgwane Prospect (local legislation and Equator Principles) • Environmental risk assessment and gap analysis for the proposed Mbila Anthracite Project (local legislation and Equator Principles) • Environmental due diligence exercise for the Ikwezi Mining – Ntendeka Colliery, KwaZulu-Natal, South Africa • Project Ice environmental due diligence exercise for coal mining prospect in Mpumalanga, South Africa • Environmental risks, constraints and opportunities report for the proposed increased base load capacity of the Kelvin Power Station

Mine Closure Planning

• 2009 – 2015 annual financial liability auditing, review and update for the Shiva Uranium, Dominion Reefs Uranium Mine, North West Province, South Africa • Preparation of a preliminary closure plan for the Bafokeng Rasimone Platinum Mine, North West Province

• Calculation of the updated quantum for closure-related financial provision of the Ntshovelo Resources, Vlakvarkfontein Colliery, Mpumalanga Province • Participation in the development of a care and maintenance programme and closure strategy for the Eskom – Majuba Colliery, KwaZulu-Natal • Quantum for closure-related financial provision calculations and closure plans for the proposed Koornfontein Coal Mine 4-seam expansion, Scheiding Chrome Mine, Canyon Springs Coal Mine, T- Project Colliery, Mbila and Msebe Anthracite Mines • Care and maintenance programmes and closure liability assessments for the Samancor Chrome Buffels and Lannex Projects • Determination of the quantum for rehabilitation-related financial provision for prospecting-related activities at the Bafokeng Rasimone Platinum Mine, Samancor Chrome eastern and western limb prospecting sites (nine sites) • Review and update of the quantum for closure-related financial provision and alignment in terms of the NEM: Financial Provision Regulations for Modikwa Platinum Mine, Limpopo Province.

Waste Management Facilities

• Waste Management License Application and Waste Management Planning for temporary hazardous and general waste management facilities at four Rand Water Pump Stations, Gauteng Province • Groundwater monitoring and environmental compliance auditing for the Ekurhuleni Metropolitan Municipality operational (five) and closed (eight) landfill sites, Gauteng, South Africa • Ongoing groundwater monitoring and trend analysis at the Interwaste FG Landfill Site (Gauteng) and Klinkerstene Waste Park (Mpumalanga), South Africa • Environmental compliance auditing for the Steve Tshwete Municipality, Middelburg Landfill Site, Mpumalanga, South Africa • Environmental compliance auditing for Interwaste Environmental Solutions (eleven sites across South Africa) • Waste Management License audit, review and alignment update for Modikwa Platinum Mine • Environmental Compliance Officer inspection and ongoing review for the Interwaste Klinkerstene Waste Park • Hydrocensus and groundwater impact assessment for the Interwaste FG Landfill Site, Gauteng

Industrial Facilities

• Environmental Authorisation for the dangerous goods handling and storage facility at the Imperial Cargo Solutions, Garfield Road Depot, Gauteng • Legal review and recommendations for the Freightmax Depot hazardous goods handling facility, Germiston • Environmental authorisation process for the Bio-2-Watt waste-to-energy plant, Bronkhorstspruit

Claire Kennedy – Civil and Environmental Engineer

Present Appointment Environmental Consultant - Prime Resources (Pty) Ltd

Period July 2018 – Present

Date of birth 11 December 1988

Nationality South African & British

Education BSc (Eng) Civil, University of Cape Town 2011 Msc Environmental Engineering, University of Strathclyde

Languages Afrikaans and English

Synopsis Claire Kennedy is a civil and environmental engineer that has 4years work experience in design of components of water infrastructure projects including structural design and stability analysis . She also has experience in water use and waste licence applications for a multitude of facilities from mines, to waste disposal sites and stream crossings.

Professional History Candidate Civil Engineer at Department of Water and Sanitation from January 2012 – August 2016. She worked in the directorate Dam Design conducting designs and drawings for components of water infrastructure projects. Claire was part of the engineering review panel reviewing water use and waste licences submitted to the Department from 2012 to 2016.

Current Projects and Project History

Water Quality Assessments

 Water quality monitoring result assessment and report at Interwaste, Klinkerstene Landfill, South Africa

Environmental Authorisation Processes and Public Participation

 Basic Assessment, Prospecting Right, Tawana Investment Holdings (Pty) Ltd, Northern Cape, South Africa

 Environmental Authorisation Application, Gold One , Modder East Operations, South Africa

Mine Closure Planning and Liability and Performance Assessments

 Assessment of the Quantum for Closure-Related Financial Provision for the Sebilo Manganese Mine, Northern Cape, South Africa

Itumeleng Morosele – Environmental Scientist | GIS Technician

Present Appointment Environmental Scientist, Prime Resources (Pty) Ltd

Period March 2018 - Present

Nationality South African

Education BSc (Hons.) Geography with distinction, University of Johannesburg

BSc Life and Environmental Sciences, University of Johannesburg

Synopsis

Itumeleng is an environmental scientist with experience in Geographic Information Systems (GIS). She has been involved with conducting environmental compliance audits, as well as assisting with Environmental Authorisation and Water Use Licence Applications, Due Diligence reporting, and Financial Liability Assessments associated with mine closure and rehabilitation.

Current Projects and Project History

Waste Management and Compliance Auditing

• Groundwater Monitoring and Environmental Compliance Auditing, Interwaste F.G. Landfill Site, Gauteng, South Africa

Water Quality Assessments

• Water quality monitoring at Interwaste, Klinkerstene Landfill, South Africa

• Water quality monitoring at Interwaste, FG Landfill, South Africa

Environmental Authorisation Processes and Public Participation

 Basic Assessment, Prospecting Right, Tawana Investment Holdings (Pty) Ltd, Northern Cape, South Africa

Water Use Licensing

 Water Use Licence Application and Integrated Waste and Water Management Plan for the proposed Cons Modder Gold Mine, Gauteng Province, South Africa

 Water Use Licence Application and Integrated Waste and Water Management Plan for the proposed Ventersburg Gold Mine, Free State, South Africa

Due Diligence

• Review of Snowden Maamba Colliery project, Zambia

Mine Closure Planning and Liability and Performance Assessments

• Rehabilitation Plan for the proposed Cons Modder Gold Mine, Gauteng, South Africa

• Closure Plans and Annual assessment of the Quantum for Closure-Related Financial Provision for the Modikwa Platinum Mine, Limpopo, South Africa

• Assessment of the Quantum for Closure-Related Financial Provision for the Sebilo Manganese Mine, Northern Cape, South Africa

GIS (Proficiency with Esri ArcGIS software 10.1 – 10.5)

• Conversion of CAD files into GIS readable formats for various projects

• Performing different spatial analyses available in the ArcGIS package for the mapping of natural and man-made features including mine layouts, underground mine plans, farm portions and environmental information for projects listed above

• Experience with the SANBI BGIS database

2 APPENDIX 1.2

PRIME RESOURCES COMPANY PROFILE

COMPANY PROFILE

Prime Resources (Pty) Ltd is a medium-sized group of consulting environmental engineers and scientists serving clients across a wide range of industries, although the majority of our project work is based around natural resources, waste and mining.

The company was established in Johannesburg in 2003. Our head offices are located in Parktown North, Johannesburg, South Africa.

Prime Resources employs a talented and innovative group of professional people. We also have an extensive network of specialist sub-contractors who, together with our team, provide specialist environmental and civil design services. We provide consulting services and solutions to clients in a wide range of fields including:

 Project Management and implementation of  Geographic Information Systems (GIS) environmental solutions services

 Environmental Social Impact Assessments  Environmental / civil / geotechnical (ESIA) and Environmental Management engineering solutions Programmes (EMPr)  Geotechnical and tailings dam assessments  Public consultation and engagement with  Feasibility studies Interested and Affected Parties (IAPs)  Environmental advisors on purchase and  Water Use Licence Applications (WULA) sale transactions – Independent Technical  Waste management strategies and licensing Advisors

 Mining Right Applications  Environmental and social due diligence and risk assessments both in terms of national  Mine closure and rehabilitation planning legislation and international best practice  Social and Labour Plans (SLP)  Advising on compliance with international best  Environmental and social compliance auditing practice, most importantly the Equator and performance assessments Principles, IFC Performance Standards, and World Bank EHS Guidelines

KEY STAFF AND QUALIFICATIONS

PROFESSIONAL STAFF ROLE QUALIFICATIONS Peter Theron Company Director Professional Engineer (Pr. 950329) Environmental Engineer BSc Eng. (Civil) Project Manager GDE Environmental Engineering, Tailings & Geotechnical Jonathan van de Wouw Project Manager BSc (Hons) Microbiology and Biotechnology Principal Environmental Scientist Gené Main Project Manager Pr. Sci. Nat. (Environmental Science) Principal Environmental MSc Botany Scientist BSc (Hons) Environmental Science Stephan Geyer Civil Engineer BSc Eng. (Civil) Dr Bronwyn Grover Environmental Scientist PhD Environmental Analytical Chemistry Geochemistry BSc Geology and Chemistry Claire Kennedy Civil and Environmental BSc Engineering (Civil) Engineer MSc (Environmental Engineering) Itumeleng Morosele Environmental Scientist BSc (Life and Environmental Sciences) BSc (Hons) Geography Fernanda Smook Office Manager Business Management courses

ASSOCIATES: PROFESSIONAL STAFF ROLE QUALIFICATIONS Romy Antrobus-Wuth Environmental Scientist MSc Conservation Biogeography BSc (Hons) Environmental Science Niel Scheepers Civil Engineering B Tech (Civil) Technician Dr Walter Fourie Principal Chemical Ph.D. Environmental Engineering Engineer B Eng (Chemical) Engineering Johan Fourie Principal Geochemist Pr. Sci. Nat. (Geological Sciences) MSc Geohydrology BSc Geology and Geochemistry

PROJECT EXPERIENCE

Environmental aspects include due diligence and independent technical reviews; pre-feasibility and baseline studies; Environmental and Social Impact Assessments (ESIAs) and associated specialist environmental impact studies; Environmental Management Plans / Programmes (EMPs/EMPrs) and associated reporting including Environmental Awareness Plans, Emergency Preparedness and Response Plans and Closure and Rehabilitation Plans; compliance auditing and performance assessments. Social aspects include Social Impact Assessments (SIAs); public consultation processes; the compilation of Resettlement Action Plans (RAPs); Social and Labour Plans (SLPs); and Public Consultation and Disclosure Plans (PCDPs). Technical aspects include the technical review and design of mine waste facilities as well as geotechnical investigations.

We are further experienced with international best practice, most notably the Equator Principles, IFC Performance Standards, and World Bank Environmental, Health and Safety Guidelines.

Previous major projects, carried out since 2009, are summarised below. Additional project details are available upon request.

INTERNATIONAL PROJECTS

 Araguaia Nickel Project, Brazil . Detailed design of slag disposal facility for Feasibility Study . Site geotechnical investigations . Detailed design of cooling water dam and river abstraction pipeline  Lindi Jumbo Graphite Project, Tanzania . Surface geotechnical study . Site selection for tailings storage facility . Pre-Feasibility Study design for tailings storage facility . Definitive Feasibility Study design for tailings storage facility . Terracing design for plant infrastructure  Cacata Phosphate Project, Angola . Environmental licensing according to Angolan legislative requirements . Environmental and Social Impact Assessment process according to international best practice  Ganajur Gold Project, India . Review of environmental aspects for Feasibility Study . Surface geotechnical study . Site selection for tailings storage facility . Feasibility Study design for tailings storage facility  Salamanca Uranium Project, Spain . Feasibility Study design for lined surface waste disposal facilities . Feasibility Study design and detailing for an in-pit waste disposal liner system  Mpokoto Gold Project, Democratic Republic of Congo . Surface geotechnical study . Site selection for tailings storage facility . Pre-Feasibility Study design for tailings storage facility . Bankable Feasibility Study design for tailings storage facility . Terracing design for plant infrastructure

 Lucunga Phosphate Project, Angola . Environmental licensing according to Angolan legislative requirements  Veduga Gold Project, Russia . Technical review of environmental and mine waste disposal aspects  Ghaghoo Diamond Project, Botswana . Independent technical review of the environmental, social and permitting documentation according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines . Preparation of an Equator Principles environmental and social action plan  Debswana Diamond Projects, Botswana . Peer review of environmental and mine waste aspects for Pre-Feasibility Studies  Liqhobong Diamond Mine, Lesotho . Independent technical review of the environmental and social aspects, permitting, water management and residue management - according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines  Koidu Diamond Project, Sierra Leone . Review of environmental, social, groundwater and tailings documentation for compliance with Equator Principles, IFC Performance Standards and EHS Guidelines  Araguaia Nickel Project, Brazil . Environmental and social baseline report Pre-Feasibility Study . Preliminary design of slag disposal facility for Pre-Feasibility Study  Maminskoye Gold Project, Central Urals, Russia . Environmental and social audit of the Pre-Feasibility Study  Cabinda Phosphate Project, Angola . Social impact plan and Environmental Management Plan for prospecting . Environmental and social baseline report towards the Definitive Feasibility Study stage  Owere Gold Project, Ghana . Independent technical review of the environmental, social and permitting documentation  Kinsevere Copper Project, Democratic Republic of Congo . Review of tailings dam risks and opportunities for compliance with Equator Principles  Kipoi Copper Mine, Democratic Republic of Congo . Review of environmental, social, heap leach and tailings of the Kipoi Central RDFS operations, Tiger Resources . Independent technical review of the environmental, social and permitting documentation according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines  Zanaga Iron Ore Project, Democratic Republic of Congo . Environmental and social section of the order of magnitude study  Pakrut Gold Mine, Tajikistan . Social and Environmental Impact Assessment process, baseline evaluations according to international best practice requirements  Lece Gold Mine, Serbia . Tailings technical review and concept design work for a tailings retreatment project  Langer Heinrich Uranium Mine, Namibia . Independent technical review of the tailings storage facility and storage strategy

 Maamba Coal Mine, Zambia . Independent technical review of the environmental, social, permitting, discard and water management according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines  North River Resources Lead Zinc, Namibia . High level review of the environmental and social documentation according to Namibian legislative requirements  Minas Moatize Coal Expansion Project, Mozambique . Independent technical review and due diligence of mine residue facilities (slurry and discard), water management, environmental and social aspects  Aquarius Shipping International, Warehouse and Container Depot, Beira, Mozambique . Geotechnical investigation  Passendro Gold Project, Democratic Republic of Congo . Independent peer review for tailings storage facility  Banro Twangiza Project, Democratic Republic of Congo . Independent technical review of the environmental, social, tailings and water management aspects according to the Equator Principles

NATIONAL PROJECTS

Projects are all conducted in terms of relevant National legislation, including the National Environmental Management Act, No. 107 of 1998 (NEMA); the Mineral and Petroleum Resources Development Act, No. 28 of 2002 (MPRDA); the National Environmental Management: Waste Act, No. 59 of 2008; the National Water Act, No. 36 of 1998 etc.

 Newshelf, Gedex Project, Gauteng Province, South Africa . Social and Labour Plan . Environmental Impact Assessment and Environmental Management Programme . General Authorisation  Imperial Cargo Solutions, Flammable Goods Store, Gauteng Province, South Africa . Environmental Impact Assessment and Environmental Management Programme  Gold One Africa, Ventersburg Project, Free State Province, South Africa . Social and Labour Plan . Environmental Impact Assessment and Environmental Management Programme . Waste Management Licence . Water Use Licence Application . Atmospheric Emission Licence  WRE – EJV Gold Project, Free State, South Africa . Site selection for tailings storage facility . Pre-Feasibility Study design for tailings storage facility  Rietvlei Mine, Mpumalanga, South Africa . Technical input on discard dump and pollution control dam design  Holfontein Gold Project, Gauteng, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application and water dam designs

 New Kleinfontein Goldmine Modder East Operations, Gauteng, South Africa . Original Environmental Impact Assessment and Environmental Management Programme and amendments thereto . Basic Assessment for a return water dam and Environmental Management Programme amendment . Water Use Licence Application and amendments thereto . Atmospheric Emissions Licence application . Rehabilitation Strategy and Implementation Programme . Social and Labour Plan revision . Equator Principles and IFC compliance review . Alien invasive vegetation eradication plan . Emergency preparedness and response plan . Stormwater management plan  Interwaste, Gauteng, Mpumalanga, Western Cape, South Africa . Environmental compliance auditing at various landfill sites and depots . Water quality monitoring and reporting . External environmental control officer for the Klinkerstene Landfill Site, Environmental Authorisation and construction Environmental Management Programme compliance auditing  Ekurhuleni Metropolitan Municipality, Gauteng, South Africa . Environmental compliance auditing at various landfill sites and transfer stations . Permit amendment application . Water quality monitoring and reporting  Royal Bafokeng Platinum, North West, South Africa . Annual assessment of the quantum for rehabilitation-related financial provision for Prospecting Rights  SamancorCr, Limpopo, South Africa . Performance assessments and assessment of the quantum for rehabilitation-related financial provision for various Prospecting Rights  Modikwa Platinum Mine, Mpumalanga, South Africa . Water Use Licence compliance audit and action plan . Annual assessment of the quantum for rehabilitation-related financial provision . Annual Rehabilitation Plan . Final Rehabilitation Decommissioning and Closure Plan . Environmental Risk Assessment . Waste Management Licence Amendment  Coal of Africa, Vele Colliery, Limpopo, South Africa . Independent technical review of the environmental, social, tailings and water management aspects according to the Equator Principles and IFC Performance Standards  Canyon Springs Coal Mine, Mpumalanga, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application . Waste Management Licence application . High level bulk water supply assessment

. External environmental control officer, construction Environmental Management Programme compliance auditing . Water Use Licence execution  Elsmore Pafuri Camp, Limpopo, South Africa . Environmental Authorisation amendment  Elsmore Luvuvhu Camp, Limpopo, South Africa . External environmental control officer, Environmental Authorisation and construction Environmental Management Programme compliance auditing  Bio-2-Watt Biogas Plant, Gauteng, South Africa . External environmental control officer, construction Environmental Management Programme compliance auditing . Technical advice  SamancorCr, Scheiding Chrome Mine, Limpopo, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application  African Exploration Mining Finance Corporation, T-Project Colliery, Mpumalanga, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application . Closure and rehabilitation plan . Bulk water supply assessment . Equator Principles compliance review and gap analysis . Stakeholder engagement plan and grievance mechanism . Emergency preparedness and response plan . Alien invasive vegetation eradication plan . Water Use Licence execution  Mbila Anthracite Mine, KwaZulu-Natal, South Africa . Basic Assessment and Environmental Management Programme . Water Use Licence amendment  Msebe Opencast Anthracite Mine, KwaZulu-Natal, South Africa . Environmental Impact Assessment and Environmental Management Programme  Tjate Platinum Mine, Limpopo, South Africa . Environmental and social baseline report . Baseline environmental assessments and project management of the environmental inputs into the Pre-Feasibility Study . Social and Labour Plan update . Site selection and preliminary design for a tailings storage facility  Tharisa Platinum Mine, North West, South Africa . Due diligence for independent technical engineers report (ITE), review of the environmental, social and tailings documentation and reporting and annual updates thereto  Anglo American Platinum Limited, Rustenburg Platinum Mines, Limpopo, South Africa . The consolidation of existing approved Environmental Management Programmes and the alignment thereof with the requirements of the MPRDA

 Kalagadi Manganese Mine, Northern Cape, South Africa . Review of environmental documentation to determine compliance with Equator Principles and international best practice, on behalf of Standard Bank  African Exploration Mining Finance Corporation, Vlakvarkfontein Colliery, Mpumalanga, South Africa . Water Use Licence Application . Closure and rehabilitation plan . The technical design, 3D modelling and detailing of the conceptual backfill plan for an opencast pit . Compilation of an alien invasive vegetation eradication plan . Social and Labour Plan amendment . Basic Assessment and Environmental Management Programme for a haul/ access road and above ground diesel storage area  Western Bushveld Joint Venture Project 1, North West, South Africa . Review of environmental, hydrology and tailings dam documentation for compliance with Equator Principles, IFC Performance Standards and EHS Guidelines, on behalf of Standard Bank  Anglo American Platinum Limited, Amandelbult Chrome Recovery Plant, Limpopo, South Africa . Basic Assessment and Environmental Management Programme for a chrome recovery plant . Addendum to the existing Environmental Impact Assessment and Environmental Management Programme in terms of the MPRDA  Steenkampskraal Project, Western Cape, South Africa . Review of environmental, hydrology and tailings dam documentation for compliance for PEA Canadian NI 43-101 filing  Malelane Iron Ore Project, Mpumalanga, South Africa . Preliminary environmental and social baseline studies  Rand Uranium, Reclamation of Lindum Tailings Storage Facility, Gauteng, South Africa . Environmental Impact Assessment and Environmental Management Programme addendum  Hlabisa Coal, KwaZulu-Natal, South Africa . High-level, desktop environmental evaluation (sensitivity analysis)  Anglo American Platinum Limited, Kilken Tailings, Limpopo, South Africa . Independent technical review of the environmental and social aspects permitting and water management according to the Equator Principles, IFC Performance Standards, and World Bank EHS Guidelines  Mooiplaats Platinum Mine, Limpopo, South Africa . Social and Labour Plan  Rietkuil Coal Project, Mpumalanga, South Africa . Independent technical review and due diligence of environmental documentation  Evander Gold Mine, Mpumalanga, South Africa . Review of environmental, social and tailings dam documentation for compliance with South African Environmental and Social Standards

 Holgoun Energy, Springbok Flats Coal Fields, Limpopo, South Africa . Competent Persons Report . High level bulk water supply assessment . High level environmental review for the Western Complex Project  Kudumane Manganese Mine, Northern Cape, South Africa . Independent technical review of the environmental and social aspects  ZYL Limited, KaNgwane Anthracite Mine, Mpumalanga, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence Application . Closure and rehabilitation plan  ZYL Limited, Southern Anthracite Project, Mpumalanga, South Africa . Environmental Impact Assessment and Environmental Management Programme  DRDGold, Blyvooruitzicht Mining Operation, Gauteng, South Africa . High level environmental review  Lonmin, Akanani Platinum Project, Limpopo, South Africa . Pre-Feasibility Study, review of the environmental and social documentation and reporting of high level risks and opportunities  Anglo American Platinum Limited, Dishaba Mine, Limpopo, South Africa . Environmental Impact Assessment and Environmental Management Programme . Water Use Licence amendment  Majuba Colliery, Mpumalanga, South Africa . Closure and rehabilitation plan  Rietfontein Prospect, Limpopo, South Africa . Geotechnical investigation . Environmental Management Programme amendment  Namaqualand Mines, Northern Cape, South Africa . Independent technical review of the environmental, social and tailings aspects according to the Equator Principles and IFC Performance Standards  Leeuwfontein and Blinkpan project areas, Mpumalanga, South Africa . Geotechnical investigation  Bafokeng Rasimone Platinum Mine, North West, South Africa . Preliminary closure and rehabilitation plan  Umtu (Manganese) Mine Project, Northern Cape, South Africa . Independent technical review of the environmental and social aspects according to the Equator Principles and IFC Performance Standards  Koornfontein Mines, Mpumalanga, South Africa . Environmental Impact Assessments and Environmental Management Programmes for the separate sections of the mining operations . Environmental Impact Assessments and Environmental Management Programmes amendment for the Leeuwfontein Block . Water Use Licence Applications for the separate sections of the mining operations . Identification of a suitable host area and conditions for resettlement and the compilation of the Resettlement Action Plan and agreement on timeframes and responsibilities

 Bafokeng Rasimone Platinum Mine, North West, South Africa . Due diligence on environmental and tailings dam documentation for listing purposes on the JSE stock exchange . Competent Persons Report including environmental, social, hydrological and tailings aspects  Simmer & Jack Limited, Elandsdrift Heap Leach Pad, Mpumalanga, South Africa . Geotechnical and slope stability investigation . As built drawings for the Elandsdrift heap leach pad  Simmer & Jack Mines Limited Transvaal Gold Mining Estates, Mpumalanga, South Africa . Design, quality control/assurance manual, site support and part time project management for the design and construction of a heap leach dam extension  Afrikander Leases Gold Mine, North West, South Africa . Environmental Impact Assessment and Environmental Management Programme amendment  Grass Valley Platinum Project, Limpopo, South Africa . Update the environmental aspects in the Pre-Feasibility Study report  Lonmin PLC Western Platinum Mine, North West, South Africa . Basic Assessment and Environmental Management Programme for a hazardous waste storage facility . Waste Management Licence application  Samancor Chrome – Ferrometals, Emalahleni, Mpumalanga . EMP performance assessment for decommissioning of the IC3 facility . Slag dump waste management licence compliance audit . Water use license compliance audit  Pan African Mineral Development Corporation . Prospecting Right Application . Environmental Authorisation process incl. BAR, EMP and closure plan  Freightmax, a division of Imperial Group, Bayhead, KwaZulu-Natal . Environmental Authorisation for dangerous goods storage facility, incl. EIR and EMP

APPENDIX 2.1

LANDOWNER NOTIFICATION Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

South32 Hotazel Manganese Mines

1 Peperboom Avenue

Hotazel

8490

Dear Sir/Madam

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground probing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

Tawana Investment Holdings (Pty) Ltd applied for the rights to prospect for Manganese and Iron Ore, in terms of section 16 of the Minerals and Petroleum Development Act, 2002 (Act No. 28 of 2002) (MPRDA) as amended.

The project is located within the Magisterial District of Kuruman under the jurisdiction of the John Taolo Gaetsewe District Municipality. The Prospecting area is approximately 1km from the town of Hotazel and the prospecting activities are planned on the following areas: A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel. The overall area applied for is approximately 169.47 Ha in size.

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Parties wishing to register as interested and affected Parties (“I & AP’s”) who wish to participate by contributing comments or require additional information, should please register or submit their correspondence in writing, no later than thirty (30) days after the issue of this notice (28 June 2018). All relevant comments received within this time will be incorporated into the EIA process, which will be made available to all registered I & AP’s for review.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

APPENDIX 2.2

PUBLIC NOTICES

Public notice at KLK Landbou - Hotazel Public notice at Hotazel Library Public notice at OK Hotazel APPENDIX 2.3

MEDIA-NOTICE

APPENDIX 2.4

LETTERS TO AUTHORITIES AND ORGANS OF STATE APPENDIX

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

The Manager

Department of Agriculture

Private Bag x 5018

Kimberley

8300

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel 280. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

DEPT. OF AGRICULTURE AND RURAL DEVELOPMENT

P/Bag x 1508

Kuruman

8460

Att: Rre Tonyane

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

The Manager

Department of Environmental Affairs

Private Bag x 6102

Kimberley

8300

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel 280. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

Department of Mineral Resources

65 Phakamile Mabija Road

Kimberley

8300

Att: P Swart

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

______

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

The Manager

Department of Public Works

Private Bag x 5002

Kimberley

8300

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel 280. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

The Manager

Department of Rural Development and Land Reform

Private Bag x 2458

Kimberley

8300

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel 280. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

DEPT. OF WATER AND SANITATION

PRIVATE BAG X6101

KIMBERLEY

8300

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel 280. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

The Manager

ESKOM

P.O.Box 606

Kimberley

8300

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel 280. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

John Taolo Gaetsewe District Municipality

4 Federale Mynbou Str

Kuruman

8460

Att: Rre K Teise

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

______

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

The Manager

SANRAL

Private Bag x 19

Bellville

7535

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel 280. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

The Manager

South African Heritage Resources Agency

Head Office

111 Harrington Street

Cape Town

8001

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel 280. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

04 June , 2018

Operations building

Hotazel Train Station

Hotazel

8490

Att: Frank Olyn

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground probing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

May 30, 2018

The Manager

Transnet

P.O.Box 1389

Bloemfontein

9300

Notice is hereby given in terms of Section 16(4) of the Mineral and Petroleum Resources, Development Act, 2002, (Act No. 28 of 2002) of intent to carry out the following activity:

Activity:

 Prospecting activities for Manganese and Iron Ore in the form of a desktop studies and ground trothing; Percussion and Diamond Core drilling.

Place:

 A piece of portion 1 of York 279 and a piece of portion 1 of Hotazel 280. The overall area applied for is approximately 169.47 Ha in size.

Applicant: Tawana Investment Holdings (Pty) Ltd

You are hereby notified of the intent to prospect on the above mentioned properties in terms of:

 The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) as amended, and

Business Address: Contact Details: 11 Beyers Naude Drive Tel: +27(0) 10 010 0845 Montgomery Park Fax: +27(0) 86 664 5253 2195

 National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Application for Environmental Authorisation and water use licence to undertake the following activities:

 NEMA Government Notice 983, listing notice 1 Activity 20 and 27.

 NWA, section 21: Water Uses

Regulatory Authority: Department of Mineral Resources (DMR) and Department of Water and Sanitation (DWS), Kimberley, Northern Cape Province.

Yours sincerely,

Ms. Lindi Plaatjie [email protected]

2.5

IAP DATABASE

Name Department / Community / Property Designation

Ms Keemenao Julia Katong Ward Councillor Ward 4

Ms Seneo Seleka Joe Morolong Local Municipality Environmental Officer

Mr Kemothibile Phiri Director Planning and Development

Mr Klaas Teise John Taolo Gaetsewe District Municipality Director: Planning and Development Director of Environmental Policy, Planning Mrs van Olmen Phillips and Coordination Secretary to Director of Environmental Mr Archibald Jammer Northern Cape Provincial Department: Policy, Planning and Coordination Environment and Nature Conservation Production Scientist Grade A: District Ms Samantha De la Fontaine Ecologist Scientific Manager Gr B: Research and Ms Elsabe Swart Development Support Mr WVD Mothibi Head of Department Northern Cape Department: Agriculture, Land Reform and Rural Development Mr Leon Terblanche Director for Sustainable Development Department of Agriculture and Rural Mr Patrick Tonyana Regional Manager Development Mr Ntsundeni Ravhugoni Head of Mine Environmental Management Department of Mineral Resources (Mine Mr Pieter Swart Environmental Management)

Authorities Ms Raisibe Sekepane Environmental Manager

Mr Moses Mahunonyane Director Institutional Establishment Northern Cape Department of Water and Sanitation Assistant Director Lower Vaal Ms Lerato Mokhoantle (Environmental Manager) Mr Lenkoe Northern Cape Department: Co-operative Head of Department (Northern Cape) Governance, Human Settlements and Traditional Ms Lesego Mokoto Affairs Assistant

Khuthala Dlamini Land Use Officer Department of Agriculture, Fisheries and Forestry (DAFF): Land Use and Soil Management Thoko Buthelezi Admin Clerk to Land Use Officer

Ms Faizal Paulsen Department of Public Works Property Management

Ms Pabelo Mokale Land Claims Office of the Regional Land Claims

Mr Frank Olyn Transnet OPS Manager

Ms Nicole Abrahams SANRAL Environmental Coordinator

Mr Khahliso Makale Eskom Officer Land and Rights - Negotiations

Mr Dennis Chinasamy South 32 (Farm York 279 and Farm Hotazel 280) HSE Lead Principal: Mining & Property Rights Africa Mr Alex Mooya South 32 (Farm York 279 and Farm Hotazel 280) Region

Landowners Landowners Ms Sylvia Makoele South 32 (Farm York 279 and Farm Hotazel 280) HSE Lead and occupants and

Mr Jacobus Pretorius Private Adjacent Adjacent Landowners

Mr Danie Botes KLK Landbou BPK

Ms Tshifhiwa Nemakhavhani Kudumane Manganese Resources Nomadlozi Mashinini Legal Head & Company Secretary

Mr Eben Anthonissen representatives Agri Kuruman

NGO / Legal / Businesses GJ Hoon Chairman APPENDIX 2.6

MINUTES OF MEETING WITH LANDOWNER

APPENDIX 3

IMPACT ASSESSMENT

TAWAMA INVESTEMENT HOLDINGS (PTY) LIMITED

IMPACT ASSESSMENT FOR THE PROSPECTING RIGHT APPLICATION SUBMITTED OVER PORTIONS OF THE FARMS YORK 279 AND HOTAZEL 280 IN THE JOE MOROLONG LOCAL MUNICIPALITY IN THE NORTHERN CAPE PROVINCE

JULY 2018

PREPARED FOR:

Tawana Investment Holdings (Pty) Limited 11 Beyers Naude Drive, Motgomery Park, Johannesburg, 2129

TABLE OF CONTENTS

1. INTRODUCTION AND BACKGROUND ...... 1

1.1. Impact Assessment ...... 1 1.2. Impact Rating Methodology ...... 1 1.3. Cumulative Impacts ...... 2

2. DESCRIPTION AND ASSESSMENT OF POTENTIAL IMPACTS ...... 3

2.1. Air Quality ...... 3 2.2. Archaeology and Palaeontology ...... 3 2.3. Aquatic Ecology, Surface Water and Wetlands ...... 4 2.4. Groundwater ...... 4 2.5. Noise ...... 4 2.6. Social ...... 4 2.7. Soil ...... 5 2.8. Terrestrial Ecology ...... 5 2.9. Traffic ...... 6 2.10. Visual Aesthetics ...... 6 2.11. Cumulative Impacts ...... 8 2.11.1. Air Quality ...... 8 2.11.2. Aquatic Ecology, Surface Water and Wetlands...... 8 2.11.3. Groundwater ...... 8 2.11.4. Noise ...... 8 2.11.5. Social ...... 8 2.11.6. Soil ...... 8 2.11.7. Terrestrial Ecology ...... 8 2.11.8. Visual Aesthetics ...... 8

TABLES Table 1: Impact ratings of invasive prospecting activities (drilling activities) ...... 7

Project Name: Tawana Prospecting Rights Application i Report Title: Impact Assessment Project Number: 180995 Date: July 2018 1. INTRODUCTION AND BACKGROUND

The activities associated with the proposed project listed in terms of NEMA require that a Basic Assessment process is conducted. This document serves to inform the Basic Assessment and describes the impacts that the proposed prospecting activities described in the Prospecting Works Programme could potentially have on the receiving biophysical and socio-economic environment. The impacts will be rated using a standardised impact rating methodology (outlined in Section 1.2 below).

1.1. Impact Assessment

The potential impacts are described per receptor. The significance of these impacts is determined according to the methodology discussed in Section 1.2. Where mitigation measures are recommended in order to reduce the significance of a potential impact, these have been indicated. The tabulated impact assessments are further elaborated upon per receptor in Section 2.

1.2. Impact Rating Methodology

Below is an assessment of the nature, extent, duration, probability and significance of the identified environmental and social impacts of the project. The significance of both positive and negative potential impacts was determined through the evaluation of impact consequence and likelihood of occurrence.

The following risk assessment model was used for determination of the significance of impacts.

SIGNIFICANCE = (MAGNITUDE + DURATION + SCALE) X PROBABILITY

The maximum potential value for significance of an impact is 100 points. Environmental impacts can therefore be rated as high, medium or low significance on the following basis:

. High environmental significance 60 – 100 points . Medium environmental significance 30 – 59 points . Low environmental significance 0 – 29 points

Project Name: TIH Prospecting Right Application 1 Report Title: Impact Assessment Project number: 180995 Date: July 2018 MAGNITUDE (M) DURATION (D) 10 – Very high (or unknown) 5 – Permanent 8 – High 4 – Long-term (ceases at the end of operation) 6 – Moderate 3 – Medium-term (2-4 years) 4 – Low 2 – Short-term (0-1 years) 2 - Minor 1 – Immediate SCALE (S) PROBABILITY (P) 5 – International 5 – Definite (or unknown) 4 – National 4 – High probability 3 – Regional 3 – Medium probability 2 – Local 2 – Low probability 1 – Site 1 – Improbable 0 – None 0 – None

The significance of a particular impact which is reduced through the application of the recommended mitigation measures is indicated within square brackets.

1.3. Cumulative Impacts

This section ends with a qualitative assessment of cumulative impacts, defined as the potential contribution of the project to the overall existing impacts in the surrounding area.

Project Name: TIH Prospecting Right Application 2 Report Title: Impact Assessment Project number: 180995 Date: July 2018

2. DESCRIPTION AND ASSESSMENT OF POTENTIAL IMPACTS

2.1. Air Quality

The prospecting activities within the Prospecting Rights Area (PRA) will take place in the form of initial non-invasive prospecting activities, followed by invasive prospecting should the outcomes of the non-invasive activities warrant such. Should invasive measures be undertaken, activities will comprise exploratory drill hole areas, temporary driller’s laydown and possibly access tracks. These areas will be demarcated and the vegetation in these areas cleared if necessary. Clearing activities may result in dust caused by the earthmoving activities as well as wind erosion across bare areas that are not stabilised by alternate means such as wet suppression. The creation of dust may thus result in temporary nuisance and aesthetic impacts (i.e. reduced visibility and soiling of materials) in the immediate vicinity of the activity, specifically during periods of increased activity or high wind speeds.

 Due to the historic land use and disturbed nature of the site it is unlikely that large quantities of vegetation will be removed

 The impact of dust will be short in duration and limited in extent. The potential impact will cease once prospecting activities have been completed and once the disturbed areas are successfully revegetated.

 The potential impact can be mitigated by limiting areas to be cleared to the smallest extent possible and by implementing dust suppression measures such as wetting where dust plumes are noted.

 Due to the limited extent of the areas to be cleared, and that dust generated is likely to fall below the threshold as per the NEMAQA National Dust Control Regulation Standards for residential areas significance of the impact is anticipated to be Low prior to- and after the implementation of the recommended mitigation measures.

2.2. Archaeology and Palaeontology

The cultural and archaeological significance and importance of the TIH PRA area itself is considered negligible due to the existing transformed nature of the area and extent of disturbance due to past mining practises which would have either unearthed or destroyed any potential significant artefacts. In addition, no individual graves or graveyards are located within the PRA

 The potential impact is only applicable during vegetation clearing activities or minor earth- moving activities.

 The potential impact can be mitigated by ensuring contractors educate personnel on what potential artefacts may look like and by implementing a chance finds procedure to prevent damage to buried resources which may be of significance, in the unlikely event that they are unearthed.

 The significance of the potential impact on buried artefacts is Low prior to and after the Project Name: TIH Prospecting Right Application 3 Report Title: Impact Assessment Project number: 180995 Date: July 2018

implementation of the recommended mitigation measures.

2.3. Aquatic Ecology, Surface Water and Wetlands

There are no watercourses or wetlands within the PRA, however there may be some depressions or water within old excavations on site. None of the potential infill boreholes that may be developed will be in proximity to a watercourse or wetland.

Due to the above, and the fact that little surface runoff is generated in the water management area, no impacts on the surface water environment are foreseen, thus the potential impact on aquatic ecology is Low.

2.4. Groundwater

With the implementation of non-invasive prospecting no groundwater impacts are foreseen. With invasive prospecting there is potential for soil contamination that may lead to groundwater contamination through the event of hydrocarbon spills from machinery.

 Implementing spill prevention measures such as handling and storing hydrocarbons on impermeable surfaces

 Plastic lining sumps

 Adequately maintaining vehicles and machinery to prevent leaks

 Cleaning any spills immediately

The significance of the potential impact on groundwater is Low prior to and after the implementation of the recommended mitigation measures

2.5. Noise

Non-invasive prospecting will not lead to an increase in noise levels, however the use of vehicles on-site as well as operation of the drilling rig may represent a point source of nuisance noise wherever drilling activities are taking place, nonetheless invasive drilling will not generate noise in excess of the baseline conditions per SANS 10103:2008 for rural / semi-urban districts

 The potential impact on the ambient noise levels is expected to be limited in extent and ceasing upon completion of drilling activities.

 The potential impact can be mitigated by, maintaining vehicles and the drill rig in good working order.

 Due to the above, the significance of the impact of noise is anticipated to be Low prior to and after the implementation of the recommended mitigation measures.

2.6. Social

Although the site is situated in close proximity to residential areas, no social impacts are foreseen due to the nature of the prospecting activities.

Project Name: TIH Prospecting Right Application 4 Report Title: Impact Assessment Project number: 180995 Date: July 2018

 Introduce a mechanism whereby complaints from stakeholders can be received and responded to

 Measures described for noise and dust nuisance will limit social impacts

 Due to the above, the significance of social impact is anticipated to be Low prior to and after the implementation of the recommended mitigation measures.

2.7. Soil

Leaks from vehicles and machinery on site, inadequate hydrocarbon handling and storage, inadequate waste management and spills from ablutions may result in soil contamination. Soil compaction may also occur as a result of the movement of vehicles and the drill rig on site. These impacts have limited potential as the soil resources have been previously stripped during opencast mining activities

 The potential impact will cease once prospecting activities have been completed and vehicles and machinery are removed from the area.

 The potential impact can be mitigated by implementing spill prevention measures such as handling and storing hydrocarbons on impermeable surfaces, adequately maintaining vehicles and drill rigs to prevent leaks, cleaning any spills immediately, plastic lining of sumps to capture biodegradable drilling fluid, implementing adequate waste management practises, minimising areas to be disturbed by vehicle and drill rig movement, and ripping and profiling compacted soil.

 The significance of the impacts of soil contamination and soil compaction are considered to be Low prior to and after the implementation of the recommended mitigation measures.

2.8. Terrestrial Ecology

There are no Ecological Support Areas (ESAs) and Critical Biodiversity Areas (CBAs) present within the project area, thus none of the potential drill holes fall within these areas of conservation importance.

The land incorporated in the PRA area has been completely transformed as a result of historical mining activities with little natural vegetation, especially trees. It is mostly grass and shrub, thus site clearing and the removal of vegetation is unlikely to result in the loss indigenous plants and species of concern, however, compaction of soils by vehicles and the drill rig may result in a reduction in the capability for vegetation re-establishment in disturbed areas.

 The potential impact will cease once prospecting activities have been completed and the disturbed areas are successfully revegetated.

 This impact can be mitigated by including biodiversity aspects in environmental awareness training.

 Drill sites should be evaluated by the ECO prior to any clearing activities in order to determine the presence of any sensitive, protected or indigenous species and to advise permitting requirements in terms of NCNCA, NFA and NEMBA

Project Name: TIH Prospecting Right Application 5 Report Title: Impact Assessment Project number: 180995 Date: July 2018

 Avoid all plant species of conservation concern (in the unlikely event that they are present) by changing the location/ extent / spatial layout of sites accordingly prior to clearing

 This impact can be mitigated by avoiding the clearing of trees where possible, limiting areas to be cleared to the smallest extent possible, ripping and profiling compacted soil, and intervening by planting indigenous vegetation in disturbed areas should natural revegetation prove unsuccessful.

 Due to the current terrestrial ecology conditions and the limited extent of the areas to be cleared, the potential impact on floral habitat is considered to be of Low significance prior to- after the implementation of the recommended mitigation measures.

2.9. Traffic

A limited number of vehicles and machinery will be required for prospecting activities which are expected to stay on site for the duration of the drilling activities in each area and will have minimal interaction with the surrounding road network. Therefore, traffic related impacts as a result of the proposed prospecting activities are unforeseen.

2.10. Visual Aesthetics

Due to the historic land-use of the site and the temporary infrastructure required and the temporary nature of the activities no significant visual impacts are expected.

Project Name: TIH Prospecting Right Application 6 Report Title: Impact Assessment Project number: 180995 Date: July 2018

Table 1: Impact ratings of invasive prospecting activities (drilling activities)

SIGNIFICANCE

PROCESS IMPACT RATING VALUE SCALE (S) SCALE DURATION (D) DURATION MAGNITUDE (M) MAGNITUDE PROBABILITY (P) PROBABILITY Dust generated may result in nuisance 2 2 1 2 Low 10 impacts [2] [2] [1] [1] [Low] [5]

Damage to buried archaeological or 2 5 1 1 Low 8 Land clearing and minor palaeontological resources of significance [2] [5] [1] [1] [Low] [8] earth-moving activities

Loss of indigenous species and protected 6 5 1 2 Low 24 trees [2] [5] [1] [1] [Low] [8]

2 2 2 3 Low 18 Noise generated may result in nuisance [2] [2] [1] [1] [Low] [5] . Presence of vehicles and drill rig Compaction of soil and subsequent . Drilling activities 2 1 1 2 Low 8 potential negative impact on vegetation [2] [1] [1] [1] [Low] [4] re-establishment

. Presence of vehicles and drill rig 2 1 1 2 Low 8 . Drilling activities Contamination of soil [2] [1] [1] [1] [Low] [4] . Waste management . Ablutions . Presence of vehicles and drill rig 2 1 1 1 Low 4 Disturbance of flora and fauna . Presence of personnel and [2] [1] [1] [1] [Low] [4] contractors

Project Name: TIH Prospecting Right Application 7 Report Title: Impact Assessment Project number: 180995 Date: July 2018 2.11. Cumulative Impacts

2.11.1. Air Quality

The region is considered to have good ambient air quality. Therefore, no cumulative impacts are expected.

2.11.2. Aquatic Ecology, Surface Water and Wetlands

As the site is not located within close proximity to wetlands or watercourses no cumulative impacts are expected.

2.11.3. Groundwater

The groundwater in the region is generally of good quality and exploration activities will not likely result in impacts to groundwater resources. Therefore, no cumulative impacts are expected.

2.11.4. Noise

The area generally experiences low ambient noise levels typical of a rural area. Therefore, no cumulative impacts are expected.

2.11.5. Social

As noise and dust levels are not expected to increase that the current rate, no cumulative impacts are expected.

2.11.6. Soil

There are no land use practices in the area which may currently be exerting an impact on soil resources. Therefore, no cumulative impacts are expected.

2.11.7. Terrestrial Ecology

Areas within the PRA are not currently in uses and there are no land use practices in the area which may currently be exerting an impact on terrestrial ecology resources. Therefore, no cumulative impacts are expected.

2.11.8. Visual Aesthetics

The area is historically degraded with no land uses in the area resulting in transformation of the natural landscape character. Therefore, no cumulative impacts are expected.

Project Name: TIH Prospecting Right Application 8 Report Title: Impact Assessment Project number: 180995 Date: July 2018 APPENDIX 4

CLOSURE PLAN

TAWANA INVESTMENT HOLDINGS (PTY) LIMITED

CLOSURE PLAN FOR THE PROSPECTING RIGHT APPLICATION SUBMITTED OVER PORTIONS OF THE FARMS YORK 279 AND HOTAZEL 280 IN THE JOE MOROLONG LOCAL MUNICIPALITY IN THE NORTHERN CAPE PROVINCE

JULY 2018

PREPARED FOR:

Tawana Investment Holdings (Pty) Ltd 11 Beyers Naude Drive Montgomery Park Johannesburg 2129

TABLE OF CONTENTS

1. INTRODUCTION ...... 4 1.1 Introduction ...... 4 1.2 Legislative requirements ...... 4 1.3 Details and Expertise of the EAP ...... 10 2. PROJECT DESCRIPTION ...... 11 2.1 Prospecting Plan Schedule ...... 13 3. ENVIRONMENTAL AND SOCIAL CONTEXT ...... 13 3.1 Air Quality ...... 13 3.2 Aquatic Ecology, Surface Water and Wetlands ...... 13 3.3 Biodiversity - Terrestrial Ecology ...... 14 3.4 Groundwater ...... 14 3.5 Soil ...... 15 3.6 Socio-economic ...... 16 4. CLOSURE RELATED ISSUES ...... 16 4.1 Current Public Engagement ...... 17 4.2 Future Public Engagement...... 17 5. ENVIRONMENTAL RISK ASSESSMENT ...... 18 5.1 Risk Identification and Closure Strategies ...... 18 5.2 Risk Assessment ...... 19 6. CLOSURE VISION AND OBJECTIVES ...... 21 7. CLOSURE ALTERNATIVES ...... 22 8. CLOSURE AND REHABILITATION ACTIONS ...... 22 8.1 Responsibilities ...... 22 9. IMPLEMENTATION SCHEDULE FOR CLOSURE AND REHABILITATION ...... 23 10. FINAL LAND USE ...... 23 11. MONITORING, AUDITING AND REPORTING ...... 24 11.1 Closure Monitoring ...... 24 11.2 Liability Assessment ...... 25 11.3 Additional Legislative Requirements ...... 25 11.4 Post-closure Monitoring ...... 25 12. QUANTUM FOR CLOSURE-RELATED FINANCIAL PROVISIONING ...... 26 13. GAPS AND ACTION PLAN ...... 29 14. CONCLUSION ...... 29

TABLES

Table 1: TIH prospecting plan schedule...... 13 Table 2: Closure risks and closure strategies ...... 18 Table 3: Assessment of the potential closure related risks associated with the TIH prospecting activities ...... 20

Table 4: Latent risk and residual environmental impact assessment for the TIH Project ...... 21 Table 5: Relinquishment criteria for the closure of the TIH prospecting activities ...... 24 Table 6: Total financial provision for the invasive prospecting activities proposed for the TIH PRA 28

ACRONYMS

BAR Basic Assessment Report CBA Critical Biodiversity Area DME Department of Minerals and Energy DMR Department of Mineral Resources DWS Department of Water and Sanitation EA Environmental Authorisation ECO Environmental Control Officer EMPr Environmental Management Programme Report ESA Ecological Support Area FEPA Freshwater Ecosystem Priority Area IDP Integrated Development Plan NFEPA National Freshwater Ecosystem Priority Area MPRDA Mineral and Petroleum Resources Development Act (No. 28 of 2002) NEMA National Environmental Management Act (No. 107 of 1998) NEMBA National Environmental Management Biodiversity Act (No. 10 of 2004) NEMWA National Environmental Management: Waste Act (No. 59 of 2008) NPV Net Present Value NWA National Water Act (No. 36 of 1998) PRA Prospecting Right Area TIH Tawana Investment Holdings (Pty) Ltd VAT Value Added Tax WMA Water Management Area

Project Name: TIH Prospecting Right 3 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

1. INTRODUCTION

1.1 Introduction

This document serves to fulfil the requirement of the NEMA EIA Regulations (GNR982 of 2014 Appendix 5) and the Financial Provisioning Regulations (GNR1147 of 2015) in terms of the Final Rehabilitation, Decommissioning and Closure Plan, the Annual Rehabilitation Plan and the Environmental Risk Assessment.

The aim of the Environmental Risk Assessment is to identify the potential latent and residual environmental risks, which may arise following cessation and rehabilitation of any invasive prospecting activities by TIH, and recommend management and monitoring measures, which should be applied in order to prevent or minimise the impact of potential latent risks post closure.

As such, the following activities were undertaken:

 A desktop study was undertaken to identify the pre-mining environmental and social context, closure commitments, potential risks pertaining to closure, and the recommendations relating to closure.

1.2 Legislative requirements

The Final Rehabilitation, Decommissioning and Closure Plan serves to meet the requirements of Section 11(1)(b), when read in conjunction with Appendix 4 and therefore must include─

GNR1147 of 2015 [Relevant GNR982 of 2014 Appendix 5 Minimum Content of a Final section of Minimum Content of a Closure Plan Rehabilitation, Decommissioning and this plan] Closure Plan (1)(f)(iii) comply with any prescribed [1.2] environmental management standards or practices; and (iv) comply with any applicable provisions of the Act regarding closure (1)(a)Details of— (3)(a) Details of─ (i) the EAP who prepared the closure plan; (i) the team that prepared the plan [1.3] and (ii) the professional registrations and (ii) the expertise of that EAP experience of the EAP (3)(b) The context of the project including─ (i) material project description information [2] and issues that have guided the development

Project Name: TIH Prospecting Right 4 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

GNR1147 of 2015 [Relevant GNR982 of 2014 Appendix 5 Minimum Content of a Final section of Minimum Content of a Closure Plan Rehabilitation, Decommissioning and this plan] Closure Plan of the plan (ii) an overview of environmental and social context that may influence closure activities [3] or be influenced by closure activities (1)(i) details of all public participation processes conducted in terms of regulation 41 of the Regulations, including— (i) copies of any representations and comments received from registered interested and affected parties; (ii) a summary of comments received from, and a summary of issues raised by registered interested and affected parties, the date of (iii) stakeholder issues and comments that receipt of these comments and the response [4] have informed the plan of the EAP to those comments; (iii) the minutes of any meetings held by the EAP with interested and affected parties and other role players which record the views of the participants; (iv) where applicable, an indication of the amendments made to the plan as a result of public participation processes conducted in terms of regulation 41 of these Regulation (iv) the mine plan and schedule for the full approved operations, and must include (aa) appropriate description of the mine plan (bb) drawings and figures to indicate how the mine develops [2.1] (cc) what areas are disturbed (dd) how infrastructure and structures (including ponds, residue stockpiles etc.) develops during the life of the mine (1)(e) information on any proposed (3)(c) Findings of an environmental risk avoidance, management and mitigation assessment leading to the most appropriate measures that will be taken to address the closure strategy including─ environmental impacts resulting from the (i) description of the risk assessment undertaking of the closure activity methodology including risk identification and [5.2.1] quantification. This to be undertaken for all (1)(f) a description of the manner in which it areas of infrastructure or activity or aspects intends to— for which an operation has a responsibility to (i) modify, remedy, control or stop any mitigate an impact or risk at closure

Project Name: TIH Prospecting Right 5 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

GNR1147 of 2015 [Relevant GNR982 of 2014 Appendix 5 Minimum Content of a Final section of Minimum Content of a Closure Plan Rehabilitation, Decommissioning and this plan] Closure Plan action, activity or process which causes (ii) identification of indicators that are most pollution or environmental degradation sensitive to potential risks and the during closure; monitoring of such risks with a view to [5.1] (ii)remedy the cause of pollution or informing rehabilitation and remediation degradation and migration of pollutants activities during closure; (iii) identification of conceptual closure [5.1] strategies to mitigate the impacts and risks (1)(h) the process for managing any (iv) a reassessment of the risks to environmental damage, pollution, pumping determine whether, after the implementation and treatment of extraneous water or of the closure strategy, the residual risk has ecological degradation as a result of closure been avoided and / or how it has resulted in [5.2.2] avoidance, rehabilitation and management of impacts and whether this is acceptable to the mining operation and stakeholders Initial plan, (v) explanation of changes to the risk no updates or assessment results as applicable in annual amendments updates to the plan as of yet (3)(d) Design principles including─ (i) legal and governance framework and [6] interpretation of these requirements for the closure design principles (1)(b) closure objectives (ii) closure vision and objectives. The objectives must reflect the local environmental and socio-economic context [6] and reflect regulatory and corporate requirements and stakeholder expectations (iii) description and evaluation of alternative closure and post-closure options where these exist that are practicable within the socio- [7] economic and environmental opportunities and constraints in which the operation is located (iv) motivation for the preferred closure action within the context of the risks and [7 and 8] impacts that are being mitigated (v) definition and motivation of the closure and post-closure period taking cognisance of the probable need to implement post-closure [11.4] monitoring and maintenance for a period sufficient to demonstrate that relinquishment criteria have been achieved (vi) details associated with any on-going [5.1.1 and

Project Name: TIH Prospecting Right 6 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

GNR1147 of 2015 [Relevant GNR982 of 2014 Appendix 5 Minimum Content of a Final section of Minimum Content of a Closure Plan Rehabilitation, Decommissioning and this plan] Closure Plan research on closure options 13] (vii) detailed description of the assumptions made to develop closure actions in the absence of detailed knowledge on site [5.1.1] conditions, potential impacts, material availability, stakeholder requirements and other factors for which information is lacking (3)(e) Proposed final land use─ (i) descriptions of appropriate and feasible final post-mining land use for the overall project and per infrastructure or activity and [10] a description of the methodology used to identify final post-mining land use, including the requirements of the operations stakeholders (ii) map of proposed final post-mining land [10] use (1)(d) measures to rehabilitate the (3)(f) Closure actions─ environment affected by the undertaking of (i) the development and documenting of a any listed activity or specified activity and description of specific technical solutions associated closure to its natural or related to infrastructure and facilities for the predetermined state or to a land use preferred closure option or options, which which conforms to the generally accepted must include all areas, infrastructure, [8] principle of sustainable development, activities and aspects both within the mine including a handover report, where lease area and off of the mine lease area applicable associated with mining for which the mine has the responsibility to implement closure actions; (ii) development and maintenance of a list and assessment of threats and opportunities and any uncertainties associated with the preferred closure option, which list will be [5.1.1] used to identify and define any additional work that is needed to reduce the level of uncertainty (1)(g) time periods within which the (3)(g) Schedule of actions for final measures contemplated in the closure plan rehabilitation, decommissioning and closure must be implemented which will ensure avoidance, rehabilitation, management of impacts including pumping [9] and treatment of extraneous water─ (i) linking to mine works programme (if greenfields) or to the current mine plan (if brownfields)

Project Name: TIH Prospecting Right 7 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

GNR1147 of 2015 [Relevant GNR982 of 2014 Appendix 5 Minimum Content of a Final section of Minimum Content of a Closure Plan Rehabilitation, Decommissioning and this plan] Closure Plan (ii) assumptions and schedule drivers (iii) spatial map of schedule showing planned spatial progression throughout operations (3)(h) Indicate the organisational capacity that will be put in place to implement the plan including─ (i) organisational structure as it pertains to [8.1] the plan (ii) responsibilities (iii) training and capacity building that may be required to build closure competence (3)(i) An indication of gaps in the plan, including an auditable action plan and [13] schedule to address the gaps (3)(j) Relinquishment criteria for each activity or infrastructure in relation to [11] environmental aspects with auditable indicators (1)(j) where applicable, details of any (3)(k) Closure cost estimation procedure, financial provision for the rehabilitation, which ensures that identified rehabilitation, closure and on-going post decommissioning decommissioning, closure and post-closure management of negative environmental costs, whether on-going or once-off, are impacts realistically estimated and incorporated into the estimate, on condition that─ (i) cost estimates for operations, or components of operations that are more than 30 years from closure will be prepared as conceptual estimates with an accuracy of ± 50 per cent. Cost estimates will have an accuracy of ± 70 per cent for operations, or components of operations, 30 or less years [12] (but more than ten years) from closure and ± 80 per cent for operations, or components of operations ten or less years (but more than five years) from closure. Operations with 5 or less years will have an accuracy of ± 90 per cent. Motivation must be provided to indicate the accuracy in the reported number and as accuracy improves, what actions resulted in an improvement in accuracy; (ii) the closure cost estimation must include the following

Project Name: TIH Prospecting Right 8 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

GNR1147 of 2015 [Relevant GNR982 of 2014 Appendix 5 Minimum Content of a Final section of Minimum Content of a Closure Plan Rehabilitation, Decommissioning and this plan] Closure Plan (aa) explanation of the closure cost methodology (bb) auditable calculations of costs per activity or infrastructure (cc) cost assumptions (iii) the closure cost estimate must be updated annually during the operation’s life to reflect known developments, including changes from the annual review of the closure strategy assumptions and inputs, scope changes, the effect of a further year’s inflation, new regulatory requirements and any other material developments; (1)(c) proposed mechanisms for monitoring (3)(l) Monitoring, auditing and reporting compliance with and performance requirements which relate to the risk assessment against the closure plan and assessment, legal requirements and reporting thereon knowledge gaps as a minimum and must include─ (i) a schedule outlining internal, external and legislated audits of the plan for the year, including─ (aa) the person responsible for undertaking the audit(s) (bb) the planned date of audit and frequency of audit (cc) an explanation of the approach that will be taken to address and close out audit results and schedule; [11] (ii) a schedule of reporting requirements providing an outline of internal and external reporting, including disclosure of updates of the plan to stakeholders (iii) a monitoring plan will be provided outlining (aa) parameters to be monitored, frequency of monitoring and period of monitoring (bb) an explanation of the approach that will be taken to analyse monitoring results and how these results will be used to inform adaptive or corrective management and/or risk reduction activities

Project Name: TIH Prospecting Right 9 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

GNR1147 of 2015 [Relevant GNR982 of 2014 Appendix 5 Minimum Content of a Final section of Minimum Content of a Closure Plan Rehabilitation, Decommissioning and this plan] Closure Plan (3)(m) Motivations for any amendments Initial plan no made to the final rehabilitation, updates or decommissioning and mine closure plan, amendments given the monitoring results in the previous as of yet auditing period and the identification of gaps

1.2.1 Best Practice and Industry Guidelines

DMR Guideline for Evaluation of the Quantum for Closure-Related Financial Provision

The Mineral and Petroleum Resources Development Act, No. 28 of 2002 (MPRDA) places the financial provision into context with respect to relevant constitutional considerations and the overall government policy currently prevailing in South Africa, as well as within a broader environmental legal framework. The DMR guideline, compiled by the then Department of Minerals and Energy (DME) (now DMR), specifically focuses on financial provision for the mining industry. The guideline document is generic in nature relating to financial provision, rehabilitation and mine closure.

GNR1228 of 2017 Draft Financial provisioning Regulations- Methodology for Calculation of Financial Provision for New Development

Costing for final rehabilitation, decommissioning and mine closure.

The costing must reflect the total cost to remediate disturbances that will occur in Year O. The costing must reflect actual market related costs based on prevailing rates exclusive of value added tax (VAT). This is the Year 0 cost and referred to as Total 1. Once any disturbance has commenced on site, the site is classified as an existing operation and subsequent closure costs will be calculated as for existing sites.

Costing for residual environmental impacts which will occur in the future

The costing must reflect the Net Present Value (NPV) based on prevailing rates of future residual environmental impacts due to disturbance of Year O. This is the Year O cost for residual environmental impacts. This cost must be considered in relation to the probability of occurrence as identified in the environmental risk assessment report and is the cost required to mitigate the risk to acceptable levels.

Add Total 1 for final rehabilitation, decommissioning and prospecting closure to Total 2 for residual environmental impacts which may occur in the future. Thus Total 1 + Total 2 = Financial Provision.

1.3 Details and Expertise of the EAP

Name of Firm Prime Resources (Pty) Ltd Physical Address: 70 - 7th Avenue, Parktown North, Johannesburg Postal Address: PO Box 2316, Parklands, 2121

Project Name: TIH Prospecting Right 10 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

Telephone Number: 011 447 4888 Fax Number: 086 604 2219 Email: [email protected] Prime Resources has affiliations with SACNASP, ECSA and Professional Affiliations: SAIMM

Itumeleng Morosele, an Environmental Consultant has a B.Sc. Hons. (Geography) degree from the University of Johannesburg and is a M.Sc. Environmental Management candidate. She has experience in geographic information systems and has been involved in conducting compliance audits.

2. PROJECT DESCRIPTION

The proposed prospecting area is located approximately 1 km south-east of Hotazel, within the Joe Morolong Local Municipality and the Magisterial District of John Taolo Gaetsewe, Northern Cape Province. The prospecting area is 142.7 hectares in extent.

Non-Invasive Activities

Project Name: TIH Prospecting Right 11 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

Geophysical survey - to confirm structural continuity, ground magnetics and ground gravity techniques will be used.

Invasive Activities - Drilling Activities

The main invasive activity during the prospecting period will be the drilling of boreholes if required. Currently it is expected that drilling of core (diamond) drill holes will be performed. Extensive prospecting and exploration activities have previously been undertaken over both portions of the farms; York 279 (Portion L1) and Hotazel 280 (Portion L1). TIH will seek to acquire all existing exploration results and data obtained in this regard and intends on utilising the initial “non- invasive prospecting” period to complete an evaluation of this data and thereafter decide whether any further confirmation drilling (to validate the previous results) will be necessary.

All core assays will be submitted to an accredited laboratory for analysis. Since the exploration program is results driven, updated final drill position plans and drill information will be submitted to DMR after conclusion of the non-invasive exploration activities by way of the required MRDA Regulation 8 progress reports.

Project Name: TIH Prospecting Right 12 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

2.1 Prospecting Plan Schedule

Table 1: TIH prospecting plan schedule Phase 1 2 3 Main activity Year 2017-2018 2018-2019 2019-2021  Literature Review / Desktop studies / Geological monitoring  Geographical mapping of the exposed ore  Review and validation of previous boreholes  Geophysical survey to confirm structural continuity, using ground magnetics and ground gravity techniques  Soil Sampling  Laboratory testing and analysis of samples  In-fill drilling of up to 15 diamond drill holes, to depths between 30 metres and 90 metres, if required after initial studies *Grey indicates activities

3. ENVIRONMENTAL AND SOCIAL CONTEXT

This section details the pre-prospecting and current environmental and social contexts that may influence closure activities.

3.1 Air Quality

Closure Recommendations

 The impact of dust will have a short duration and is expected to decrease once prospecting activities in a drill hole area have been completed and is expected to cease once the disturbed areas are successfully revegetated.  Establish a self-sustaining and stable vegetative cover of any exposed surfaces created during exploration drilling.

3.2 Aquatic Ecology, Surface Water and Wetlands

The project area is located in quaternary catchment D41K, within the Lower Vaal River Water Management Area (WMA) and Drainage Basin D (Orange River basin). The Lower Vaal WMA is located downstream of Bloemhof Dam and upstream of Douglas Weir. It extends to the

Project Name: TIH Prospecting Right 13 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

headwaters of the Harts, Molopo and Kuruman River in the north and the Vaal River Downstream of Bloemhof in the south. The Lower Vaal WMA covers a catchment area of 51,543 km2.

The PRA does not contain rivers within its boundaries and is located approximately 5 km away from the nearest river course, i.e. Ga-Mogara River (Gamagara elsewhere). Within the quaternary catchment, the Witleegte, Ga-Mogara and Vlermuisleegte Rivers are present, these are however at a distance greater than 5km from the site boundaries.

There are no wetlands situated within the bounds of the PRA, with the nearest wetland located approximately 5 km away.

Closure Recommendations

 Any contaminated water arising from prospecting activities must be collected and contained and not allowed to infiltrate into the groundwater.  Ensure that all contaminated soils are disposed of at a suitable disposal facility.  Rehabilitation must take place in such a way as to ensure that the disturbed exploration sites are free draining.

3.3 Biodiversity - Terrestrial Ecology

The project area falls within the Savanna Biome, within the Eastern Kalahari Bushveld Bioregion and the Inland Saline Vegetation Bioregion. Only one vegetation type is associated with the project area, namely the Kathu Bushveld vegetation type which is listed as Least Threatened in terms of Section 52 of NEMBA.

The Ecosystem protection levels of the Kathu Bushveld ecosystem is not protected.

There are no Critical Biodiversity Areas (CBA’s) or Ecological Support Areas (ESA’s) within the PRA area – which is bare / transformed by historic mining activities.

According to the Mining and Biodiversity Guidelines (2013), there is no classification of biodiversity importance for the PRA site.

Closure Recommendations

 Clean any spills immediately and implement adequate waste and chemical management practices.  Rip and profile any soil compacted due to exploration activities.  Natural revegetation will likely occur.  Areas disturbed by exploration activities must be inspected after a growing season has passed and should natural revegetation prove unsuccessful areas must be revegetated using indigenous vegetation species.

3.4 Groundwater

There are 4 major aquifer systems in the Vaal WMA:

 Karst aquifers with borehole yields >5.0 l/s, supporting fresh dolomite springs  Intergranular and fractured aquifers with boreholes yields between 0.1 and 2.0 l/s

Project Name: TIH Prospecting Right 14 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

 Fractured aquifers with borehole yields between 0.1 and 2.0 l/s, highly variable water quality  Intergranular/ alluvial aquifers with borehole yields between 0.1 and 2.0 l/s, multi layered aquifer systems (fresh upper aquifers, underlain by brackish to hyper saline groundwater).

The Mine Atlas rates the aquifer vulnerability along the Gamagara River valley (Kathu-Van Zylsrus area), as 3 (high) due to fresh water quality (<70mS/m and in the Lower Kuruman River (close to Van Zylsrus-Askham area) as 3.2 (high) due to its good fresh water quality (<70 mS/m) and high yields (2.0 to 5.0 l/s), however nearer to the project area the risk is considered moderate (rated between 2 and 3). Most of the groundwater abstraction that takes place in the Molopo sub-area (which includes the D41M catchment) is in the vicinity of dry sandy riverbeds. A substantial part of the recharge of groundwater is also assumed to be from these watercourses. To the south of the project area in quaternary catchment D41L, an extensive dolomitic aquifer is hosted in the Ghaap Plateau dolomites.

Closure Recommendations

 Remove hydrocarbons.  Maintain vehicles and machinery to prevent leaks, cleaning any spills immediately, and implementing adequate waste and chemical management practices.

3.5 Soil

The Soil and Terrain database developed by ISRIC World Soil Information provide data on key soil and terrain properties. According to the database, the project region is dominated ferralic arenosols, however it is noted that any such soil resources were previously stripped and removed from the TIH PRA area during historic opencast mining activities. Any remaining soil resources would be those stockpiled intermittently around the opencast mine void. The description given below specifically applies to any such stockpiled or the limited remaining in-situ soil resources.

Arenosols develop during the weathering of quartz-rich material. The soils have a loamy sand or coarse-grained texture and occur at a depth of at least 50 cm from the surface. The soil typically has less than 35% rock fragments by volume. The soil type is generally suitable for extensive stock grazing but could be used for arable crops if well irrigated.

Project Name: TIH Prospecting Right 15 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

Closure Recommendations

 To decrease the potential for erosion, disturbed areas must successfully revegetate.  Implement spill prevention measures such as handling and storing hydrocarbons on impermeable surfaces, adequately maintain vehicles and machinery to prevent leaks, clean any spills immediately, minimise areas to be disturbed by vehicle and machinery, and rip and profile any in situ soils which become compacted as a result of exploration drilling activities.  Clean any spills immediately, and implement adequate waste and chemical management practices during closure.

3.6 Socio-economic

The project area is located within Ward 4 of the Joe Morolong Local Municipality and the John Taolo Gaetsewe District Municipality.

Joe Morolong Local Municipality is mostly rural, with virgin land surface comprising about 60% of the surface. Agriculture, mining and community services are the primary economic sectors. JMLM has three main nodes where relatively higher economic activity takes place, namely Vanzylsrus, Hotazel and Blackrock. Mining is the predominant economic activity in Hotazel and Blackrock. Vanzylsrus operates as service centre for the surrounding area.

Considering that the land in question is privately owned and that nearby stakeholders and communities will not likely be affected as a result of exploration activities, the potential socio- economic impact is considered negligible.

Closure Recommendations

 Adhere to agreements made with landowners.  The mitigation measures detailed in the BAR should be implemented.

4. CLOSURE RELATED ISSUES

This is the draft Closure Plan which forms part of the documents that are made available for public comment.

Project Name: TIH Prospecting Right 16 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

Any issues and concerns raised during the public participation process will be responded to and proposed alternatives and mitigation measures assessed where applicable. The Final Closure Plan will be revised in line with any comments received following public participation.

4.1 Current Public Engagement

The public participation process followed met the requirements of Chapter 6 of the NEMA EIA Regulations, GNR982 of 2014.

The public participation process followed is described below:

 The current landowner of the farm portions subject to the Prospecting Rights Application (South 32 – Hotazel Manganese Mines) were provided with written notification of the project  A media notice was published in the Kathu Gazette which indicated that TIH had submitted an application for a Prospecting Right to the DMR, the location of the project, legislative context, and gave details whereby Interested and Affected (IAPs) could indicate their interest in the project, register on the IAP database or otherwise request additional information and provide comment.  Public notices containing the same data as above were placed in three highly visible locations namely; Hotazel Library, OK Hotazel and KLK Hotazel.  Notification letters were sent out to the identified State Departments and Stakeholders (including the Dept. of Agriculture (Kimberley), the Dept. of Agriculture and Rural Development (Kuruman), the Dept. of Environmental Affairs (Kimberley), the Dept. of Rural Development and Land Reform (Kimberley), the Dept. of Water and Sanitation (Kimberley), the Dept. of Mineral Resources (Kimberley), the Dept. of Public Works (Kimberley), Land Claims, SAHRA (Cape Town), SANRAL (Bellville), Eskom (Kimberley), South 32 (Hotazel), Transnet (Bloemfontein), Transnet (Hotazel), the John Taolo Gaetsewe District Municipality (Kuruman), KLK Landbou BPK (Hotazel), Kudumane Manganese Resources and Agri Kuruman). These letters indicated that THI had submitted an application for a Prospecting Right to the DMR, the activities proposed, the location of the project, the legislative context and the request to submit comment within the specified timeframe  A database was prepared and maintained for the duration of the initial public commenting period which included all those contacted per the above and any IAPs requesting to register in response to the above or who otherwise provided comment. Any person responding to any of the abovementioned notifications was added to the IAP database.  A Comments and Response Report was compiled as part of the public participation process. All comments received and responses thereto or other representations made were also recorded.

4.2 Future Public Engagement

Follow-up public consultation will now be undertaken which will entail providing all registered IAPs, stakeholders and State Department representatives with a copy of the BAR and EMP inclusive of this closure plan as an appendix, for review and comment. Any additional IAPs,

Project Name: TIH Prospecting Right 17 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

State Department representatives or other stakeholders identified who were not previously consulted with will also be added to the IAP database and provided with the BAR / EMP for comment.

 Commenting Period: The BAR / EMP will be provided in the requested format (digitally or hard copy, as requested) as well as on the Prime Resources website (www.resources.co.za), for a period of 30 days (16 July 2018 to 15 August 2018).

 Comments and Response Report: The existing comments and responses report will be further updated following the forthcoming 30-day public consultation period.

5. ENVIRONMENTAL RISK ASSESSMENT

5.1 Risk Identification and Closure Strategies

The potential risks relating to the rehabilitation of exploration activities associated with the TIH PRA are detailed in Table 2, per environmental attribute. The relevant closure actions to achieve the closure strategies are detailed under Section 8.

Table 2: Closure risks and closure strategies Closure risk Closure strategy Areas to be cleared will be limited to the minimum extent possible. All the areas disturbed by prospecting activities must be Dust generated from activities and erosion across bare successfully rehabilitated. Intervening by areas may result in visual aesthetic and nuisance impacts. planting indigenous vegetation in disturbed areas should natural revegetation prove unsuccessful. Ripping and profiling soils compacted as a result of exploration activities. All the areas disturbed by prospecting activities must be Compaction of soil and subsequent potential negative successfully rehabilitated. Intervening by impact on vegetation re-establishment. planting indigenous vegetation in disturbed areas should natural revegetation prove unsuccessful. Adequately maintaining vehicles and machinery

Contamination of soil and terrestrial environment. to prevent leaks. Cleaning any spills immediately.

Intervening by planting indigenous vegetation

Unsuccessful revegetation in disturbed areas should natural revegetation prove unsuccessful.

5.1.1 Uncertainties Relating to the Closure Strategies

 Natural revegetation will likely occur, however if after a growing season has passed and natural revegetation proves unsuccessful bare areas must be revegetated using indigenous vegetation species.

Project Name: TIH Prospecting Right 18 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

5.2 Risk Assessment

5.2.1 Methodology

The following assessment model was used for determination of the significance of closure related risks.

SIGNIFICANCE = (MAGNITUDE + DURATION + SCALE) X PROBABILITY

The maximum potential value for significance of an impact is 100 points. Closure related risks can therefore be rated as high, medium or low significance on the following basis:

 High environmental significance 60 – 100 points  Medium environmental significance 30 – 59 points  Low environmental significance 0 – 29 points

MAGNITUDE (M) DURATION (D)

10 – Very high (or unknown) 5 – Permanent

8 – High 4 – Long-term (ceases at the end of operation) 6 – Moderate 3 – Medium-term (2-4 years) 4 – Low 2 – Short-term (0-1 years) 2 - Minor 1 – Immediate SCALE (S) PROBABILITY (P) 5 – International 5 – Definite (or unknown) 4 – National 4 – High probability 3 – Regional 3 – Medium probability 2 – Local 2 – Low probability 1 – Site 1 – Improbable 0 – None 0 – None

Since the only risks associated with the proposed prospecting activities relate to the invasive borehole drilling planned and since the prospecting activities cannot be broken down into construction, operation and decommissioning phases the following risks identified in the Impact Assessment (Appendix 3) may also be closure related risks. The significance of the risks identified was determined using the above methodology. Refer to Table 3 below for the TIH PRA closure risk assessment.

Project Name: TIH Prospecting Right 19 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

Table 3: Assessment of the potential closure related risks associated with the TIH prospecting activities

SIGNIFICANCE

PROCESS IMPACT RATING VALUE SCALE (S) SCALE DURATION (D) DURATION MAGNITUDE (M) MAGNITUDE PROBABILITY (P) PROBABILITY Land clearing and minor Dust generated may result in nuisance 2 1 1 2 Low 8 earth-moving activities impacts [2] [1] [1] [1] [Low] [4]

. Presence of vehicles and Compaction of soil and subsequent 2 1 1 2 Low 8 drill rig potential negative impact on vegetation [2] [1] [1] [1] [Low] [4] . Drilling activities re-establishment

. Presence of vehicles and . Compaction of soil and subsequent machinery negative impact on vegetation re- 2 1 1 2 Low 8 . Removing of drill rig and establishment [2] [1] [1] [1] [Low] [4] associated infrastructure . Disturbance of flora and fauna

Project Name: TIH Prospecting Right 20 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

5.2.2 Outcomes

As indicated in Table 3, if the closure strategies (as detailed in Table 2) are achieved through the implementation of the action plan described in Section 8 of this plan, the overall significance of the closure-related risks identified can be suitably managed. The following latent / residual risks were identified:

 Compaction of soil and subsequent potential negative impact on vegetation re-establishment.  Natural revegetation will likely occur, however there may be inadequate rehabilitation if the natural revegetation process proves unsuccessful.

Monitoring

 Disturbed areas must be inspected after a growing season has passed.

Mitigation

 Compacted areas must be ripped and profiled.  Should natural revegetation prove unsuccessful areas must be revegetated using indigenous vegetation species.

No other residual impacts are foreseen.

Table 4: Latent risk and residual environmental impact assessment for the TIH Project

SIGNIFICANCE

(P)

PROCESS IMPACT RATING VALUE SCALE (S) SCALE DURATION (D) DURATION MAGNITUDE (M) MAGNITUDE PROBABILITY PROBABILITY Rehabilitation of cleared land Inadequate rehabilitation 2 1 1 2 Low 8 through natural revegetation

6. CLOSURE VISION AND OBJECTIVES

The main objective will be to rehabilitate- and return the borehole drill areas, additional access tracks created and any areas affected as a result of invasive prospecting activities (including temporary infrastructure) to resemble the surrounding landscape with no remaining infrastructure or potential hazards to people or the environment.

Further environmental objectives include:

. Ensure that no temporary infrastructure is left on-site and ensure environmental and safety risks are minimised; . Rehabilitate areas disturbed by prospecting activities; . Rehabilitated areas must not pose a safety hazard to humans and animals; . Limit to the greatest extent possible the clearing of vegetation during prospecting activities;

Project Name: TIH Prospecting Right 21 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

. Establish a self-sustaining and stable vegetation cover over the individual areas disturbed by the prospecting activities, if necessary by ripping and re-seeding using an appropriate indigenous seed-mix to promote the rehabilitation of the affected area to coincide with the surrounding landcover and as per landowner agreement; . Minimise the establishment of alien vegetation; . Ensure the rehabilitated landform is free draining; and . Ensure adherence to local, provincial and national regulatory requirements.

Closure Objectives Extent to which aligned to baseline environment  The topography of rehabilitated drill sites will be shaped to Developing a rehabilitated ensure that these areas are free draining. landform that is free draining,  Natural revegetation will likely occur. with established, self-sustaining  Disturbed areas must be inspected after a growing season has vegetation passed and should natural revegetation prove unsuccessful areas must be revegetated using indigenous vegetation species.  Alien vegetation must be removed. Rehabilitate and return the drill  Natural revegetation will likely occur. hole areas to a capability that is  Disturbed areas must be inspected after a growing season has in line with the surrounding passed and should natural revegetation prove unsuccessful areas landscape. must be revegetated using indigenous vegetation species.  No temporary infrastructure is to be left on-site.  After all foreign matter has been removed from the sumps the Rehabilitated areas do not pose a excavations shall be backfilled with subsoil, compacted and safety hazard to humans and levelled with previously stored topsoil. No foreign matter such as animals. cement or other rubble shall be introduced into such backfilling.  All boreholes shall be covered and made safe by means of a concrete cap.  All waste will be removed.

7. CLOSURE ALTERNATIVES

There are no closure alternatives. All surface infrastructure is to be removed and the affected landscape rehabilitated.

8. CLOSURE AND REHABILITATION ACTIONS

The following section details the preferred closure and rehabilitation actions in line with the closure strategy which must be implemented to ensure that closure objectives are met and the realisation of the potential residual risks is avoided.

8.1 Responsibilities

Duties related to closure and rehabilitation will be overseen by the Environmental Control Officer (ECO) who will guide the drilling contractors and exploration geologists, depending on the contractual agreement for the proposed invasive prospecting activities.

The ECO will be responsible for employing the relevant suitably qualified specialists to conduct monitoring and auditing as required. On completion of prospecting, the drilling sites shall be rehabilitated as described below.

Project Name: TIH Prospecting Right 22 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

8.1.1 Borehole drilling sites

 Photographs of the borehole drilling sites shall be taken at selected points before and during prospecting and after rehabilitation and kept on record;  Any spill should be cleaned up immediately by removing the spill together with the polluted soil and disposing of it at a recognized dumping facility;  Boreholes shall be compacted with appropriate inert material and soil and backfilled with concrete (up 300mm below surface for natural areas and 600mm below surface for agricultural areas). No foreign matter such as rubble or waste material shall be introduced into the hole;  All boreholes shall be covered and made safe by means of a concrete cap;  Sumps shall be pumped dry and the contents disposed of at a recognized facility;  Linings must be removed and disposed of at a recognized facility;  After all foreign matter has been removed from the sumps the excavations shall be backfilled with subsoil, compacted and levelled with previously stored topsoil. No foreign matter such as cement or other rubble shall be introduced into such backfilling;  The exposed soil surface areas should be scraped clean and any contaminated soil disposed of;  Soils compacted due to exploration activities should be ripped/ ploughed and the stockpiled topsoil replaced; and  Disturbed areas must be inspected after a growing season has passed and should natural revegetation prove unsuccessful areas must be revegetated using indigenous vegetation species.

8.1.2 Access Roads

 Any access road or portion thereof; constructed by TIH for the prospecting activities which will no longer be required by the landowner/tenant, shall be rehabilitated;  Roads should be ripped or ploughed and if necessary appropriately fertilized to ensure the regrowth of vegetation; and  Disturbed areas must be inspected after a growing season has passed and should natural revegetation prove unsuccessful areas must be revegetated using indigenous vegetation species.

9. IMPLEMENTATION SCHEDULE FOR CLOSURE AND REHABILITATION

After drilling is complete, the borehole drill site will be rehabilitated. Once all drilling is completed, any newly created access roads will be rehabilitated where required. A period of 1 year is assumed for the full re-establishment of vegetation.

10. FINAL LAND USE

The final end land use for the borehole drill sites and any created access tracks is to a capability reflective of the surrounding landscape.

Project Name: TIH Prospecting Right 23 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

11. MONITORING, AUDITING AND REPORTING

11.1 Closure Monitoring

 A period of 1 year is assumed for the full re-establishment of vegetation.  Disturbed areas must be inspected after a growing season has passed and should natural revegetation prove unsuccessful areas must be revegetated using indigenous vegetation species.

11.1.1 Reporting

 The ECO must compile a report one year after rehabilitation. This report must be based on the findings at the borehole drill sites and any access roads created (including the before and after photographs and recommended management measures if required).

Table 5: Relinquishment criteria for the closure of the TIH prospecting activities Environmental Relinquishment Indicators Reporting requirements attribute criteria  Ensure that no temporary Photographic evidence of Developing a infrastructure is left on- removal of all surface landscape that is site and ensure infrastructure; an aesthetically environmental risks are inconspicuous and Aesthetic quality acceptable in relation minimised; rehabilitated project site; to the existing  No waste remains on site; safe waste disposal landscape.  Rehabilitate areas certificates; and close-out disturbed by drill rigs. reports.  Establish a self-sustaining Disturbed areas must be and stable vegetation inspected after a growing cover over the areas season has passed and Biodiversity / All disturbed habitat disturbed by the should natural revegetation Vegetation areas rehabilitated to prospecting activities; prove unsuccessful areas reflect natural areas.  Minimise the must be revegetated using establishment of alien indigenous vegetation vegetation. species.  The topography of the rehabilitated drill sites / Photographic evidence Developing a created access tracks will taken after large rainfall Surface Water landform that is free be reshaped to ensure events to indicate that no draining that the area is fee- pooling is occurring draining.  Ensure that no temporary infrastructure or waste is left on-site; Rehabilitated areas Photographic evidence of  All boreholes shall be are not posing a the rehabilitated drill sites Safety covered and made safe safety hazard to and safe waste disposal by means of a concrete humans and animals. certificates. cap;  Rehabilitate areas disturbed by drill rigs.

Project Name: TIH Prospecting Right 24 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

11.2 Liability Assessment

As per Section 24(P)(3) of NEMA, TIH must annually assess their environmental liability and, if circumstances so require, must adjust their financial provision to the satisfaction of the Minister responsible for Mineral Resources. The process for annual review of financial provision is outlined in Regulation 9(4) the NEMA Financial Provision Regulations.

The annual assessment must be undertaken by an independent specialist and includes reviewing this plan together with the Annual Rehabilitation Plan and the Environmental Risk Assessment Report. The annual assessment must then be reviewed by an auditor.

Should the review, assessment and audit of the adequacy of the financial provision identify a shortfall in the financial provision, TIH must increase the financial provision within 30 days from the date of signature on the final auditor's report, to meet the assessed and audited sum.

The results of the assessment of the adequacy of the financial provision, including proof of payment or arrangements for any adjustments required, must be submitted by TIH to the DMR for approval, in the form of an auditor’s report, together with the Annual Rehabilitation Plan, this plan and the Environmental Risk Assessment Report. All the above-mentioned documentation submitted to the Minister by TIH must be signed-off by the Chief Executive Officer or person appointed in a similar position, as well as an independent auditor.

As this is the initial closure plan, there are no updates or amendments as of yet. This plan is to be audited annually and updated when necessary (i.e. progressive rehabilitation takes place, changes in the prospecting layout, number of drill sites or description occur, additional potential risks arise, additional closure actions are required and/ or adjustments are made to the financial provision).

11.3 Additional Legislative Requirements

In terms of current legislation, within 180 days of the cessation of prospecting operations, an application for a closure certificate, in terms of Regulation 43 of the MPRDA, must be submitted to the DMR. This application must be accompanied by the required information, programmes, plans and reports prescribed in terms of the MPRDA and NEMA including a Final Performance Assessment of the site, this plan and an Environmental Risk Report.

After the application has been submitted, an application for Environmental Authorisation (EA) in terms of NEMA, as per the NEMA EIA Regulations (GNR982 of 2014), must be applied for as the decommissioning of any activity requiring a closure certificate in terms of Regulation 43 of the MPRDA is a listed activity in terms of the NEMA EIA Listing Notice 1 (GNR983 of 2014).

Once EA is obtained, decommissioning, rehabilitation and closure activities may commence. The associated EMPr and Closure Plan is required to be audited, the frequency of which will be stipulated in the EA.

11.4 Post-closure Monitoring

The ECO must compile a report one year after rehabilitation. This report must be based on the findings at the borehole drill sites and any created access roads (including the before and after photographs and recommended management measures if required).

Project Name: TIH Prospecting Right 25 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

12. QUANTUM FOR CLOSURE-RELATED FINANCIAL PROVISIONING

As per GNR1147 of 2015 the holder of a right in terms of the MPRDA must determine and make financial provision for the rehabilitation and management of negative environmental impacts from prospecting operations to the satisfaction of the Minister responsible for Mineral Resources. According to Regulation 5 a holder must make financial provision for decommissioning and rehabilitation activities at the conclusion of prospecting activities.

Regulation 6 makes provision for the method of determining the costs of the financial provision and states that a holder must determine the financial provision through a detailed itemisation of all activities and costs required for final decommissioning and rehabilitation of the prospecting, exploration, mining or production operations at the end of the life thereof. As such, the quantum for closure-related financial provision in terms of the above has been determined.

The Guideline for Evaluation of the Quantum for Closure-Related Financial Provision compiled by the then Department of Minerals and Energy (DME) (now DMR) was used to inform the itemised breakdown. The guideline rates were however adjusted using contractor rates to provide actual costs for decommissioning and rehabilitation. The rates utilised are based on contractor rates which have been escalated by Consumer Price Index (CPI) of 5.26% for 2017.

From the methodology for calculation of Financial Provision for a new development in the draft financial provisioning regulations, the costing for final rehabilitation and decommissioning must reflect the total cost to remediate disturbances that will occur in Year O and must reflect actual market related costs based on prevailing rates exclusive of VAT. The costing for residual environmental impacts which will occur in the future must reflect the Net Present Value (NPV) based on prevailing rates of future residual environmental impacts due to disturbance of Year O. This is the Year O cost for residual environmental impacts. Total 1 for final rehabilitation, decommissioning and mine closure and Total 2 for residual environmental impacts which may occur in the future are then added to obtain the Total Financial Provision.

 15 drill pads (10m x 10m each, 1500 m2 in total)  Contractor laydown (4000 m2)  Access tracks – existing access tracks will be used where possible but provision is made for the rehabilitation of a further 150m x 2m of general gravel tracks (300 m2)

Total 1, the financial provision for the final rehabilitation activities associated with the TIH PRA, has been calculated to be R 14,598. Total 2, the financial provision for the residual environmental impacts is calculated as R 8,373. Refer to Table 6.

The total financial provision for the invasive prospecting activities proposed for the TIH Hotazel PRA Project, Total 1 + Total 2, is therefore R 23,331.

Project Name: TIH Prospecting Right 26 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

Should the planned activities change the closure costs for the additional activities must be incorporated into the total financial provision.

Providing for the financial provision for a period of ten years forthwith by forecasting the total financial provision for ten years and escalating by CPI at 6% throughout equates to R 39 417. This amount is in line with rehabilitation forecast indicated in the Prospecting Works Programme.

Project Name: TIH Prospecting Right 27 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018

Table 6: Total financial provision for the invasive prospecting activities proposed for the TIH PRA Site/Facility Name Tawana Investment Holdings (TIH) Hotazel PRA Closure Components, Closure Costs and Weighting Factors As below Provision for final rehabilitation, decommissioning and mine closure plan Relevant Component On-site Total Closure Component No. Main Description Unit Rate Quantity (As per contractor rates) 2018 Rehabilitation of access 3 Minor gravel roads and tracks m2 R 32 300.0 R 9 456 roads Ripping to alleviate compaction General ripping [15 drill pads 8 Earthworks (10m x 10m each), storage area, ha R 11 364 0.2 R 2 159 campsite, core shed] General surface rehabilitation, including Establishment of vegetation 10 ha R 16 715 0.2 R 3 343 grassing of all denuded (general) areas TOTAL 1= YEAR 0 = SUM OF CLOSURE COMPONENT COSTS R 14 958

Provision for residual environmental impacts which will occur in the future Total Description Unit Rate Quantity 2018 Inspection of disturbed areas, one year after rehabilitation, maintenance and aftercare ha R 21 468 0.4 R 8 373 TOTAL 2 = YEAR 0 = SUM OF CLOSURE COMPONENT COSTS R 8 373

TOTAL FINANCIAL PROVISION= TOTAL 1 + TOTAL 2 R 23 331

Project Name: TIH Prospecting Right 28 Report Title: Closure Plan Project number: 180995 Date: July 2018

13. GAPS AND ACTION PLAN

As this is the initial closure plan compiled to align with the requirements of the recently enacted regulations (GNR1147 of 2015) there are no updates or amendments as of yet. This document is to be audited annually and updated.

Since the prospering activities have not yet commenced and invasive prospecting may only commence following the completion of an initial phase of non-invasive exploration activities, no rehabilitation/remediation activities have been implemented for the preceding 12 months, nor will any rehabilitation or remediation activities likely be required in the forthcoming 12 months. The Annual Rehabilitation Plan has therefore not yet been compiled. The Annual Rehabilitation Plan may be required when invasive prospecting activities commence or as directed by the Competent Authority.

14. CONCLUSION

The measures and recommendations made in this plan serve to assist the holder of the Prospecting Right in responsibly and timeously planning for and implementing closure of the envisioned prospecting activities within the TIH PRA. This plan must be assessed annually and updated as necessary.

Within 180 days of the cessation of prospecting activities an application for a closure certificate, in terms of Regulation 43 of the MPRDA, must be submitted to the DMR. After the application has been submitted an application for Environmental Authorisation in terms of NEMA must be applied for prior to commencing with decommissioning, rehabilitation and closure activities. No closure certificate may be issued unless each government department charged with the administration of any law which relates to any matter affecting the environment have confirmed in writing that the provisions pertaining to health and safety and management of pollution to water resources, the pumping and treatment of extraneous water and compliance to the conditions of the Environmental Authorisation have been addressed. Notwithstanding the issuing of a closure certificate, liability for the environmental degradation on the site remains the responsibility of the holder of the right.

If the holder fails to rehabilitate or to manage any impact on the environment, or is unable to undertake such rehabilitation or to manage such impact, the Minister responsible for Mineral Resources may, upon written notice, use all or part of the financial provision to rehabilitate or manage the environmental impact in question.

The total financial provision for the invasive prospecting activities proposed for the TIH PRA is R 23,331 (allowance for a period of ten years forthwith equates to R 39 417).

Project Name: TIH Prospecting Right 29 Report Title: Rehabilitation and Closure Plan Project number: 180995 Date: July 2018 APPENDIX 5

SOCIO-ECONOMIC CONDITIONS: LAND CLAIMS