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GLENCORE OPERATIONS (PTY) LTD: WATERVAL MINE

CONSOLIDATED EIAR AND EMPR

DMR REF NO’s: NW30/5/1/2/2/157 MR NW30/5/1/2/2/244 MR NW30/5/1/2/2/246 MR NW30/5/1/2/2/192 MR NW30/5/1/2/2/260MR Report date: June 2020

WATERVAL MINE: CONSOLIDATED EIAR AND EMPR. Report Date: June 2020 ii

ENVIRONMENTAL IMPACT 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 Glencore Operations South Africa (Pty) Ltd: Waterval Mine

Project Consolidated EIAR and EMPR for Public Review

Tel No. 014 597 8163 / 8409

Fax No. 014 597 8408

Postal Address PO Box 310, Kroondal, 0350

DMR Reference No NW30/5/1/2/2/157 MR

NW30/5/1/2/2/244 MR

NW30/5/1/2/2/246 MR

NW30/5/1/2/2/192 MR

NW30/5/1/2/2/260MR

1 Please note that this EIAR and EMPr is an amended consolidated EIAR and EMPr for Waterval Mine. No new listed activities have been applied for in terms of the EIA Regulations, 2014 and NEMA / NEM: WA. However, this EIAR and EMPr has been compiled in accordance with the DMR’s latest template.

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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 ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

The objective of the environmental impact assessment process is to, through a consultative process: -

(a) determine the policy and legislative context within which the activity is located and document how the proposed activity complies with and responds to the policy and legislative context; (b) describe the need and desirability of the proposed activity, including the need and desirability of the activity in the context of the preferred location; (c) identify the location of the development footprint within the preferred site based on an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all the

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identified development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects of the environment; (d) determine the—- i. nature, significance, consequence, extent, duration and probability of the impacts occurring to inform identified preferred alternatives; and ii. degree to which these impacts— (aa) can be reversed; (bb) may cause irreplaceable loss of resources, and (cc) can be avoided, managed or mitigated; (e) identify the most ideal location for the activity within the preferred site based on the lowest level of environmental sensitivity identified during the assessment; (f) identify, assess, and rank the impacts the activity will impose on the preferred location through the life of the activity; (g) identify suitable measures to manage, avoid or mitigate identified impacts; and (h) identify residual risks that need to be managed and monitored.

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Table of Contents PART A

SCOPE OF ASSESSMENT AND ENVIRONMENTAL IMPACT ASSESSMENT REPORT

1 Details of project applicant and environmental assessment practitioner ...... 7

1.1 Details of the project applicant ...... 7

1.2 Details of the environmental assessment practitioner ...... 7

1.3 Expertise of the environmental assessment practitioner ...... 8

2 Description of the property...... 8

3 Locality of the project ...... 10

3.1 Location of the project Area ...... 10

3.2 Location of the operation ...... 11

4 Description of the scope of the proposed activity ...... 13

4.1 Listed and specified activities applied for ...... 13

4.2 Description of activities undertaken ...... 21

5 Policy and legislative context ...... 54

6 Need and desirability of the proposed activities ...... 61

6.1 Need and desirability in terms of the Guideline on Need and Desirability, dated 20 October 2014 ...... 62

7 Motivation for the preferred development footprint within the approved site including a full description of the process followed to reach the proposed development footprint within the approved site...... 76

7.1 Details of the development footprint alternatives considered ...... 76

7.2 Details of the Public Participation Process Followed ...... 76

7.3 Summary of issues raised by I&Aps ...... 76

7.4 The Environmental attributes associated with the development footprint alternatives. A baseline environment...... 77

7.5 Impacts and Risks Identified ...... 181

7.6 Methodology used in determining and ranking potential environmental impacts and risks 211

7.7 Positive and negatives that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and community affected ...... 217

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7.8 Possible mitigation measures that could be applied and the level of risk ...... 217

7.9 Motivation where no alternative sites were considered ...... 218

7.10 Final site layout plan ...... 218

8 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 ...... 218

9 Assessment of each identified potentially significant impact and risk ...... 219

10 Summary of specialist reports ...... 220

11 Environmental impact statement ...... 224

11.1 Summary of the key findings of the environmental impact assessment ...... 224

11.2 Final site map ...... 225

11.3 Summary of the positive and negative implications and risks of the proposed activity ...... 226

12 Proposed impact management outcomes for inclusion into the EMPr ...... 234

13 Final proposed alternatives ...... 235

14 Aspects for inclusion as conditions of the authorisation ...... 235

15 Description of any assumptions, uncertainties and gaps in knowledge ...... 238

15.1 Further gaps in knowledge ...... 241

16 Reasoned opinion as to whether the proposed activity should or should not be authorised ...... 241

16.1 Reasons why the activity should be authorised or not ...... 242

16.2 Conditions that must be included in the authorisation ...... 242

17 Period for which Environmental Authorisation is required ...... 243

18 Undertaking ...... 243

19 Financial provisions ...... 244

19.1 Explain how the aforesaid amount was derived...... 244

19.2 Confirm that this amount can be provided for from operating expenditure ...... 251

20 Deviations from the approved scoping report and plan of study ...... 252

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20.1 Deviations from the Methodology used in determining the significance of potential environmental impacts and risks ...... 252

20.2 Motive for the deviation...... 252

21 Other information required by the competent authority ...... 252

21.1 Compliance with the provisions of section 24(4)(a) and (b) read with section 24(3)(a) and (7) of the National Environmental Management Act 107 of 1998 ...... 252

22 Other matters required in terms of section 24(4) (a) and (b) of the Act ...... 253

PART B

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

1 Draft environmental management programme ...... 256

1.1 Details of the EAP ...... 256

1.2 Description of the aspects of the activity ...... 256

1.3 Composite map ...... 256

1.4 Description of impact management objectives including management statements...... 256

1.5 Impact Management Outcomes ...... 263

1.6 Impact Management Actions ...... 263

1.7 Financial Provision...... 263

1.8 Mechanisms for monitoring compliance with and performance assessments against the environmental management programme...... 265

1.9 Programme for reporting on compliance ...... 271

1.10 Environmental awareness plan ...... 271

1.11 Specific information required by the Competent Authority ...... 272

2 Undertaking ...... 274

3 Declaration of independence ...... 274 Annexures Annexure A: Project team CV’s

Annexure B: Figures

Annexure C: Mining Rights

Annexure D: Authorisations

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Annexure E: Social and Labour Plan

Annexure F: Public Participation Report

Annexure G: Existing specialist and monitoring information1

Annexure G1: B.B. Mabuza and D.G. Paterson. November 2007. Report for Xstrata Mining Division (Pty) Ltd by the Institute for Soil, Climate and Water. Agricultural Research Council. Soil Investigation in the Waterval area

Annexure G2: Natural Scientific Services cc. June 2015. Waterval Biodiversity Assessment: Glencore Alloys. Natural Scientific Services cc. April 2015. Glencore Alloys. Land Function Analysis – Waterval.

Annexure G3: Aquatico Scientific (Pty) Ltd. January 2018, February 2018 and March 2018. Glencore – Western Chrome Mines – Waterval Mine. Monthly Water Quality Report.

Annexure G4: Clean Stream Biological Services. April 2018. “Glencore Chrome RTB (Merafe) – Kroondal; Biomonitoring of the Hex River catchment”.

Annexure G5: Annual groundwater monitoring report for 2014, titled: “Glencore Chrome, Area, Annual Report on Groundwater Monitoring Results for 2014”, dated December 2014.

Annexure G6: National Occupational Health and Safety Consultants. January 2018. Fallout Dust Sample Reports (Waterval).

Annexure G7: Ashreq Environmental and Occupational Hygiene Consultants. July 2012. Xstrata. Report on environmental noise monitoring. Waterval West Mine.

Annexure G8_1: Report titled: “Heritage Impact Assessment for the proposed tailings facility, Waterval Mine, Rustenburg Municipal District, North West Province”, dated June 2009 and compiled by J van Schalkwyk.

Annexure G8_2: Report titled: “Heritage Impact Assessment for the proposed tailings facility, Waterval Mine, Rustenburg Municipal District, North West Province”, dated June 2009 and compiled by J van Schalkwyk.

Annexure G9: Report titled: “Xstrata Alloys South Africa (Pty) Ltd: Report on Geohydrological Investigation as part of the EMPR Amendment for the proposed Waterval Chrome Opencast Mine and tailings facility”, dated May 2009 and compiled by Clean Stream Groundwater Services.

1 Documents as included under Annexure H are existing information (in some cases specialist studies) generated in the past for the Kroondal Chrome Mine’s EMP purposes. It should be noted that these studies were conducted prior to the promulgation of the 2014 EIA Regulations, but the content of such studies remain applicable for inclusion into this Consolidated EIA and EMPr document.

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Annexure G10: Report titled: “Conceptual Storm water management plan for Xstrata Alloys – Waterval East Operation”, draft, dated March 2011, compiled by Metago.

Annexure H: MRD Codes of Practice (COP’s)

Annexure I: Rehabilitation Plan

Annexure J: Financial Provision

Annexure K: Mining Works Programme References Annual groundwater monitoring report for 2014. Glencore Chrome, Rustenburg Area, Annual Report on Groundwater Monitoring Results for 2014, dated December 2014.

Aquatico Scientific (Pty) Ltd. 2015, February 2015 and March 2015. Glencore – Western Chrome Mines – Waterval Mine. Monthly Water Quality Report.

Ashreq Environmental and Occupational Hygiene Consultants. July 2012. Xstrata. Report on environmental noise monitoring. Waterval West Mine.

B.B. Mabuza and D.G. Paterson. 2007. Report for Xstrata Mining Division (Pty) Ltd by the Institute for Soil, Climate and Water. Agricultural Research Council. Soil Investigation in the Waterval area

BEAL. December 2009. Xstrata Mining Pty (Ltd) Design Report for the new Tailings Facility at Waterval Chrome Mine

Clean Stream Groundwater Services. 2009. Xstrata Alloys South Africa (Pty) Ltd: Report on Geohydrological Investigation as part of the EMPR Amendment for the proposed Waterval Chrome Opencast Mine and tailings facility

Clean Stream Biological Services. 2015. “Glencore Chrome RTB (Merafe) – Kroondal; Biomonitoring of the Hex River catchment”.

J van Schalkwyk. 2009. Heritage Impact Assessment for the proposed tailings facility, Waterval Mine, Rustenburg Municipal District, North West Province

Metago. 2011. Conceptual Storm water management plan for Xstrata Alloys – Waterval East Operation.

National Occupational Health and Safety Consultants. 2015. Fallout Dust Sample Reports (Waterval).

Natural Scientific Services cc. 2015. Waterval Biodiversity Assessment: Glencore Alloys.

Natural Scientific Services cc. 2015. Glencore Alloys. Land Function Analysis – Waterval.

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PART A

SCOPE OF ASSESSMENT AND ENVIRONMENTAL IMPACT ASSESSMENT REPORT

Introduction (Executive Summary)

Glencore Alloys is involved in the mining of Chrome and Platinum Group Metals (“PGM’s") and the manufacture of ferro-alloys. The company was known as Xstrata Alloys prior to the merger of Glencore International plc and Xstrata plc in May 2013.

Figure 1: Current corporate structure of Glencore Operations South Africa (Pty) Ltd (SLP, 2014-2018)

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Waterval Mine is an existing mining operation situated 3 km east of Rustenburg in the North West Province on various portions and holdings of the farm Waterval 306 JQ. The main aim of the operation is to produce silica ore for the ferrochrome furnaces of Xstrata, situated in the Rustenburg area. The silica ore fragments are obtained through blasting, crushing, washing, drying and screening.

An Environmental Management Programme Performance Assessment (‘EMP PA”) was conducted in November 2013 by CHEMC Environmental on the approved EMPr, dated 2009. Subsequently, Glencore Operations SA (Pty) Ltd appointed Shangoni Management Services to undertake another Environmental Audit on compliance with and adequacy of the 2009 EMPr, (as per Regulation 34 of the Environmental Impact Assessment (“EIA”) Regulations, dated December 2014). The latest Environmental Audit report, dated July 2016, concluded that the approved EMPr, dated 2009, and the EMPr addendum provides sufficient detail on environmental risks and mitigation requirements pertaining to the activities being undertaken on the mine. However, it was identified that there are a limited number of EMPr commitments that are not applicable to the activities currently undertaken at Waterval Mine. The author’s opinion was that this EMPr amendment and consolidation continue.

Further to the above, the following additional reasons resulted in a decision to amend and consolidate the Waterval Mine EMPr:

• Consolidated the following approved EMPr’s into one EMPr: o Environmental Management Programme report for the Xstrata Waterval Chrome Mine, dated July 2009 and compiled by CHEMC environmental; o Environmental Impact Assessment and Environmental Management Programme, Waterval PGM plant EMPr, dated 2011 and compiled by Environmental and Energy Services; and

Waterval Mine has recently obtain a new section of mining right (Section 11 consent, in terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002) (“MPRDA”) from the adjacent Samancor Chrome: WCM Millsell – Waterkloof operation). Refer also to Annexure C

• More up-to-date information is available on the various environmental aspects in the form of specialist studies and monitoring data for inclusion into the EMPr; • Various new environmental legislative publications have occurred since the previous EMPr and EMPr addendum, dated 2009 and 2011 were approved; and • Practical Management and Mitigation Measures, in compliance with the latest environmental legislation needed to be incorporated into the EMPr.

Shangoni Management Services (Pty) Ltd was appointed by Glencore Operations South Africa (Pty) Ltd as the independent Environmental Assessment Practitioner (EAP) to facilitate the updating and consolidation of the Glencore Waterval Mine’s Environmental Impact Assessment Report (“EIAR”) and Environmental Management Programme Report (EMPr). This EIAR and EMPr intends on superseding all prior EMPrs previously compiled and approved for the mine, and serves the purpose of incorporating and consolidating all currently approved activities at the mine up to February 2020.

This EIAR and EMPr includes information from the following previous EMPr’s:

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• CHEMC Environmental, July 2009 (approved in December 2010). Xstrata Alloys Environmental Management Programme Reports Update (hereafter referred to as the ‘Updated EMPR, 2009’), which incorporated the following older EMPr’s: ‹ Waterval Mine Environmental Management Programme Report (January 2002), and ‹ Addendum to the Environmental Management Programme Report (2004); and • Environmental and Energy Services, 2011. Environmental Impact Assessment and Environmental Management Programme, Waterval PGM plant EMPr, (hereafter referred to as the ‘PGM EMPR, 2011’). • M2 Environmental Connections cc, 2010. Environmental Management Programme Report for Samancor Chrome Limited (Western Chrome Mines): Millsell - Waterkloof Section on various portions of the farm Waterkloof 305 JQ, North West Province (hereafter referred to as the ‘Millsell - Waterkloof EMPR, 2010’).

Table 1: Summary of Environmental Applications and Authorisation

Date of Type of Prepared by and Authorisation and Date Document name document Reference Number Competent Authority Approved 14 December 2010 Xstrata Alloys Environmental Department of Management CHEMC Mineral Resources Environmental Programme Environmental. 2009 Management Refer also to Error! Reports Update Programme (EMP) No Reference Reference source (hereafter referred Number. not found. below to as the ‘Updated and Annexure C for EMPR, 2009’). details on the various Mining Rights

Environmental Management Programme Report for Samancor Approved Chrome Limited Environmental M2 Environmental. (Western Chrome 10 June 2014 2010 Management Connections cc Mines): Millsell - Programme (EMP) Department of Waterkloof 30/5/1/2/3/2/2/479 EM Mineral Resources Section on various portions of the farm Waterkloof 305 JQ, North West Province.

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Date of Type of Prepared by and Authorisation and Date Document name document Reference Number Competent Authority Xstrata Alloys Environmental Management Programme for the proposed new Tailings dam for Approved Waterval Chrome Mine (hereafter Mining Right 29 June 2011 Environmental referred to as the Reference Number: Department of Impact 2010 / “Tailings dam NW 30/1/2/2/246 MR; Economic Assessment (EIA) 2011 EMP, 2011”). Development, and Environmental NWDACE Reference Environment, Authorisation Environmental Number: Authorisation for NWP/EIA/292/2008 Conservation and the construction of Tourism Xstrata Tailings (“DEDECT”) Dam on Portion 82 (a portion of Portion 2) of the farm Waterval 306JQ.

Confirmed not be listed activity in terms of GNR544, GNR545 and Proposed upgrade GNR546 of June of the current 2010 and does not storm water Basic Assessment require authorisation control canals and Report and Site Reference No: (letter dated 13 2011 dams at Waterval Inspection NWP/EIA/38/2011 October 2012) West Mine Outcome (letter) (Activity No 37 of Department of GNR.544, dated Economic June 2010) Development, Environment, Conservation and Tourism (“DEDECT”)

Environmental Authorisation for the proposed Approved upgrade of the 09 December 2011 current storm Basic Assessment water control Department of Report and canals and dams, Reference No: Economic 2011 Environmental and the NWP/EIA/36/2011 Development, Authorisation construction of a Environment, thickener at Conservation and Waterval East Tourism Mine (Activity No. (“DEDECT”) 37 of GNR544, dated June 2010)

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Date of Type of Prepared by and Authorisation and Date Document name document Reference Number Competent Authority Licence in terms of Integrated Water Chapter 4 of the Department of Water 11 January 2015 and Sanitation 2015 Use Licence National Water Department of Water (IWUL) Act, 1998 (Act 36 03/A22H/ABFGJ/2749 and Sanitation of 1998)

Table 2 below provides more detail with regards to the various mining rights granted to Waterval Mine and the farm portions associated therewith. Table 3 provides information on the surface rights and title deeds of the relevant farm portions.

Table 2: Waterval Mine approved mining rights issued by the Department of Mineral Resources

Farm portions included in Mining Right Description of Mining Right Mining Right Portions 45 and 97 of the farm Rustenburg Town and Converted Mining Right: File Townlands 272 JQ and No’s: Holdings 25 and 26, Portion 1 of Holding 27, Portions 27, 30, • Conversion of old order Mining NW30/5/1/2/2/157 MR 31, 32, 34 (all portions of Right: Converted in terms of Portion 2) and Mineral area 1 • NW30/5/1/2/2/244 MR Item 7 of Schedule II of on Remainder of Portion 2, and MPRDA. • NW30/5/1/2/2/246 MR Portions 35, 36, 37, Mineral area 1, Holdings 21, 22, 23 and 20 February 2007 Remaining Extent of Holding 24, all of the farm Waterval 306 JQ.

Amended / varied by the Portions 45 and 97 of the farm inclusion of Platinum Group Rustenburg Town and Metals, Nickel ore, Copper ore, Townlands 272 JQ and Amendment / Variation of a Cobalt ore, Iron ore and Silver Holdings 25 and 26, Portion 1 Mining Right: File No’s: ore (excluding Platinum Group of Holding 27, Portions 27, 30, • Metals and Minerals mines out NW30/5/1/2/2/157 MR 31, 32, 33, 34 (all portions of of necessity in the mining of Portion 2) and Mineral area 1 • NW30/5/1/2/2/244 MR platinum group metals found in on remainder of Portion 2, and the UG2 and Merensky Reefs; • NW30/5/1/2/2/246 MR Portions 35, 36, 37, Mineral and Portions 7, 8 and 145 of the area 1, Holdings 21, 22, 23 and farm Rustenburg Town and 22 December 2014 Remaining extent of Holding Townlands 272 JQ, thereby 24, all of the farm Waterval 306 extending the original mining JQ. rights area.

Portion 1(RE), Portion 3, Portion 7, Portion 8, Portion 9, Portion 10 (RE), Portion 11, Mining Right: File No: Mining Right transferred to Portion 12 of the Farm Waterval Mine in terms of • NW30/5/1/2/2/260 MR Waterval 307JQ. Section 11 of MPRDA. Portion RE of the farm Waterval 581JQ and a Portion of Portion 1 of the Farm Waterval 581JQ.

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Farm portions included in Mining Right Description of Mining Right Mining Right A portion of Portion 53 (RE) of the Farm Waterkloof 305JQ.

Refer to Annexure C for copies of the mining rights listed above. Furthermore, Figure 3 below shows the mining rights boundary of Waterval Mine. Table 3: Surface rights owners and title deeds numbers

Property Farm portions Title deed no Surface rights owner size Portion 135 of the Farm Town and T15039/1976 1.0 ha Republic of South Africa Townlands of Rustenburg 272 JQ

Portion 136 of the Farm Town and T18494/1987 Unknown Unknown Townlands of Rustenburg 272 JQ

Portion 137 of the Farm Town and T40140/1979 1.8 ha Republic of South Africa Townlands of Rustenburg 272 JQ

Portion 138 of the Farm Town and 29.2608 Provincial Government of the T17253/1977 Townlands of Rustenburg 272 JQ ha North-West Province

Portion 141 of the Farm Town and T28281/1981 0.44 ha Municipality of Rustenburg Townlands of Rustenburg 272 JQ

Portion 53 of the Farm Waterkloof 16.3412 T15249/2003 SAMANCOR Chrome Ltd. 305 JQ ha

Portion 2 of the Farm Waterval 2394182 T2465/1961 Rustenburg Platinum Mines Ltd. 306 JQ ha

Portion 27 of the Farm Waterval 50.2310 Glencore Operations South Africa T104380/2000 306 JQ ha (Pty) Ltd.

Portion 33 of the Farm Waterval Glencore Operations South Africa T152202/1999 9.4331 ha 306 JQ (Pty) Ltd.

Portion 34 of the Farm Waterval Glencore Operations South Africa T152202/1999 9.6324 ha 306 JQ (Pty) Ltd.

Portion 75 of the Farm Waterval Unknown 306 JQ

Portion 76 of the Farm Waterval Unknown 306 JQ

Portion 81 of the Farm Waterval 12.5251 T60892/2003 Xvest Invc 2009 cc 306 JQ ha

Portion 82 of the Farm Waterval 121.7951 Glencore Operations South Africa T4731/2004 306 JQ ha (Pty) Ltd.

Portion 116 of the Farm Waterval T83629/2013 1.5 ha ADLU Projects cc 306 JQ

Portion 26 of the Farm Waterval Unknown SH 450 JQ

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Property Farm portions Title deed no Surface rights owner size Portion 1 of the Farm Waterval 12.5437 T74967/2014 Rustenburg Local Municipality 307 JQ ha

Portion 7 of the Farm Waterval T39996/2013 9.6433 ha Rustenburg Local Municipality 307 JQ

Portion 8 of the Farm Waterval T74967/2014 9.3982 ha Rustenburg Local Municipality 307 JQ

Portion 9 of the Farm Waterval T74967/2014 6.9191 ha Rustenburg Local Municipality 307 JQ

Portion 3 of the Farm Waterval 27.4304 T39996/2013 Rustenburg Local Municipality 307 JQ ha

Portion 12 of the Farm Waterval T112737/2003 4.4996 ha Bouvest 2263 cc 307 JQ

Portion 10 of the Farm Waterval 56.4776 T74967/2014 Rustenburg Local Municipality 307 JQ ha

Portion 11 of the Farm Waterval 11.1500 T83347/2004 Rustenburg Platinum Mines Ltd 307 JQ ha

1 Details of project applicant and environmental assessment practitioner 1.1 Details of the project applicant

Name of operation Waterval Mine

Applicant Glencore Operations South Africa (Pty) Ltd

Postal address PO BOX 310, KROONDAL, 0350

Responsible person Annah Ngope

Telephone no. 014 597 8163

Fax no. 014 597 8408

e-mail address Annah.Ngope @glencore.co.za

1.2 Details of the environmental assessment practitioner

EAP Shangoni Management Services (Pty) Ltd.: Ashley Miller

Tel No (012) 807 7036

Fax No (012) 807 1014

e-mail Address [email protected]

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1.3 Expertise of the environmental assessment practitioner

Name and Surname Qualifications and summary of experience Brian is a registered professional engineer (Chemical) with a Brian Hayes (Technical master’s degree in Environmental Engineering from the reviewer) University of Nottingham. Brian has 26 years’ experience in environmental management and environmental engineering.

Ashley obtained his B.Sc (Honours) degree in Environmental Analysis and Management through the University of Pretoria. Ashley is part of the Mining Department at Shangoni Management Services (Pty) Ltd. and has experience in Environmental Management Programme Reports (“EMPr”), Environmental Impact Assessments (“EIA”), Scoping Reports and Basic Assessments. He also has experience in Integrated Ashley Miller Water and Waste Management Plans (“IWWMP”), Integrated Water Use Licence Applications (“IWULA”), Water Use Licence audits as well as Environmental Management Programme Performance Assessment audits. Ashley has also gained valuable experience in Geographic Information Systems (“GIS”) in terms of compiling regional, locality and infrastructure maps as well as in-depth mine plans.

2 Description of the property

Table 4: Description of the properties applicable to the proposed Waterval Mine project

Various portions and holdings of the farm Waterval 306 JQ and Farm name Waterval 307 JQ. • 616.9699 hectares (as per existing approved mining rights 244MR 246MR 157 MR and 192MR) Application area (ha) • 389.3787 hectares (as per additional mining right area 260MR)

Bojanala District Municipality Magisterial district Rustenburg Local Municipality (“RLM”)

Distance and direction from 3 km east of Rustenburg in the North West Province nearest town T0JQ00000000027200135 T0JQ00000000027200136 T0JQ00000000027200137 21-digit Surveyor General T0JQ00000000027200138 code for each farm portion T0JQ00000000027200141 T0JQ00000000030500053 T0JQ00000000030600002

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T0JQ00000000030600027 T0JQ00000000030600022 T0JQ00000000030600034 T0JQ00000000030600075 T0JQ00000000030600076 T0JQ00000000030600081 T0JQ00000000030600116 T0JQ00000000045000026

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3 Locality of the project 3.1 Location of the project Area

Figure 2: Locality Map of the Waterval Mine

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3.2 Location of the operation

Figure 3: Mining Rights Boundary of the Waterval Mine

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Figure 4: Farm portions relevant to Waterval Mine

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4 Description of the scope of the proposed activity 4.1 Listed and specified activities applied for

Table 5: Activities and listed activities associated with the existing operation

ARIAL LISTED APPLICABLE LISTING NAME OF ACTIVITY EXTENT OF ACTIVITY NOTICE ACTIVITY (mark with (GNR 544, GNR 545 or GNR Ha or m² X) 546)/NOT LISTED Total extent of mining rights area (in terms of farm portions): This activity forms part of the • 616.9699 Waterval East and Waterval approved mining rights and West: hectares (as EMPr (in terms of the MPRDA, 2002) for Waterval Underground mining and per existing Mine. associated activities (including the approved following): This activity is also mining rights considered to form part of an • Marking, drilling and blasting of existing ‘Environmental 244MR Authorisation’ for the mine. holes; - 246MR 157 The mining activities (as per • Provision of support all mentioned mining rights MR and covered in this EIAR / EMPr) (underground); 192MR) were also included in the • Engineering activities approved EMPr, dated 2009. • 389.3787 The activities commenced (underground); hectares (as prior to the promulgation of • Shafts and Ventilation Shafts the EIA Regulations (GN. R per 385, GN. R 386 and GN. R additional 387), dated April 2006. mining right area 260MR)

Linear activity. Waterval East and Waterval These activities were Refer to Error! West: included in the approved Reference EMPr, dated 2009 and are Transporting of ore from source not - therefore considered to form underground to an area adjacent to found. for aerial part of the existing the plant area by means of a view of environmental authorisation conveyor. conveyors on for Waterval Mine. the mine.

Waterval East

Loading of ore at pickup area by These activities were means of a front-end loader into the Total plant area: - included in the approved jaw crusher. EMPr, dated 2009 and are

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ARIAL LISTED APPLICABLE LISTING NAME OF ACTIVITY EXTENT OF ACTIVITY NOTICE ACTIVITY (mark with (GNR 544, GNR 545 or GNR Ha or m² X) 546)/NOT LISTED Ore-processing: Crushing and ± 4.68 Ha therefore considered to form (including all part of the existing Screening stockpiles) environmental authorisation for Waterval Mine. Ore-processing: Washing

Waterval West Loading of ore at pickup area by means of a front-end loader into the jaw crusher. Total plant area: ± 8.56 Ha - Ore-processing: Crushing and (including all Screening stockpiles) These activities were included in the approved Ore-processing: Washing EMPr, dated 2009 and are therefore considered to form Linear activity. part of the existing Waterval East and Waterval Refer to Error! environmental authorisation West: Reference for Waterval Mine. Conveying of ore within the plant source not - area (from crushing and screening found. for aerial to washing plant and to various view of stockpiles) (i.e. use of conveyors). conveyors on the mine.

Waterval East

Stockpiling of topsoil - These activities were Total plant area: included in the approved Stockpiling of waste rock on waste - EMPr, dated 2009 and are rock dumps ± 4.68 Ha therefore considered to form (including all part of the existing stockpiles) Stockpiling of Chrome product - environmental authorisation for Waterval Mine.

These activities were Pumping of tailings (via pipelines): Linear activity. included in the approved EMPr, dated 2009, and the • From washing plant to Refer to Figure approved EMPr, dated 2011, - thickener, and 5 for aerial view and are therefore considered of pipelines on • to form part of the existing From thickener to existing TSF. the mine. environmental authorisation for Waterval Mine.

Waterval West

Stockpiling of topsoil - These activities were Total plant area: included in the approved Stockpiling of waste rock on waste - EMPr, dated 2009 and are rock dumps ± 8.56 Ha therefore considered to form (including all part of the existing stockpiles) Stockpiling of Chrome product - environmental authorisation for Waterval Mine.

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ARIAL LISTED APPLICABLE LISTING NAME OF ACTIVITY EXTENT OF ACTIVITY NOTICE ACTIVITY (mark with (GNR 544, GNR 545 or GNR Ha or m² X) 546)/NOT LISTED These activities were Pumping of tailings (via pipelines): Linear activity. included in the approved EMPr, dated 2009, and the • From washing plant to Refer to Figure approved EMPr, dated 2011, - thickener, and 5 for aerial view and are therefore considered of pipelines on • to form part of the existing From thickener to existing TSF. the mine. environmental authorisation for Waterval Mine.

Waterval East and Waterval West: These activities were Operation and maintenance of included in the approved process water storage and EMPr, dated 2009 and are pumping facilities at the plants. - - therefore considered to form Refer to Error! Reference source part of the existing not found. below for a list of the environmental authorisation process water dams at Waterval for Waterval Mine. Mine.

Waterval East and Waterval West: Pumping of process water via These activities were pipelines: Linear activity. included in the approved EMPr, dated 2009, and the • Within the plant process; Refer to Figure approved EMPr, dated 2011, 5 for aerial view - • Between storage facilities; and are therefore considered of pipelines on to form part of the existing • From the storm water dam and the mine. environmental authorisation return water dam back to the for Waterval Mine. process (from existing TSF).

Waterval East TSF & These activities were Waterval East and Waterval infrastructure: included in the approved West: ± 7.45 Ha EMPr, dated 2009, and are Operation and maintenance of - therefore considered to form Waterval West existing TSF and associated part of the existing TSF & infrastructure. environmental authorisation infrastructure: for Waterval Mine. ± 7.05 Ha

The storm water management measures indicated in Error! Waterval East and Waterval Reference source not West: Linear activity. Forms part of found. and Error! Operation and maintenance of the overall - Reference source not storm water and dirty water mining found., include both existing management measures (channels, activities. and proposed measures for berms etc.) within the mining area. Waterval East and Waterval West. Existing storm water management measures were included in the

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ARIAL LISTED APPLICABLE LISTING NAME OF ACTIVITY EXTENT OF ACTIVITY NOTICE ACTIVITY (mark with (GNR 544, GNR 545 or GNR Ha or m² X) 546)/NOT LISTED approved EMPr, dated 2009 and are therefore considered to form part of the existing environmental authorisation for Waterval Mine.2

Waterval East and Waterval West: Supply of water for domestic- and Not applicable - These activities were processing purposes: Abstraction included in the approved from boreholes and underground. EMPr, dated 2009, and are therefore considered to form Waterval East and Waterval Linear activity. part of the existing West: Refer to Figure environmental authorisation Pumping of borehole water (via 5 for aerial view - for Waterval Mine. pipelines) from abstraction points of pipelines on to clean water storage facilities. the mine.

Waterval East

These activities were included in the approved EMPr, dated 2009, and the approved EMPr, dated 2011, and are therefore considered Operation and maintenance of to form part of the existing - - clean water storage facilities. environmental authorisation for Waterval Mine. The Waterval Mine has further been issued with a Water Use Licence (Licence No.: 03/A22H/ABFGJ/2749).

Waterval West

These activities were included in the approved EMPr, dated 2009, and the approved EMPr, dated 2011, and are therefore considered Operation and maintenance of to form part of the existing - - clean water storage facilities: environmental authorisation for Waterval Mine. The Waterval Mine has further been issued with a Water Use Licence (Licence No.: 03/A22H/ABFGJ/2749).

2 Any new storm water management measures, as per Annexure H11 (storm water management plan), that trigger listed activities (if any) in terms of the EIA Regulations, dated 2014, will be applied for as part of an Environmental Authorisation Application prior to construction thereof.

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ARIAL LISTED APPLICABLE LISTING NAME OF ACTIVITY EXTENT OF ACTIVITY NOTICE ACTIVITY (mark with (GNR 544, GNR 545 or GNR Ha or m² X) 546)/NOT LISTED Waterval East and Waterval West: Use of borehole water: Plant processing activities, At septic tanks, and At change houses (ablution block), offices and workshops. Not applicable - Waterval East and Waterval West: Dust suppression activity on roads

Waterval East and Waterval West:

Operation and maintenance of These activities were septic tanks included in the approved EMPr, dated 2009 and are Waterval East and Waterval therefore considered to form West: part of the existing Maintenance activities: Workshop environmental authorisation area for Waterval Mine.

Waterval East and Waterval West: Possible on-site maintenance activities: Mining area Waterval East Waterval East and Waterval workshop, West: maintenance and waste Washing of vehicles management Waterval East and Waterval areas: West: ± 2.07 Ha - Storage, offloading and refuelling Waterval West of hazardous substances (e.g. workshop, hydrocarbons (diesel and oil); maintenance chemicals etc.) and waste management areas: These activities were Waterval East and Waterval included in the approved West: ± 2.95 Ha EMPr, dated 2009 and are therefore considered to form Waste management activities on part of the existing the mine, including: environmental authorisation • The operation of the Salvage and waste management licence for Waterval Mine. Yard; Furthermore, Waterval Mine • Storage, handling, removal and has a waste management licence (dated September disposal of general waste; 2013) (Ref: 12/9/11/L726/7) in terms of the National

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ARIAL LISTED APPLICABLE LISTING NAME OF ACTIVITY EXTENT OF ACTIVITY NOTICE ACTIVITY (mark with (GNR 544, GNR 545 or GNR Ha or m² X) 546)/NOT LISTED • Storage, handling, removal and Environmental Management: Waste Act, 2008 (Act 59 of disposal of hazardous waste 2008) (Government Notice and old oil; (GN) 718, dated July 20093), for the following waste • Storage, handling, removal and management activities: disposal of medical waste; and Category A (1); (2) and (19). • Waste re-use and recycling activities.

Waterval East Waterval East and Waterval offices and West: change house Use and maintenance of: areas: • Security entrance; ± 1.08 Ha - • Weighbridge; Waterval West offices and • Office(s); and These activities were change house included in the approved • Change houses (ablution block). areas: EMPr, dated 2009 and are ± 1.97 Ha therefore considered to form part of the existing Waterval East environmental authorisation explosive for Waterval Mine. depot: Waterval East and Waterval West: ± 0.08 Ha - Operation and maintenance of Waterval West explosives magazine explosive depot: ± 0.39 Ha

3 The list of Waste Management Activities that have, or are likely to have, a detrimental effect on the environment published under Government Notice (GN) 718, dated July 2009, in terms of section 19(2) of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008), has since been amended as part of GN 921, dated November 2013 and GN 633, dated July 2015. Category A(1), A(2) and A(3) are now regarded as Category C activities (for compliance with certain norms and standards, where relevant).

Transitional Provision No. 5 of GN 921 states that “A person who lawfully conducted a waste management activity that is no longer listed in Category A or B, but listed in Category C of this Schedule, on the date of coming into effect of this Notice, may continue with the waste management activity for the duration stipulated in the permit or waste management licence until the expiry date of the permit or waste management licence whereafter such a person must comply with the requirements or standards for that waste management activity.”

As per condition 13.11 of the waste management licence, the licence is valid for a period of 10 years (i.e. up until January 2023).

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ARIAL LISTED APPLICABLE LISTING NAME OF ACTIVITY EXTENT OF ACTIVITY NOTICE ACTIVITY (mark with (GNR 544, GNR 545 or GNR Ha or m² X) 546)/NOT LISTED Waterval East and Waterval West: Not Applicable - Use and / or maintenance of transformers.

Rehabilitation activities during the Decommissioning Phase, including: • Removal / demolition of mine Rehabilitation and Closure- infrastructure; related activities were included in the approved • Sloping and levelling of all EMPr, dated 2009. However, previously disturbed areas to Waterval Mine has a Refer to area remaining Life of Mine in sustainable free-draining land extent for - excess of 30 years. forms; activities above. Any additional necessary • Topsoil placement (where Refer also to authorisations for Annexure I. decommissioning and applicable); rehabilitation activities, will • Re-vegetation; and be applied for in future, where required.

Shaping, capping and vegetating of TSF’s.

Mine Closure -

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Figure 5: Final Site Layout Plan

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4.2 Description of activities undertaken

4.2.1 Minerals mined

The minerals mined at Waterval Mine are listed in the table below. The primary mineral mined is

2+ 3+ chromite (with general formula (Mg, Fe ) (Cr, Al, Fe )2 O4).

The mineral deposit is developed to the east of the town Rustenburg with the ore body that dips towards the north and strikes east-west. The main target for the mining at Waterval Mine is the LG6 Chromitite Package. The package consists of the LG6A Chromitite Layer which is separated from the LG6 Chromitite Layer by the LG6 Pyroxenite Middling.

Table 6:Minerals mined (source: Amended Mining Works Programme, dated January 2012)

Primary/ Definition as per Mineral Formula Description Associated MPRDA

Mineral is Code: Cr developed in Upper, Middle- Commodity: Chrome Ore General formula; and Lower Group Chromite Primary Chromitite 2+ 3 Type_Code: B (Mg,Fe )(Cr,Al,Fe )2 O4 Layers in the Critical Zone of Type_Description: the Bushveld Ferrous and base Complex. metals

All ore minerals bearing Code: PGM Platinum, Palladium, Commodity: Includes the formula of all Osmium, Iridium, Platinum Group Platinum ore minerals bearing Rhodium & Metals Group Associated platinum group minerals Ruthenium) Minerals Type_Code: PGM (Pt, Pd, Os, Ir, Ru & Rh) Metals are developed in the Type_Description: various layers of Platinum Group the Bushveld Minerals Complex.

Code: Cu Commodity: Includes the formula of all All ore minerals Copper Ore Copper Ore Associated ore minerals bearing bearing copper Minerals Type_Code: B copper (Cu) (Cu). Type_Description: Ferrous and base metals

Code: Au Includes the formula of all Gold Ore All ore mineral Commodity: Gold Associated ore minerals bearing gold Minerals bearing gold (Au) Ore (Au) Type_Code: GS

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Primary/ Definition as per Mineral Formula Description Associated MPRDA Type_Description: Gemstones (except diamonds)

Code: Ni Commodity: Nickel Includes the formula of all All ore mineral Ore Nickel Ore Associated ore minerals bearing bearing nickel Minerals Type_Code: B nickel (Ni) (Ni) Type_Description: Ferrous and base metals

Code: Au Commodity: Lead Includes the formula of all Lead Ore All ore mineral Associated ore minerals bearing lead Type_Code: B Minerals bearing lead (Pb) (Pb) Type_Description: Ferrous and base metals 5The Mining Works Programme is available from the mine upon request

4.2.2 Description of the main mining activities and processes

Currently, the Waterval operations focus on underground mining. The descriptions of the current activities at Waterval Mine are detailed in Table 5 above and illustrated on Figure 5. Waterval Mine is divided into a Waterval East and a Waterval West section. Refer to Figure 6 below.

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Figure 6: Waterval East and Waterval West Sections

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4.2.2.1 Current infrastructure and activities

Current infrastructure and activities at Waterval Mine include:

Current and proposed (authorised) Waterval Mine infrastructure, areas and activities: • Underground mining and associated activities (including the following): o Marking, drilling and blasting of holes; o Provision of support (underground); o Engineering activities (underground); o Shafts and Ventilation Shafts

• Buildings and parking areas; • Beneficiation plants; • Conveyors systems; • Topsoil stockpiles; • Security buildings; • Workshops; • Change houses; • Explosives magazine areas; • Training Centre; • Medical Centre; • Compressor house; • Salvage Yard; • Sub-stations and transformers; • Roads; • Powerlines; • Telephone lines; • Weighbridge; • Monitoring boreholes; • Water metres; • Fences; • Diesel storage tanks and refuelling areas; • Water and mining waste management infrastructure and facilities, including: o Silt traps, sumps and trenches; o Storage of water pumped from borehole(s) used for irrigation at Waterval East; o Other potable water tanks / dams; o East Storage dam ESD1; o East Storage dam ESD2; o New Earth / Return Water Dam ESD3; o Main Supply dam ESD4; o Water Supply Dam ESD9;

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o Cement Dam ESD5; o West Earth Dam WSD1; o West Earth Dam WSD2; o Penstock Overflow WSD3; o West Erickson dam WCD6; o East Slimes dam ESD7; o West Slimes dam WSD7; o West Waste Rock Dump; o East stockpiles (ROM); o West stockpiles (ROM); o West stockpile (product); o Waterval new Tailings Storage Facility (yet to commence); o New storm water dam; o New Return Water Dam; o West Septic tank WST1; and o West Septic tank WST2.

• Water supply networks; • Process / return water pipelines; • Pumps; • Tailings pipelines; • Use of water from underground (dewatering) for processing and irrigation (licenced i.t.o NWA, 1998) as well as for safety purposes; and • Discharging of water dewatered from underground workings into the Hex River through a pipe (licenced i.t.o NWA, 1998).

Possible future infrastructure and activities (authorisation not applied for / received yet): The following infrastructure is proposed for the future: • Proposed store road; • Opencast mining.

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Table 7:Photographs showing some of the infrastructure and facilities at Waterval Mine

Waterval East

Rondawel dam Workshop areas

Flammable substance storage Plant and conveyor system

Above-ground diesel storage and refuelling Decline entrance for chairlifts area

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Waterval East

General and waste storage areas Oil skimming bay

Ventilation shaft Waste skips

Water management infrastructure at plant Potable water tank

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Waterval East

Entrance to Salvage Yard Plant and conveyor system

Hazardous substance storage areas (e.g. Transformer Paint store)

4.2.2.2 Mining Method

The mining method currently applied at the Glencore Waterval Mine is room and pillar underground mining. Room and pillar is a mining system in which the mined material is extracted across a horizontal plane, creating horizontal arrays of rooms and pillars.

Pillars of 6m wide by 12m long are spaced at 16m centres on dip and strike. Typical extraction ratios of 73% are being achieved.

Glencore Waterval Mine has also applied for the mining of Platinum Group Metals (“PGMs”), for which the mining rights were granted. Refer to Annexure C and Table 2 above. Traditional chrome mining as is currently done, will continue. The mine is already operational and Glencore Waterval Mine will be removing its own tailings from the TSF footprint (as well as the underflow from the current chrome processing plant) and process it again for minerals other than chrome (PGM’s and associated minerals). The waste currently emanating from the chrome plant will also be redirected to the new PGM flotation section for further processing. The resulting slimes from the PGM plant will then be deposited onto a temporary TSF and once the current footprint is processed, it will be lined, and the tailings will be pumped to the “new” TSF that will lie on the current TSF footprint.

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4.2.2.3 Ore Processing

There are two main plants in the Waterval Mining Complex - Waterval West plant and Waterval East plant. All ore is transported to the Waterval plants for main crushing and washing.

Run of mine is received from the underground workings at -400mm in size averaging 28%Cr2O3 and

20%SiO2. The ore is crushed by using a jaw crusher and reduced to a -90mm material. The crushed ore is processed in the screening plant whereby it is classified into different size fractions. The ore is then classified into the following size fractions:

• 90mm +17.5mm Lumpy ore; • 17.5mm +0.85mm Chips ore; and • 0.85mm Fines ore.

Lumpy ore is upgraded via a Drum Separator to a Lumpy saleable product of 39% Cr2O3 and 8.5%

SiO2.

The chips product is upgraded via a Dense Medium Cyclone to a -17.5mm +0.85mm chips product.

This product is screened into 2 fraction sizes, namely the+10mm at 38% Cr2)3 and 9% SiO2 and -10mm at 37% Cr2O3 and 10% SiO2.

Fines are upgraded in the Spiral plant by the use of a gravity separation method into three saleable products, namely:

• Metallurgical grade of 43.5% Cr2O3 and 3.5% SiO2;

• Chemical grade of 46.0% Cr2O3 and 1% SiO2; and

• Foundry grade of 46.0% Cr2O3 and 1% SiO2.

Product - Lumpy and Chips Product

Heavy Medium Plant

Waste Product oversize

Run of mine Ore stockpiling Crusher Plant Ore stockpiling Screening Plant

Product - Foundry Sand, Metgrade and Chemical

undersize Grade

Gravity concentration

Waste Product Figure 7: Waterval plant schematic diagram (Waterval MWP)

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Figure 8: PGM Plant flow (Waterval MWP)

The proposed PGM plant project plans to collect the tailings underflow, which was previously deposited on the tailings dam, and to treat it before it is passed through a flotation cell. A platinum flotation plant, tailings facility, pipelines and storm water management infrastructure will be established on the same footprint as the current Waterval Chrome plant. The reclamation and excavation of the old and current tailings facility will be done first. This involves pushing the top tailings from the top down to the loading area to form a slope. The stability of the dump renders it unsafe to load it from the bottom as the tailings easily form a high wall which can cave in onto the loader. The material is then screened to remove all foreign, metallic and oversize particles. It is then hauled with a dumper truck to a plant stockpile area. Only in-mine roads will be used. The tailings are then dumped in a feeder bin and conveyed into the plant.

Pipes, pumps and valves will be constructed to ensure all underflow water from the current chrome facility is pumped to the PGM plant when needed.

The plant feed will consist of two types of material, namely: • Current material arising from the Waterval chrome plant (Approximate feed rate: 19 t.hr-1); and • Slimes dump material from the Waterval tailings dams (Approximate feed rate: 11t.hr-1).

Both of types of material have an approximate PGM grade of 4-7g.t-1. The slimes material is oxidized to some degree and this does hamper flotation. This material will need some form of milling and attritioning to polish the surfaces so that the material can be susceptible to floatation. High Energy flotation cells will be used (with absorbed power at 4-5 kW/m3 based on the normal running live cell volume). From Tailing Technology experience gained on similar applications, high energy is needed to float finer material, such as that of the Waterval tailings.

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Milling The objective of any milling for this type of application is not to grind the material finer but to just attrition- grind and polish the surfaces of the particles so that the reagents may act and enhance the recovery of material by flotation. From the test work done it can be seen that a large fraction of the PGM’s (84.8% and 78.5% in slimes dam and thickener underflow respectively) is in the -75um size fraction. Thus, further size reduction is not necessary, but only attritioning will be of an advantage for the flotation of the oxidised slimes dam material. From experience on a similar application, the ball mill is capable of achieving this, and operability is easier than that of a SMD. Slimes dump material is fed from the re-mining section at an SG of 1.4-1.6 t.m-1 at a federate of 11t/hr to the Feed Tank 1. Feed is then pumped at constant rate to the 250kW ball mill.

Flotation The primary flotation circuit will receive its feed from the 20m3 holding tank. The feed will be presented at a slurry density of 1.3 to 1.5 t.m-3, dry solids feedrate of 30t.h-1, and volumetric flowrate of between 46m3.h -1 and 74m3.h -1. The primary flotation bank will comprise of 6 x 15m3 (6 off) forced-draught, tank-type flotation cells arranged in series on individual steps. An inter-cell step height of 800mm will be accommodated in the design. This cell combination will provide an effective flotation volume of can 90m3 equating to a residence time of 44 minutes, including a 20% allowance for froth, mechanism and aeration volumes. The anticipated rougher circuit mass pull to concentrate is 8%, based on plant feed. Cleaners and re- cleaners will comprise of 4 x 10m3 (4 off) and 3 x 5m3 (3 off) flotation cells. The flotation bank will consist of 6 roughers, 4 cleaners and 3 re-cleaners.

The slimes material has the option of being pumped to Feed tank 2 or Rougher 3. From previous experience the slime dam material has been found to yield lower recoveries than the current arising material, and treating the current arising material separately can yield higher recovery than treating both materials together. The collector is added into the Feed tank. The frother is added into the rougher feed. Depressant is added into the rougher feed. All the rougher concentrates and re-cleaner tails gravitate down to the cleaner feed sump, which is pumped to cleaner feed. The cleaner concentrates gravitate to the recleaner feed and cleaner tails are pumped to the feed tank. As an optional measure, the cleaner tails can also be pumped to rougher tails if the grade is low enough, thus decreasing circulating loads of slow-floating material. The rougher tails are pumped to the tailings dam.

The re-cleaner 3 can also be converted to a Re-cleaner which could be necessary to get the final

concentrate to meet the following specifications: 150g/t and 3% Cr2O3. The final concentrate from the re-cleaner concentrator is then pumped to the thickener, and then to the filter press ready for dispatch.

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Figure 9: Surface Layout plan for Waterval East – Including PGM Project

Figure 10: Surface layout plan for Waterval West – Including PGM Project

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4.2.2.4 Mine and plant residue

Existing Glencore Waterval mine and plant residue facilities

The following mine and plant residue facilities are operational at Waterval Mine: • MRD: Waterval West Waste Rock Dump Status: Decommissioned (material trucked away for retreatment). Location: Farm Waterval 306JQ, (Portion 27) Residue type: Chrome residue All commodities produced when generating this residue: Chrome concentrates for Ferrochrome and chemical uses • MRD: Waterval East Waste Rock Dump Status: Decommissioned (material trucked away for retreatment). Location: Farm Waterval 306JQ, (Portion 33) Residue type: Chrome residue All commodities produced when generating this residue: Chrome concentrates for Ferrochrome and chemical uses • MRD: Waterval West Tailings Storage Facility (also referred to as the old tailings dam) Status: Not currently in use (full capacity). Location: Farm Waterval 306JQ, (Portion 27) Size: 9 ha Residue type: Chrome tailings All commodities produced when generating this residue: Chrome concentrates for Ferrochrome and chemical uses • MRD: Waterval East Tailings Storage Facility (also referred to as the old tailings dam) Status: Not currently in use Location: Farm Waterval 306JQ, (Portion 33) Size: 4 ha Residue type: Chrome tailings All commodities produced when generating this residue: Chrome concentrates for Ferrochrome and chemical uses Method of residue delivery: Cyclone Average monthly delivery to Residue deposit: Previously 10 000 tonnes / month Design Life: 2 years remaining

Refer to Annexure H for copies of the Mine Residue Deposit (“MRD”) Codes of Practice.

4.2.2.5 Transport and conveyance

General The Rustenburg / Pretoria tarred provincial road () bypasses the mine 0.5 km to the south. An un- tarred road from the (that lead from the N4) is used to access the mine.

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There are no railway lines on the mine site, nor does the mine use railways to transport ore. Employees are responsible for their own transport to the site.

Mineral transport on site Ore is transported on-site from the underground workings (via conveyors) to the processing plants. From the processing plants / mining areas, waste rock is transported to the waste rock dumps via conveyor and tailings to the TSF via pipeline.

Mineral transport off-site Ore is transported to the smelter(s) (off-site) via road transport (truck).

4.2.2.6 Water management

Water supply and use All potable water is obtained from the Rand Water Board. Water used in the processing plants is mainly water that is recycled from the return water dam, as well as small quantities from underground dewatering activities. The water in the plants is recycled and utilised in a closed water system.

Table 8: Section 21(a) licenced water use activities (WUL, 2015)

Description Source Properties Coordinates Volume

Water is pumped from Portion 33 of the underground workings in Underground 25°40’44.09” S farm Waterval 306 480 000 m3/a the mine and used in the dewatering JQ. 27°16’12.08” E processing plant

Abstraction of Portion 27 of the groundwater used as Borehole 25°40’36.05” S farm Waterval 306 32 602 m3/a make-up water for the WBH1 JQ 27°16’04.01” E plant

Abstraction of Portion 27 of the groundwater used as Borehole 25°40’33.08” S farm Waterval 306 32 602 m3/a emergency make up WBH3 JQ 27°15’36.04” E water for the plant

Abstraction of Portion 27 of the groundwater used for Borehole 25°40’35.05” S farm Waterval 306 51 m3/a irrigation of gardens at WBH9 JQ 27°15’45.02” E Head Office

Abstraction of Portion 27 of the groundwater used for Borehole 25°40’35.05” S farm Waterval 306 51 m3/a irrigation of gardens at WBH10 JQ 27°15’45.02” E Head Office

Abstraction of Portion 27 of the groundwater used for Borehole 25°40’44.09” S farm Waterval 306 51 m3/a irrigation of gardens at WBH4 JQ 27°15’47.06” E Head Office

Abstraction of Portion 26 of the groundwater used for 25°41’13.05” S Borehole EB3 farm Waterval 306J 64.2 m3/a irrigation of gardens at Q 27°15’45.07” E Waterval East

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Description Source Properties Coordinates Volume

Abstraction of Portion 26 of the groundwater used for 25°40’59.06” S Borehole EB4 farm Waterval 306J 64.2 m3/a irrigation at the Training Q 27°16’10.01” E Centre and Clinic

Table 9: Section 21(j) licenced dewatering activities (WUL, 2015)

Description Properties Coordinates Volume

Underground dewatering from Portion 33 of the farm 25°40’44.09” S underground mine workings for 1 440 000 m3/a Waterval 306 JQ. safety purposes. 27°16’12.08” E

Process water management facilities Waterval Mine is authorised (as per its Water Use Licence dated 11 January 2015) to dispose a maximum quantity (in m3/annum) into the waste and / or water management facilities, as listed in Table 10 below. Refer also to Figure 5 for an indication of the location of these facilities.

Table 10: Section 21(g) licenced process water management facilities (WUL, 2015)

Volume / Facility Location Coordinates Description Capacity

3 Disposal of storm East storage Portion 34 of the farm 25°40’58.60” S 253 630 m /a water runoff from the dam ESD1 Waterval 306 JQ 3 27°16’14.45” E (10 500m ) tailings

3 Disposal of storm East storage Portion 34 of the farm 25°42’59.88” S 253 630 m /a water runoff from the dam ESD2 Waterval 306 JQ 3 27°16’16.64” E (10 500m ) tailings

New Earth / 3 Disposal of storm Portion 34 of the farm 25°41’2.13” S 253 630 m /a Return water water runoff from the Waterval 306 JQ 3 dam ESD3 27°16’14.19” E (10 500m ) tailings

Disposal of underground water Main Water 3 into the main water Portion 34 of the farm 25°41’1.33” S 470 160 m /a Supply dam supply dam ESD4 to Waterval 306 JQ 3 ESD4 27°16’15.67” E (4 500m ) the Waterval East plant for use in the process

Disposal of underground water 3 into the main water Water Supply Portion 33 of the farm 25°41’59.50” S 470 160 m /a supply dam ESD9 to dam ESD9 Waterval 306 JQ 3 27°16’13.15” E (4 500m ) the Waterval East plant for use in the process

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Volume / Facility Location Coordinates Description Capacity Disposal of water pumped from Cement dam Portion 26 of the farm 25°44’4.57” S 299 620 m3/a underground into plant ESD5 Waterval 306 JQ 27°16’4.32” E (3180 m3) feed water Cement dam ESD5. Used in the processing plant

3 Disposal of storm West Earth Portion 27 of the farm 25°40’40.02” S 115 147 m /a water from Waterval Dam WSD1 Waterval 306 JQ 3 27°16’5.22” E (14 737 m ) West

3 Disposal of storm West Earth Portion 27 of the farm 25°41’4.57” S 115 147 m /a water from Waterval Dam WSD2 Waterval 306 JQ 3 27°16’4.32” E (14 737 m ) West

Penstock 3 Overflow of water from Portion 27 of the farm 25°41’4.57” S 77 989 m /a Overflow the Waterval West old Waterval 306 JQ 3 WSD3 27°16’4.32” E (9 375 m ) tailings

Disposal of water from underground dewatering. Used in West Erickson Portion 27 of the farm 25°40’44.10” S 183 960 m3/a the plant for dam WCD6 Waterval 306 JQ 27°15’49.03” E (3 400 m3) processing and also used for dust suppression on the roads.

Disposal of slimes into East Slimes Portion 33 of the farm 25°41’07.1” S 463 550 m3/a East slimes dam ESD7 dam ESD7 Waterval 306 JQ 27°16’07.4” E (45 328 m3) (old slimes dam that is no longer in use)

Disposal of slimes into 3 West Slimes Portion 27 of the farm 25°40’35.8” S 180 097 m /a West slimes dam dam WSD7 Waterval 306 JQ 27°15’53.8” E (42 464 m3) WSD7 (old slimes dam that is no longer in use)

West Waste Portion 27 of the farm 25°40’43.57” S 77 925 m3/a Disposal of waste rock Rock Dump Waterval 306 JQ 27°15’45.93” E

East stockpiles Holding 26 of the 25°41’07.09” S Stockpiling of ROM 608 m3/a (ROM) farm Waterval 306 JQ 27°16’00.67” E material

West None Portion 27 of the farm 25°40’45.68” S Stockpiling of ROM stockpiles specified in Waterval 306 JQ material (ROM) 27°15’51.28” E Licence

None West stockpile Portion 27 of the farm 25°40’48” S specified in Stockpiling of product (Product) Waterval 306 JQ 27°15’50” E Licence

Disposal of tailings into None Waterval new Portion 82 of the farm 25°40’37.86” S planned new TSF from specified in TSF Waterval 306 JQ Waterval West and 27°16’18.27” E Licence East plants

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Volume / Facility Location Coordinates Description Capacity Disposal of dirt storm 3 New Storm Portion 82 of the farm 25°40’39.25” S 35 000 m /a water from the TSF water dam Waterval 306 JQ 27°16’18.27” E (5000 m3) into a planned new storm water dam

3 New Return Portion 82 of the farm 25°40’39.25” S 6 250 m /a Disposal of dirt storm water dam Waterval 306 JQ 27°16’18.27” E (1000 m3) water from TSF

Dust suppression on Dust Portion 27 of the farm 25°40’46.42” S the haul roads using 53.86 m3/a suppression Waterval 306 JQ 27°15’41.95” E water taken from the West Erickson Dam

3 West Septic Portion 27 of the farm 25°40’48.66” S 182 m /a Disposal of sewage tank WST1 Waterval 306 JQ 27°15’45.29” E (7.65 m3) effluent from offices

West Septic Portion 27 of the farm 25°40’44.80” S 252 m3/a Disposal of sewage tank WST2 Waterval 306 JQ 27°15’47.09” E (10.5 m3) effluent from offices

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Figure 11: Waterval water flow diagram

Discharges Waterval Mine is authorised (as per its Water Use Licence dated 11 January 2015) for the Section 21(f) water use activities listed in below.

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Table 11: Section 21(f) licenced water use activities (WUL, 2015)

Facility Location Coordinates Volume / Capacity

Discharging of water dewatered from Portion 34 of the farm 25°42’68.46.6” S underground 960 000m3/a Waterval 306 JQ. workings into the Hex 27°27’37.9” E River through a pipe

Storm water management Existing Glencore Waterval Mine Conceptual storm water management plans for Xstrata (now Glencore) Alloys – Waterval East and West operations were developed in March 2011 by Metago. The resultant reports are attached hereto in Annexure G11. The clean and dirty catchments delineation is indicated on Figure 12

below. Figure 13 and Figure 14 below indicate the storm water management plans for the Waterval East and West sections.

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Figure 12: Clean and dirty water catchments affecting the Waterval Operation (Metago, 2011)

Waterval East: Clean and dirty water catchments: In Figure 12 above, clean and dirty catchments have been delineated. For Waterval East it can be seen that there is no upstream contributing area which will require diversion around the mine site. There is however, two small upstream clean areas within the mine site (Clean Water C and D). These clean water areas require diversion away from the dirty areas on the mine site. The dirty catchment is limited to the remainder of the mine site and will require routing via channels/berms to a containment facility. It is important to note that the Waterval East operation is divided by a road into the eastern and western sections for the purposes of discussion in the Storm Water Management report.

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Majority of the Waterval East mining area is considered to be a dirty water generating area

(Figure 12). The storage/handling of fuel, lubricants and chemicals will require special attention due to their hazardous nature. These areas are therefore managed on impermeable floors, appropriate bunding and sumps. The dirty water catchment area has the following catchment characteristics and associated 1:50 year flood peak, (Table 12) as calculated using the Rational Method.

Table 12: Calculated catchment characteristics and peak flow rates for 1:50 year flood for the dirty catchment

Time of Area Drainage Slope Peak flow rate Catchment Concentration (km2) length (km) (m/m) (m3/s) (minutes) Western Dirty 0.07 0.18 0.02 23 1.1 Area

Eastern Dirty 0.16 0.3 0.02 31 2.6 Area

Storm water management infrastructure: Storm water management infrastructure has been designed as per the requirements of GN 704, dated 1999. The dirty water containment facilities presented in the figure have been indicatively sized and positioned and do not represent final design. Dirty water generated on the western area will be routed to an appropriately sized sand trap. The purpose of this will be to contain the first flush of storm water, assumed to be high in sediment. During flood events, water will flow from the silt trap into an appropriately sized storm water culvert (under the road); into the eastern side of the mining operations and routed to the dirty water containment facility.

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Clean water diversions: The storm water management plan includes two upstream clean water diversions (Clean Water C and D) that consist of both a berm and channel components (compacted earth-fill). Clean water diversion berms are designed to divert upstream clean water around dirty water generating areas (i.e. intercepting clean water runoff and diverting this water around mining activities). These have been sized to cater for the 1:50 year flood event and will serve two main purposes: • The channel section will divert upstream clean water which would otherwise flow into the identified dirty areas. • The berm section will ensure containment of dirty water in dirty areas.

It should be noted that in Figure 13

Figure 13: Waterval East Storm Water Management Plan (Metago, 2011). below, there is an additional clean water diversion which is planned to run along the eastern side of the dividing road. This is merely to ensure that any runoff generated on the road does not enter the dirty water management system of the mine, but is rather diverted around the property. For this diversion, the dimensions as per Table 3-3 in Annexure G11 (Waterval East Storm Water Management Plan Report) can be used.

Dirty water containment (berms and channels): As per the clean water diversions, dirty water containment systems have been designed to ensure dirty water generated on the site is contained. These systems will also consist of a berm and channel component. Unlike the earthen clean water diversions, these channels will be lined with concrete and soil-crete (filled in cells). Appendix A of Annexure G11 (Waterval East Storm Water Management Plan

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Report) presents a typical dirty water containment channel design as recommended by VIP Consulting. The berm component to this design has not been indicated in this design but will be constructed from the earthen material excavated from the channel and located on the clean catchment side of the channel. The berm and channel component have been designed to accommodate the 1:50 year flood and serve two main purposes: • Diverting upstream clean water which would otherwise flow into the identified dirty areas. • Contain dirty water in the identified dirty areas and direct towards the appropriate dirty water containment facility.

Dirty water containment (containment facility): Regulation 6 of GN 704, deals with the capacity requirements of clean and dirty water systems, and states that clean and dirty water systems must be kept separate and must be designed, constructed, maintained and operated such that these clean and dirty water systems do not spill into each other as a result of storm events below and including the 1 in 50 year event. A minimum freeboard of 0.8 m above full supply level must also be maintained as per the requirements of GN 704. Water accumulated in this containment facility during the wet season should be used as a priority in the process water circuit to ensure the capacity requirements are not compromised during periods of heavy/extended rainfall. In this project, the capacity of the dirty water containment facility was calculated based on the summation of the 1:50 year design rainfall (24 hour) event for the catchment area and the highest monthly rainfall (January) falling over the catchment, less the corresponding monthly evaporation (January) taking place over the surface area of the proposed containment facility. Runoff coefficients used were determined according to the return period of interest, such that maximum monthly rainfall event was associated with a smaller runoff coefficient than the 1 in 50 year design rainfall event. All dams were sized based on an average operating depth of 2 m (excluding any freeboard allowance). The addition of any process water from the mine has not been included in the sizing’s of this facility. Table 13 presents the volume requirements for the dirty water containment facility.

Table 13: Dirty water containment facility volumes requirements for 1:50 year flood event

Catchment Volume (m3)

Waterval East Dirty area 25,575

The design of the dirty water containment facility (Appendix B of Annexure G11 (Waterval East Storm Water Management Plan Report)) is such that there will be three interlinked components. These include concrete lined pollution and effluent dams, and a storage dam which is lined with both geo-membrane and clay. The pollution dam serves to contain the first flush of dirty water, assumed to be the dirtiest water. Water will overflow from the pollution dam into the storage and effluent dams during flood events, from where it can be pumped back for use in the process. The volume of the dirty water containment facility according to VIP (2011) is 27,097m3, which corresponds well with Metago’s calculation (25,575m3).

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The dirty water containment facility has also been designed to include a downstream seepage containment channel which will be approximately 3 metres deep and serve to identify and contain lateral seepage losses from the containment facility.

Figure 13: Waterval East Storm Water Management Plan (Metago, 2011).

Waterval West: Clean and dirty water catchments: For Waterval West it can be seen that there is a substantial upstream clean catchment area (Clean Water A and Clean Water B) which will require diversion around the site. The dirty catchment is limited to the mine property and will require routing via channels/berms to a containment facility, all of which should be sized according to the regulations. The entire Waterval West mining area has been considered to be a dirty water generating area. The storage/handling of fuel, lubricants and chemicals will require special attention due to their hazardous nature. These areas are therefore managed on impermeable floors, appropriate bunding and sumps. The dirty water catchment area has the following catchment characteristics and associated 1:50 year flood peak, (Table 14) as calculated using the Rational Method.

Table 14: Calculated catchment characteristic and peak flow rates for 1:50 year flood for the dirty catchment

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Time of Area Drainage Slope Peak flow rate Catchment Concentration (km2) length (km) (m/m) (m3/s) (minutes) Dirty Area 0.29 0.5 0.02 39 3.6

Storm water management infrastructure: Storm water management infrastructure has been designed as per the requirements of GN 704, dated 1999. The dirty water containment facilities presented in the figure have been indicatively sized and positioned and do not represent final design.

Clean water diversions: The storm water management plan includes upstream clean water diversions (clean water A and B) which consist of both a berm and channel component (compacted earth-fill). Clean water diversion berms are designed to divert upstream clean water around dirty water generating areas (i.e. intercepting clean water runoff and diverting this water around mining activities). These have been sized to cater for 1:50 year flood event and will serve two main purposes: • The channel section will divert upstream clean water which would otherwise flow into the identified dirty areas. • The berm section will ensure containment of dirty water in dirty areas.

Dirty water containment (berms and channels): As per the clean water diversions, dirty water containment systems have been designed to ensure dirty water generated on the site is contained. These systems will also consist of a berm and channel component. Unlike the earthen clean water diversions, these channels will be lined with concrete and soil-crete (filled in cells). Appendix A of Annexure G11 (Waterval West Storm Water Management Plan Report) presents a typical dirty water containment channel design as recommended by VIP Consulting. The berm component to this design has not been indicated in this design but will be constructed from the earthen material excavated from the channel and located on the clean catchment side of the channel. The berm and channel component have been designed to accommodate the 1:50 year flood and serve two main purposes: • Diverting upstream clean water which would otherwise flow into the identified dirty areas. • Contain dirty water in the identified dirty areas and direct towards the appropriate dirty water containment facility.

Dirty water containment (containment facility): Regulation 6 of GN 704 deals with the capacity requirements of clean and dirty water systems, and states that clean and dirty water systems must be kept separate and must be designed, constructed, maintained and operated such that these clean and dirty water systems do not spill into each other as a result of storm events below and including the 1 in 50 year event. A minimum freeboard of 0.8 m above full supply level must also be maintained as per the requirements of GN 704. Water accumulated

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in this containment facility during the wet season should be used as a priority in the process water circuit to ensure the capacity requirements are not compromised during periods of heavy/extended rainfall. In this project, the capacity of the dirty water containment facility was calculated based on the summation of the 1:50 year design rainfall (24 hour) event for the catchment area and the highest monthly rainfall January) falling over the catchment, less the corresponding monthly evaporation (January) taking place over the surface area of the proposed containment facility. Runoff coefficients used were determined according to the return period of interest, such that maximum monthly rainfall event was associated with a smaller runoff coefficient than the 1 in 50 year design rainfall event. All dams were sized based on an average operating depth of 2 m (excluding any freeboard allowance). The addition of any process water from the mine has not been included in the sizings. Table 15 presents the volume requirements for the dirty water containment facility.

Table 15: Dirty water containment facility volumes requirements for 1:50 year flood event

Catchment Volume (m3)

Waterval West Dirty area 30,042

The design of the dirty water containment facility (Appendix B of Annexure G11 (Waterval West Storm Water Management Plan Report)) is such that there will be three interlinked components. These include concrete lined pollution and effluent dams, and a storage dam which is lined with both geo-membrane and clay. The pollution dam serves to contain the first flush of dirty water, assumed to be the dirtiest water. Water will overflow from the pollution dam into the storage and effluent dams during flood events, from where it can be pumped back for use in the process. The volume of the dirty water containment facility according to VIP (2011) is 30,125m3 and corresponds well with Metago’s calculation (30,042m3)

The dirty water containment facility has also been designed to include a downstream seepage containment channel which will be approximately 3 metres deep and serve to identify and contain lateral seepage losses from the containment facility.

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Figure 14: Waterval West Storm Water Management Plan (Metago, 2011)

Surface water monitoring Glencore Alloys: Waterval Mine has a surface water monitoring programme in place. Surface water quality monitoring is conducted on a monthly basis by a contractor. Refer to Annexure G3 for the monthly monitoring reports and to Section 7.4.1: Chapter G of this report for more detail.

Surface water monitoring Glencore Alloys: Waterval Mine has a groundwater monitoring programme in place. Refer to Annexure G5 and Section 7.4.1: Chapter I of this report for more detail.

Domestic wastewater management Two conservancy tanks are located at Waterval West. These conservancy tanks are drained on weekly basis by an external contractor, with the sewage taken to the Rustenburg Sewage Treatment Works for disposal and treatment. Further, the Waterval East offices and other facilities dispose sewage into the Rustenburg municipal reticulation, which is then conveyed to Rustenburg sewage plants for treatment. The Rustenburg municipality operates the sewage plants.

4.2.2.7 Non-mineral Waste management

Waste management on-site Glencore’s Chrome Mining Division has a central waste management procedure that is to be adhered to by Waterval Mine. According to the mentioned procedure all possible recycling methods are to be identified in order to reduce the quantities of waste at all sites.

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Chrome Mining Division has appointed a contractor to manage and control all waste and scrap generated within all sites, excluding tyres.

Colour coded bins are placed at strategic points and once full the bins are transported to the Salvage yard by the contractor, where the contractor will sort the waste into the respective storage areas for example, plastic, paper, hazardous and domestic waste, etc. Waste is to be separated into mainly 6 categories:

• Scrap metal, plastic (skips where applicable); • Domestic waste (green colour coded drums); • Hazardous waste (black colour coded drums); • Fluorescent tubes (yellow colour coded drums equipped with capped crusher pipe); • Old PPE (blue and orange drums); and • Old cartridges (kept in office) (Red).

Further to the above, the following management and disposal methods (for other waste types) are followed:

Table 16: Disposal and management methods for additional waste types on site

Waste type Management / disposal method

All used oil is drained from oil sumps and associated facilities and are sold Used oil to an external contractor for recycling purposes.

An appointed service provider is responsible for the handling and removal of medical waste according to protocol and ensuring subsequent Medical waste incineration. Needles, scalpels, blades (sharps) are placed in a puncture- resistant leak-proof container dedicated specifically for that purpose.

Batteries are checked by the Engineering foreman to determine whether Old batteries the battery can be charged or disposed of. All old batteries are taken back by the suppliers.

Explosives packaging Explosives bags collected by external contractor for off-site incineration.

Building rubble Building rubble is to be removed by the building contractor.

All waste tyres are transported to the Salvage yard for temporary storage, Waste tyres where they are sorted by the contractor before taken for recycling or re- use purposes.

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Figure 15: Basic waste process flow

The collection of waste on the mine’s various sites is done as required to ensure that the Salvage yard stays in a neat and tidy condition.

The contractor keeps a detailed register for all the waste by commodity that enters and leaves the Salvage yard. A printout of the register is supplied at the end of each month to the environmental department. Reconciliation is done and a report is compiled indicating waste consumption / usage.

Removal and disposal of general (domestic) waste (not recycled) Non-mineral general waste is removed off-site by a registered waste contractor to a licenced municipal waste landfill site in Rustenburg.

Removal and disposal of hazardous waste Non-mineral hazardous waste is removed off-site by a registered hazardous waste contractor to a licenced hazardous waste landfill site.

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Waste minimisation and recycling Glencore Chrome Mining Division has a documented Waste management procedure. The overall objective of the waste management procedure is to reduce generation and environmental impacts of all forms of waste. The mentioned plan provides guidance on waste management, disposal, re-use, recycling, reporting and auditing and divides waste types into the ‘reduce, re-use and recycle’ streams.

4.2.2.8 Hazardous substance management

According to a Hazardous Chemical substance survey conducted for Glencore (then Xstrata) Alloys: Western Mines, by Enhanced Water Solutions, the following hazardous substances were found at Waterval Mine.

Table 17: List of Hazardous substances (not limited to) found at Waterval Mine (EWS, 2010)

Hazardous substances Acetylene Habitant spray

Ammonia Clean Iodine Solutions

Anti-Freeze Laser jet cartridge

Betadine Long-time PD2

Bio Scrub Methyl Silicate

Bleach Methylated spirits

Brake Fluid Minova

Car batteries Miracle tool

Carbon dioxide Mycota Powder

Cetidine Oxygen gas

Chlorohydrexine 5 L Paint

Engine oil Paste Hand Cleaner

Floxit 9024 Safety Spray

Foam cleaner Toilet cubes

Gear lube EP 80W/90 Green Detergent

Glencore Alloys Western Chrome Mining Division has a documented Waste management procedure, which is to be adhered to by Waterval Mine. The following main requirements (amongst other) are set out in the mentioned procedure:

• A Material Safety Data Sheet (“MSDS”) register of all substances used on-site shall be prepared. The register will also identify the location where the material is used; • A MSDS of each hazardous substance will be readily accessible to all employees who may reasonably use or come into contact with such substance;

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• All persons potentially affected by exposure to workplace hazardous substances and their supervisors will receive training; • Large quantities of dangerous goods can only be transported on designated vehicles driven by appropriately trained people with transportation certificates; • Pump and piping system that handle hazardous substances must be well maintained and constructed using appropriate materials; • Incidents will be reported immediately; • Regular checks must be carried out on the fuel storage equipment; • Storage bays should be bunded to provide for a minimum retention capacity of not less than 150% of the largest tank’s capacity; • Drainage valves should be constructed at the base of the wall and be secured in a closed position; • Tanks for the storage of diesel should comply to the SANS standards and with any relevant hazardous substances regulations. The tanks should be inspected periodically and where a tank is found to be leaking it should not be used for storage of dangerous goods until that leaks has been repaired; • Each hazardous substance storage area should be labelled appropriately; and • The floor of the storage area should be constructed of concrete and slopes that any spillage will flow to a sump contained within the bunded area.

Diesel (fuel) storage areas A surface diesel storage area is managed and operated at Waterval Mine. Refer to Table 7 above which includes a photograph of the mentioned diesel storage area. The site consists of two (2) 23 000 litre tanks. The following main requirements (amongst other) are set out in the above-mentioned manual: • Vehicles should be refuelled underground with their engines stopped, and only while they are within the designated refuelling bay where the ventilation is adequate and spillage can be controlled. The dispending hose length should be restricted accordingly; • The floor of the refuelling bay should be constructed of concrete and slopes that any spillage will flow into a concrete drain then into a sump within the refuelling bay; • Diesel, fuel and oil should be pumped from the storage tanks to the service bay, not gravity fed, and any pump supplying hydrocarbons to a second storage tank or a vehicle shall be provided with a shut off device which is readily accessible, clearly identified and capable of shutting off power to the pump in an emergency; • Where tanks on surface are used to supply diesel to the tanks underground via a pipeline: o The combined capacity of the surface batch tank and pipeline feeding the underground tanks should not exceed 50 % of the largest underground tank capacity; o The surface tanks should be fully bunded and securely fenced; o Filling of the surface batch tanks should not take place while diesel is being transferred to the underground storage tank; and

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o A communication system should be provided between the surface batch tank and the underground storage area, outside the bunded areas.

• Pipes carrying diesel fuel and oil underground should be either screwed or welded steel and restricted to a maximum diameter of 25mm to reduce spillage in the case of failure.

4.2.2.9 Energy Management

The Glencore Chrome Mining Division Resource Reduction Procedure sets out a list of energy saving initiatives for the western mines (including Waterval Mine). These relate to:

• Air compressors; • Buildings and air conditioning; • Fuel efficient diesel engines, • Lighting systems; • Pumps; • Equipment operation and upgrades; • Greenhouse gas emissions; • Diesel energy use; • Baseline energy use; • Walk-around energy surveys; and • Management review.

Programmes are in place across Glencore operations to reduce energy intensity and achieve cost savings. Energy efficiency audits are routinely carried out at the operations and the capital expenditure approval processes requires energy efficiency to be considered for all major new investment and projects.

4.2.2.10 Power supply

The power supply originates at a local substation. The substation covers 0.01ha and is situated on Waterval East. Power is supplied by the local municipality.

4.2.2.11 Housing

Waterval Mine does not operate any hostels or living quarters at present.

Housing Allowance All employees receive a housing allowance which is calculated on their basic salary.

Housing Subsidy: A housing subsidy is paid to employees who can provide proof of a registered housing bond. The value of the subsidy is also based on the basic salary of the individual.

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4.2.2.12 Shafts

Incline- and Shafts There are two incline shafts. One at Waterval West and one at Waterval East. Waterval East Shaft used to be an opencast mine, but has been converted to an underground shaft. All ventilation shafts are located within the mining area except for one that is located in the municipal area.

4.2.3 Estimated reserves

Table 18 below summarises the mineral resources for the area (as at December 2017), as per the MWP, February 2018 (attached in Annexure K).

Table 18: Mineral resources and reserves statement (MWP, 2018)

4.2.4 Production rate and Life of Mine

The Life of Mine (LOM) for Waterval Mine is in excess of 30 years. The production forecast for each year (10-year period) is provided in Table 19 below.

Table 19: Chrome production (MWP, 2018)

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5 Policy and legislative context

The following table is a summary of the policy and legislative context applicable to the proposed project.

Table 20: policy and legislative context applicable to the proposed project

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (A description of the policy and legislative context HOW DOES THIS DEVELOPMENT COMPLY within which the REFERENCE WHERE APPLIED development is proposed WITH AND RESPOND TO (i.e. Where in this document including an identification of THE POLICY AND has it been explained how the all legislation, policies, LEGISLATIVE CONTEXT development complies with plans, guidelines, spatial (E.g. In terms of the National and responds to the legislation tools, municipal Water Act:-Water Use and policy context) development planning Licence has/has not been frameworks and instruments applied for). that are applicable to this activity and are to be considered in the assessment process) Constitution of Republic of South Africa (Act No 108 OF 1996). Glencore Waterval Mine is in possession of a number of The Mineral and Petroleum Mining Rights to mine mineral Resources Development Act, resources (refer to Error! 2002 (Act No. 28 of 2002) Reference source not found.). The purpose of this The Mineral and Petroleum EIAR / EMPr is to consolidate Resources Development all the existing and updated Regulations, 2004, Throughout this EIAR / EMPr EMPrs into one document and Regulations R.562 dated April to ensure that the latest 2004). information is contained in The National Environmental such document. The EMPr Management Act, 1998 (Act amendment is done in No. 107 of 1998). accordance with the NEMA, 1998 and the EIA Regulations The Environmental Impact R.982, dated December 2014. Assessment Regulations, R. 982 dated December 2014.

Bojanala Platinum District Municipality: Air quality Chapter J of Section 7.4.1, management by-law, Section 9 (Part A) and Section published under LAN230 in District and Local Municipality 1.4.9 (Part B) of this EIAR / EMPr. North west Provincial Gazette by-laws have been taken into 7191 of 15 November 2013. consideration during the inclusion of mitigation and Bojanala Platinum District management measures. Refer Municipality: Fire services by- to Section 1.4.9 (Part B) of this law, published under LAN204 Section 9 (Part A) and Section EIAR / EMPr. in North west Provincial 1.4.9 (Part B) of this EIAR / EMPr. Gazette 7053 of 09 November 2012.

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APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (A description of the policy and legislative context HOW DOES THIS DEVELOPMENT COMPLY within which the REFERENCE WHERE APPLIED development is proposed WITH AND RESPOND TO (i.e. Where in this document including an identification of THE POLICY AND has it been explained how the all legislation, policies, LEGISLATIVE CONTEXT development complies with plans, guidelines, spatial (E.g. In terms of the National and responds to the legislation tools, municipal Water Act:-Water Use and policy context) development planning Licence has/has not been frameworks and instruments applied for). that are applicable to this activity and are to be considered in the assessment process) Bojanala Platinum District Municipality: Municipal health services by-law, published Section 9 (Part A) and Section under LAN199 in North west 1.4.9 (Part B) of this EIAR / EMPr. Provincial Gazette 6947 of 22 November 2011.

Bojanala Platinum District Section 9 (Part A) and Section Municipality: Draft Air Quality 1.4.9 (Part B) of this EIAR / EMPr. Management Plan. 2011.

Rustenburg Local Municipality: Air pollution by-law, published Section 9 (Part A) and Section under LAN264 in North west 1.4.9 (Part B) of this EIAR / EMPr. Provincial Gazette 7383 of 12 December 2014.

Rustenburg Local Municipality: By-law relating to the disposal of contaminated and / or Section 9 (Part A) and Section infectious waste, published 1.4.9 (Part B) of this EIAR / EMPr. under LAN234 in North west Provincial Gazette 6205 of 06 September 2005.

Rustenburg Local Municipality: By-law relating to the District and Local Municipality prevention of nuisances, Section 9 (Part A) and Section by-laws have been taken into published under LAN233 in 1.4.9 (Part B) of this EIAR / EMPr. consideration during the North west Provincial Gazette inclusion of mitigation and 6205 of 06 September 2005. management measures. Refer to Section 1.4.9 (Part B) of this Rustenburg Local Municipality: EIAR / EMPr. By-law pertaining to public health hazards and nuisances, Section 9 (Part A) and Section published under LAN238 in 1.4.9 (Part B) of this EIAR / EMPr. North west Provincial Gazette 6205 of 06 September 2005.

Rustenburg Local Municipality: Section 9 (Part A) and Section Waste management by-law, 1.4.9 (Part B) of this EIAR / EMPr. published under LAN79 in

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APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (A description of the policy and legislative context HOW DOES THIS DEVELOPMENT COMPLY within which the REFERENCE WHERE APPLIED development is proposed WITH AND RESPOND TO (i.e. Where in this document including an identification of THE POLICY AND has it been explained how the all legislation, policies, LEGISLATIVE CONTEXT development complies with plans, guidelines, spatial (E.g. In terms of the National and responds to the legislation tools, municipal Water Act:-Water Use and policy context) development planning Licence has/has not been frameworks and instruments applied for). that are applicable to this activity and are to be considered in the assessment process) North west Provincial Gazette 7005 of 12 June 2012.

District and Local Municipality Rustenburg Local Municipality: by-laws have been taken into Water supply and wastewater consideration during the by-laws, published under Section 9 (Part A) and Section inclusion of mitigation and LAN407 in North west 1.4.9 (Part B) of this EIAR / EMPr. management measures. Refer Provincial Gazette 6343 of 24 to Section 1.4.9 (Part B) of this November 2006. EIAR / EMPr.

The Environmental Impact Assessment Regulations, R. 983 dated December 2014. The activities undertaken at the Glencore Waterval Mine The Environmental Impact that have been approved in Refer to Section 4.1 (Part A) of Assessment Regulations, R. terms of the previous this EIAR / EMPr. 984 dated December 2014. legislation are provided in Error! Reference source not The Environmental Impact found.. Assessment Regulations, R. 985 dated December 2014.

The need and desirability of the mine has been discussed in Section 6 below in terms of Guideline on Need and the required format contained Desirability in terms of the in the Guideline on Need and Environmental Impact Section 6 (Part A) of this EIAR / Desirability (GN 891 of 2014). Assessment (“EIA”) EMPr. Regulations, 2010. It should however be noted Government Notice 891 of that Waterval Mine is an 2014. existing mine, and the Need and Desirability section (below) has been described in this context.

In terms of the requirement Mining and Biodiversity regarding the management of Chapters E, F and M of Section Guideline: Mainstreaming biodiversity, the Mining and 7.4.1; and Section 7.4.4 (Part A) biodiversity into the mining Biodiversity Guideline: of this EIAR / EMPr sector. Mainstreaming biodiversity into the mining sector was consulted in terms of the

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APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (A description of the policy and legislative context HOW DOES THIS DEVELOPMENT COMPLY within which the REFERENCE WHERE APPLIED development is proposed WITH AND RESPOND TO (i.e. Where in this document including an identification of THE POLICY AND has it been explained how the all legislation, policies, LEGISLATIVE CONTEXT development complies with plans, guidelines, spatial (E.g. In terms of the National and responds to the legislation tools, municipal Water Act:-Water Use and policy context) development planning Licence has/has not been frameworks and instruments applied for). that are applicable to this activity and are to be considered in the assessment process) following principles and sections, as contained in the Guideline, and have been incorporated throughout this EIAR / EMPr: Biodiversity information used in Section 7.4.1 include the relevant GIS maps and documents to plot the location of the mining site onto maps depicting critical biodiversity areas, flora, sensitive areas etc. Maps were also sourced from SANBI. The use of specialist studies in order to determine the impacts on the ecological sphere of the environment; Biodiversity related impacts as well as impacts with regards to conservation planning and protected areas were assessed and are included in Section 9 (Part A).

Section 4.2.2.5 and Chapters G The National Water Act, 1998 and I of Section 7.4.1 (Part A) of (Act No. 36 of 1998). this EIAR / EMPr and Annexure Glencore Waterval Mine has G4. an Integrated Water Use Section 4.2.2.5; Section 12 and Licence (“IWUL”), dated Government Notice (“GN”) Chapter G of Section 7.4.1 (Part January 2015. 704, dated 1999 under the A) of this EIAR / EMPr and NWA, 1998. Annexure G4.

The National Environmental Chapter E, F and M of Section Impacts and mitigation / Management: Biodiversity Act 7.4.1 (Part A) of this EIAR / EMPr management measures (NEM:BA), 2004 (Act No. 10 of as well as Annexure G2. relevant to biodiversity and 2004). conservation are provided in

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APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (A description of the policy and legislative context HOW DOES THIS DEVELOPMENT COMPLY within which the REFERENCE WHERE APPLIED development is proposed WITH AND RESPOND TO (i.e. Where in this document including an identification of THE POLICY AND has it been explained how the all legislation, policies, LEGISLATIVE CONTEXT development complies with plans, guidelines, spatial (E.g. In terms of the National and responds to the legislation tools, municipal Water Act:-Water Use and policy context) development planning Licence has/has not been frameworks and instruments applied for). that are applicable to this activity and are to be considered in the assessment process) NEM:BA Threatened or Sections 9, 10, 11 and 12 of Protected Species (“ToPS”) Part A and Sections 1.4, 1.5 Regulations, 2013. and 1.6 of Part B of this EIAR / EMPr. Environmental Conservation Act, 1989 (Act No 73 of 1989).

National Forests Act, 1998 (Act No 84 of 1998)

National Veld and Forest Fire Act, 1998 (Act No 101 of 1998)

Alien and Invasive Species Regulations published in the Government Gazette No. 37886, dated 01 August 2014

Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) (“CARA”)

National Environmental Management: Protected Areas Impacts and mitigation / Act (“NEM:PAA”) (Act No 57 of management measures relevant to biodiversity and 2003). Chapter E, F and M of Section conservation are provided in 7.4.1 (Part A) of this EIAR / EMPr NEM:BA National Threatened Sections 9, 10, 11 and 12 of as well as Annexure G2. Terrestrial Ecosystems list, Part A and Sections 1.4, 1.5 December 2011. and 1.6 of Part B of this EIAR / EMPr. National Biodiversity Strategy and Action Plan (“NBSAP”)

North West Parks and Tourism Board Act, 1997 (Act No 3 of 1997).

North West Province Environmental Implementation Plan (NW: EIP 2008)

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APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (A description of the policy and legislative context HOW DOES THIS DEVELOPMENT COMPLY within which the REFERENCE WHERE APPLIED development is proposed WITH AND RESPOND TO (i.e. Where in this document including an identification of THE POLICY AND has it been explained how the all legislation, policies, LEGISLATIVE CONTEXT development complies with plans, guidelines, spatial (E.g. In terms of the National and responds to the legislation tools, municipal Water Act:-Water Use and policy context) development planning Licence has/has not been frameworks and instruments applied for). that are applicable to this activity and are to be considered in the assessment process) Impacts and mitigation / management measures relevant to biodiversity and Chapter E, F and M of Section North West Conservation Plan conservation are provided in 7.4.1 (Part A) of this EIAR / EMPr (NW: C Plan 2012). Sections 9, 10, 11 and 12 of as well as Annexure G2. Part A and Sections 1.4, 1.5 and 1.6 of Part B of this EIAR / EMPr.

The National Environmental Management: Air Quality Act (Act No 39 of 2004).

Government Gazette, 32816, General Notice 1210, National Chapter J of Section 7.4.1 (Part Ambient Air Quality Standards, A), Section 9 (Part A) and Section in terms of the National 1.4.9 (Part B) of this EIAR / EMPr. Environmental Management: Air Quality Act, 2003 (Act No. 39 of 2004), Department of Environmental Affairs, 24 December 2009.

Government Gazette, 35463, Air quality monitoring is General Notice 486, National performed at Waterval Mine on Ambient Air Quality Standard a monthly basis Refer also to for Particulate Matter with Annexure G6. Aerodynamic Diameter less than 2.5 Micron Meters (PM2.5), in terms of the National Environmental Management: Air Quality Act, Chapter J of Section 7.4.1 (Part 2003 (Act No. 39 of 2004), A), Section 9 (Part A) and Section Department of Environmental 1.4.9 (Part B) of this EIAR / EMPr. Affairs, 29 June 20012.

Government Gazette 36974, General Notice 827, National Dust Control Regulations, in terms of the National Environmental Management: Air Quality Act, 2004 (Act No.

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APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (A description of the policy and legislative context HOW DOES THIS DEVELOPMENT COMPLY within which the REFERENCE WHERE APPLIED development is proposed WITH AND RESPOND TO (i.e. Where in this document including an identification of THE POLICY AND has it been explained how the all legislation, policies, LEGISLATIVE CONTEXT development complies with plans, guidelines, spatial (E.g. In terms of the National and responds to the legislation tools, municipal Water Act:-Water Use and policy context) development planning Licence has/has not been frameworks and instruments applied for). that are applicable to this activity and are to be considered in the assessment process) 39 of 2004), Department of Environmental Affairs, 1 November 2013.

Waterberg-Bojanala Priority Area Draft Air Quality Management Plan. 2014.

North West Provincial Air Quality Management Plan. 2009.

SABS Code of Practice 0103 of 2008: The measurement and rating of environmental noise with respect to land use, An environmental noise survey health, annoyance and to Chapter K of Section 7.4.1 (Part was conducted for Waterval speech communication. A) of this EIAR / EMPr and West Mine in 2012. Refer also Annexure G9. to Annexure G7. SABS Code of Practice 0328 of 2008: Environmental Noise Impact Assessments.

Glencore Waterval Mine has a waste management licence in terms of the National Environmental Management: National Environmental Section 4.2.2.6 and Section 12 Waste Act, 2008 (Act 59 of Management: Waste Act (Act (Part A) of this EIAR / EMPr. 2008) (Government Notice No 59 of 2008), as amended. (GN) 718, dated July 2009). Refer to Annexure D for a copy of the waste management licence.

Impacts and mitigation / management measures are National Heritage Resources Chapter N of Section 7.4.1 (Part provided in Sections 9, 10, 11 Act (Act No. 25 of 1999), as A) of this EIAR / EMPr and and 12 of Part A and Sections amended. Annexure G3. 1.4, 1.5 and 1.6 of Part B of this EIAR / EMPr. Refer also to Annexure G8.

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APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT (A description of the policy and legislative context HOW DOES THIS DEVELOPMENT COMPLY within which the REFERENCE WHERE APPLIED development is proposed WITH AND RESPOND TO (i.e. Where in this document including an identification of THE POLICY AND has it been explained how the all legislation, policies, LEGISLATIVE CONTEXT development complies with plans, guidelines, spatial (E.g. In terms of the National and responds to the legislation tools, municipal Water Act:-Water Use and policy context) development planning Licence has/has not been frameworks and instruments applied for). that are applicable to this activity and are to be considered in the assessment process) DMR Guideline for Consultation with communities Public Participation relevant to and Interested and Affected this EIAR / EMPr Amendment Parties. As required in terms of has been undertaken in Sections 16(4)(b) or 27(5)(b) of accordance with the relevant the Mineral and Petroleum Sections 7.3 and 11 of Part A this Guideline(s) and EIA Resources Development Act EIAR / EMPr and Annexure F. Regulations, dated December (Act 28 of 2002), and in 2014. Refer to the Public accordance with the standard Participation Report in directive for the compilation Annexure F. thereof as published on the official website of the DMR.

Alternatives have not been Integrated Environmental assessed as part of this EIAR / Management Information Sections 7.1, 7.4, 7.7 and 7.9 of EMPr since Glencore Waterval Series. Criteria for determining this EIAR / EMPr Mine is an existing operational alternatives in EIA. mine.

The closure cost assessment Government Gazette 39425. (financial provision) report, as Government Notice R.1147 well as the Rehabilitation Plan Section 19 (Part A) and Sections dated 2015, “Regulations and Schedule and Closure- 1.4.1 and 1.7 (Part B) of this EIAR pertaining to the financial and Decommissioning Plan / EMPr, as well as Annexures K, provision for prospecting, have been compiled for L and M. exploration, mining or Waterval Mine in terms of the production operations” mentioned Regulations. Refer to Annexures K, L and M.

6 Need and desirability of the proposed activities

As per the Waterval Mine’s Social and Labour Plan (“SLP”) (2014 – 2018) (Annexure E), Rustenburg Local Municipality (“RLM”) is reputed to be one of South Africa’s fastest growing urban areas with an annual compound economic growth rate of 6% between 1996 and 2002. This significant growth is largely attributed to the impact of the world’s four largest mines in the immediate vicinity of the town, namely, Anglo Platinum, Impala Platinum, Glencore and Lonmin. Approximately 97% of the total

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platinum production occurs in Rustenburg, with the mining sector providing around 50% of all formal employment.

The National Spatial Development Perspective emphasizes the need for infrastructural development in high development corridors and areas of latent potential, and investment in people in these areas has been considered as one of the guiding development perspectives used in the RLM IDP. The RLM IDP indicated that the municipality faces many challenges some of which include a lack of availability to land, insufficient quality and quantity of water and electricity, a declining agricultural sector and the general level of education of most of the locals.

Through the Social and Labour Plan Waterval aim on developing and implementing comprehensive Human Resources Development Programmes, a Mine Community Development Plan, a Housing and Living Conditions Plan, an Employment Equity Plan, and Processes to save jobs and manage downscaling and/or closure. The above programmes are aimed at promoting employment and advancement of the social and economic welfare of all South Africans whilst ensuring economic growth and socio-economic development.

Waterval Mine will strive to fulfil the following objectives in developing and implementing the Social and Labour Plan: a) Promote economic growth and mineral and petroleum resources development in the Republic; b) Promote employment and advance the social and economic welfare of all South Africans; c) Contribute towards the socio¬-economic development of the areas in which Waterval is operating as well as the areas from which the majority of the workforce is sourced; and d) To utilize and expand the existing skills base for the empowerment of HDSA and to serve the community. The mine is aware of the socio - economic pressure on the hosting community and that alternative work in the surrounding area is limited as well as the additional needs for municipal services and infrastructure. To limit the negative impact of the mining operation on the area, the mine has a resilient focus on local recruitment and undertakes to retain this focus.

6.1 Need and desirability in terms of the Guideline on Need and Desirability, dated 20 October 2014

On the 20th of October 2014, the Department of Environmental Affairs published a Guideline on Need and Desirability in terms of the Environmental Impact Assessment (“EIA”) Regulations, 2010, in Government Notice 891 of 2014. The following table indicates on how the guideline requirements were considered in this EIR/EMPr.

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Table 21: Need and Desirability of the Mining Operation

Section where requirement is Requirement addressed/response

1. How will this development (and its separate Glencore: Waterval Mine falls within Mucina elements/aspects) impact on the ecological & Rutherford’s (2006) Moot Plains Bushveld integrity of the area?4 (SVcb8) and Thornveld (SVcb6) vegetation types. The Moot Plains Bushveld 1.1 How were the following ecological integrity is considered Vulnerable with only 13% statutorily conserved mainly in the considerations taken into account? Magaliesberg Nature Area. The Marikana 1.1.1 Threatened Ecosystems.5 Thornveld regional vegetation type is classified as Endangered with less than 1% 1.1.2 Sensitive, vulnerable, highly dynamic or stressed statutorily conserved in reserves (i.e. the ecosystems, such as coastal shores, estuaries, Magaliesberg Nature Area). wetlands, and similar systems require specific This vegetation unit is highly impacted, and as much as 48% of the vegetation type has attention in management and planning procedures, been transformed as a result of agriculture especially where they are subject to significant and urban development (refer to Annexure human resource usage and development pressure.6 G2 and Section 7.4.1 (Part A) Chapter E of this EIAR / EMPr for more detail).

1.1.3 Critical Biodiversity Areas ("CBAs") and Ecological As per Chapter M of Section 7.4.1 (Part A) of Support Areas ("ESAs"). this EIAR / EMPr, the North West Conservation Plan (NW: C Plan) is based on 1.1.4 Conservation targets. a provincial Biodiversity Assessment (Desmet et al. 2009), and provides important 1.1.5 Ecological drivers of the ecosystem. guidance for biodiversity conservation and 1.1.6 Environmental Management Framework. sustainable development in the province. Among other things, the C Plan will be used 1.1.7 Spatial Development Framework. to inform the development of provincial biodiversity Sector Plans, bioregional plans, Spatial Development Frameworks (“SDFs”), Environmental Management Frameworks (“EMFs”), Strategic Environmental Assessments (“SEAs”) and the Environmental Impact Assessment (“EIA”) process in the province. According to the NW: C Plan, Waterval Mine and its associated infrastructure is situated in a Category 2 Critical Biodiversity Area (“CBA 2”). CBAs are areas of the landscape that need to be maintained in a natural or near-natural state to ensure the continued existence and functioning of species and ecosystems, and the delivery of ecosystem services. Furthermore, the National Terrestrial Priority Areas (“NPA”) assessment was based on

4 Section 24 of the Constitution and section 2(4)(a)(vi) of NEMA refer. 5 Must consider the latest information including the notice published on 9 December 2011 (Government Notice No. 1002 in Government Gazette No. 34809 of 9 December 2011 refers) listing threatened ecosystems in terms of Section 52 of National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004). 6 Section 2(4)(r) of NEMA refers.

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Section where requirement is Requirement addressed/response integrating data on species, habitats and ecological processes to identify areas of greatest biodiversity significance. This resulted in the identification of nine spatial priority areas for terrestrial biodiversity (Driver et al. 2004). These priority areas represent areas with high concentrations of biodiversity features and/or areas where there are few options for meeting biodiversity targets (Rouget et al. 2004). According to the Bojanala District Municipality Integrated Development Plan (“IDP”), 2012-17, large parts of the District Municipality are characterised by high levels of biodiversity as determined in the North West Biodiversity database. In response to the importance of the Bojanala Platinum District as far as biodiversity is concerned, the North West Parks and Tourism board is also considering the extension of a number of existing nature reserves and conservation areas.

1.1.8 Global and international responsibilities relating to the A Provincial Air Quality Management Plan environment (e.g. RAMSAR sites, Climate Change, was developed for the North west Province, etc.).7 in March 2009, which Waterval Mine needs to be take cognisance of. Furthermore, as per Government Notice 154, dated 08 March 2013, the Waterberg National Priority area (in terms of air quality) has been changed to now also include the Bojanala District Municipality. The name of the priority area has been changed to the ‘Waterberg-Bojanala National Priority Area’. An Air Quality Management Plan has been drafted for the priority area, setting out the objectives and implementation plan for the area. This has been taken into consideration during the inclusion of the mitigation and management measures into this EIAR / EMPr. Refer to Section 1.4.9 (Part B) of this report.

1.2 How will this development disturb or enhance ecosystems and/or result in the loss or protection of The impacts of this existing mining operation biological diversity? What measures were explored to in terms of biodiversity are discussed in detail in the Risk Assessment. Refer also to firstly avoid these negative impacts, and where these Section 9 of Part A of this EIAR / EMPr. negative impacts could not be avoided altogether,

7 Section 2(4)(n) of NEMA refers.

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Section where requirement is Requirement addressed/response

what measures were explored to minimise and remedy (including offsetting) the impacts? What measures were explored to enhance positive impacts?8

1.3 How will this development pollute and/or degrade the biophysical environment? What measures were explored to firstly avoid these impacts, and where impacts could not be avoided altogether, what measures were explored to minimise and remedy (including offsetting) the impacts? What measures were explored to enhance positive impacts?9

1.4 What waste will be generated by this development? Glencore’s Chrome Mining Division has a What measures were explored to firstly avoid waste, central waste management procedure that is and where waste could not be avoided altogether, to be adhered to by Waterval Mine. According to the mentioned procedure all what measures were explored to minimise, reuse possible recycling methods are to be and/or recycle the waste? What measures have been identified in order to reduce the quantities of explored to safely treat and/or dispose of unavoidable waste at all sites. waste?10 Chrome Mining Division has appointed a contractor to manage and control all waste and scrap generated within all sites, excluding tyres. Colour coded bins are placed at strategic points and once full the bins are transported to the salvage yard by the contractor, where the contractor will sort the waste into the respective storage areas for example, plastic, paper, hazardous and domestic waste, etc. Glencore Chrome Mining Division has a documented Waste management and minimisation plan (“WMMP”). The overall objective of the WMMP is to reduce generation and environmental impacts of all forms of waste. The mentioned plan provides guidance on waste management, disposal, re-use, recycling, reporting and auditing and divides waste types into the ‘reduce, re-use and recycle’ streams. Refer to Section 4.2.2.6 (Part A) of this EIAR / EMPr.

1.5 How will this development disturb or enhance According to the Updated EMP, 2009, “there landscapes and/or sites that constitute the nation's are no known sites of archaeological interest

8 Section 24 of the Constitution and Sections 2(4)(a)(i) and 2(4)(b) of NEMA refer. 9 Section 24 of the Constitution and Sections 2(4)(a)(ii) and 2(4)(b) of NEMA refer. 10 Section 24 of the Constitution and Sections 2(4)(a)(iv) and 2(4)(b) of NEMA refer.

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Section where requirement is Requirement addressed/response cultural heritage? What measures were explored to on the site, as the sites would have already firstly avoid these impacts, and where impacts could been destroyed.” not be avoided altogether, what measures were A Heritage Impact Assessment (“HIA”) was conducted by J van Schalkwyk for the study explored to minimise and remedy (including area associated with Tailings storage facility offsetting) the impacts? What measures were that was planned for Waterval mine, explored to enhance positive impacts?11 however the activity never commenced. The resultant report that formed part of the relevant project Environmental Management Programme (“EMP”) is attached in Annexure G8. No sites, features or objects dating to the Stone Age, Iron Age or Historical Period were identified in the study area.

1.6 How will this development use and/or impact on non- renewable natural resources? What measures were explored to ensure responsible and equitable use of the resources? How have the consequences of the depletion of the non-renewable natural resources been considered? What measures were explored to firstly avoid these impacts, and where impacts could not be avoided altogether, what measures were The mining and removal of minerals (non- renewable resources) at Waterval Mine explored to minimise and remedy (including results in the destruction of the geological offsetting) the impacts? What measures were strata, which is a consequence of mining. explored to enhance positive impacts?12 Note that Waterval Mine is an existing mining operation. 1.7 How will this development use and/or impact on Refer to Section 9 (Part A) of this EIAR / renewable natural resources and the ecosystem of EMPr for more information regarding the which they are part? Will the use of the resources environmental and social impacts identified. and/or impact on the ecosystem jeopardise the Since the existing Waterval Mine’s activities relate to the removal of ore reserves (to integrity of the resource and/or system taking into maintain economic growth) and the use of account carrying capacity restrictions, limits of water in its process, the dependency on acceptable change, and thresholds? What measures resources is ongoing. were explored to firstly avoid the use of resources, or Refer also to Section 4.2.2.5 (Part A) for if avoidance is not possible, to minimise the use of detail regarding water management on-site. resources? What measures were taken to ensure responsible and equitable use of the resources? What measures were explored to enhance positive impacts?13

1.7.1 Does the proposed development exacerbate the increased dependency on increased use of resources

11 Section 24 of the Constitution and Sections 2(4)(a)(iii) and 2(4)(b) of NEMA refer. 12 Section 24 of the Constitution and Sections 2(4)(a)(v) and 2(4)(b) of NEMA refer. 13 Section 24 of the Constitution and Sections 2(4)(a)(vi) and 2(4)(b) of NEMA refer.

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Section where requirement is Requirement addressed/response

to maintain economic growth or does it reduce resource dependency (i.e. de-materialised growth)? (note: sustainability requires that settlements reduce their ecological footprint by using less material and energy demands and reduce the amount of waste they generate, without compromising their quest to improve their quality of life)

1.7.2 Does the proposed use of natural resources constitute the best use thereof? Is the use justifiable when considering intra- and intergenerational equity, and are there more important priorities for which the resources should be used (i.e. what are the opportunity costs of using these resources this the proposed development alternative?)

1.7.3 Do the proposed location, type and scale of development promote a reduced dependency on resources?

1.8 How were a risk-averse and cautious approach A risk-averse and cautious approach was applied in terms of ecological impacts?14 applied by the undertaking of numerous specialist studies and monitoring programmes during recent years. A conservative approach was followed in terms of the identification and assessing of environmental impacts during the EIA / EMPr phase.

1.8.1 What are the limits of current knowledge (note: the gaps, uncertainties and assumptions must be clearly stated)?

1.8.2 What is the level of risk associated with the limits of Refer to Section 15 (Part A) of this EIAR / current knowledge? EMPr.

1.8.3 Based on the limits of knowledge and the level of risk, how and to what extent was a risk-averse and cautious approach applied to the development?

How will the ecological impacts resulting from this development impact on people's environmental right in terms following:15

1.8.4 Negative impacts: e.g. access to resources, The identification and assessment of the opportunity costs, loss of amenity (e.g. open space), environmental and socio-economic impacts

14 Section 24 of the Constitution and Section 2(4)(a)(vii) of NEMA refer. 15 Section 24 of the Constitution and Sections 2(4)(a)(viii) and 2(4)(b) of NEMA refer.

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Section where requirement is Requirement addressed/response air and water quality impacts, nuisance (noise, odour, has been presented in Section 9 (Part A) etc.), health impacts, visual impacts, etc. What below. measures were taken to firstly avoid negative impacts, but if avoidance is not possible, to minimise, manage and remedy negative impacts?

1.8.5 Positive impacts: e.g. improved access to resources, improved amenity, improved air or water quality, etc. What measures were taken to enhance positive impacts?

1.9 Describe the linkages and dependencies between human wellbeing, livelihoods and ecosystem services applicable to the area in question and how the development's ecological impacts will result in socio- economic impacts (e.g. on livelihoods, loss of heritage site, opportunity costs, etc.)?

1.10 Based on all of the above, how will this development positively or negatively impact on ecological integrity objectives/targets/considerations of the area?

1.11 Considering the need to secure ecological integrity Glencore Waterval Mine is an existing and a healthy biophysical environment, describe how operational mine. No alternatives are the alternatives identified (in terms of all the different therefore applicable to the mine. This EIAR / EMPr serves the purpose of containing elements of the development and all the different consolidated information as per Waterval impacts being proposed), resulted in the selection of Mine’s various mining rights granted and the "best practicable environmental option" in terms previous EMPr’s compiled, and thus forms part of an amendment application. of ecological considerations?16 Since the existing mining and related activities, as well as the proposed tailings dam project related infrastructure and activities formed part of previous approved EMPr’s, and such EMPr’s are considered to be existing ‘environmental authorisations’, the mentioned activities can be considered as being authorised. The identification and assessment of alternatives for the above- mentioned proposed activities have not been included in this EMPr, as the existing and mentioned proposed activities were authorised as part of previous EMPr’s.

1.12 Describe the positive and negative cumulative The identification and assessment of the ecological/biophysical impacts bearing in mind the environmental and socio-economic impacts size, scale, scope and nature of the project in relation has been presented in Section 9 (Part A) below.

16 Section 2(4)(b) of NEMA refer.

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Section where requirement is Requirement addressed/response

to its location and existing and other planned developments in the area?17

What is the socio-economic context of the area, based on, amongst other considerations, the following considerations?

2.1.1 The IDP (and its sector plans' vision, objectives, strategies, indicators and targets) and any other strategic plans, frameworks of policies applicable to the area,

2.1.2 Spatial priorities and desired spatial patterns (e.g. need for integrated of segregated communities, need to upgrade informal settlements, need for densification, etc.),

2.1.3 Spatial characteristics (e.g. existing land uses, Refer to Chapter O of Section 7.4.1 (Part A) of this EIAR / EMPr. planned land uses, cultural landscapes, etc.), and The identification and assessment of the 2.1.4 Municipal Economic Development Strategy ("LED environmental and socio-economic impacts Strategy"). has been presented in Section 9 (Part A) below. 2.2 Considering the socio-economic context, what will the socio-economic impacts be of the development (and its separate elements/aspects), and specifically also on the socio-economic objectives of the area?

2.2.1 Will the development complement the local socio- economic initiatives (such as local economic development (LED) initiatives), or skills development programs?

2.3 How will this development address the specific Refer to Chapter O of Part 7.4.1 (Part A) of physical, psychological, developmental, cultural and this EIAR / EMPr and the Social and Labour social needs and interests of the relevant Plan attached hereto as Annexure E. Note that Waterval Mine is an already existing 18 communities? mining operation in the area.

2.4 Will the development result in equitable (intra- and The identification and assessment of the inter-generational) impact distribution, in the short- positive and negative environmental and and long-term?19 Will the impact be socially and socio-economic impacts has been presented in Section 9 (Part A) below. economically sustainable in the short- and long-term? The mine will be economically sustainable over the short and long-term as the mining

17 Regulations 22(2)(i)(i), 28(1)(g) and 31(2)(1) in Government Notice No. R. 543 refer. 18 Section 2(2) of NEMA refers. 19 Sections 2(2) and 2(4)(c) of NEMA refers.

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Section where requirement is Requirement addressed/response operation is expected to continue for at least the next 30 years.

In terms of location, describe how the placement of the proposed development will:20

2.4.1 result in the creation of residential and employment opportunities in close proximity to or integrated with each other, As the mine is an existing mining operation, 2.4.2 reduce the need for transport of people and goods, no residential opportunities will be created. The mine will continue to provide work for 2.4.3 result in access to public transport or enable non- employees during the operational phase. motorised and pedestrian transport (e.g. will the development result in densification and the achievement of thresholds in terms public transport),

2.4.4 compliment other uses in the area, Refer to Section 7.4.2 (Part A) of this EIAR / EMPr.

2.4.5 be in line with the planning for the area, Refer to Chapters M and O of Section 7.4.1 (Part A) of this EIAR / EMPr.

2.4.6 for urban related development, make use of Not applicable. underutilised land available with the urban edge,

2.4.7 optimise the use of existing resources and infrastructure,

2.4.8 opportunity costs in terms of bulk infrastructure expansions in non-priority areas (e.g. not aligned with the bulk infrastructure planning for the settlement that reflects the spatial reconstruction priorities of the settlement), As previously mentioned, the Waterval Mine is an existing mine. 2.4.9 discourage "urban sprawl" and contribute to compaction/densification,

2.4.10 contribute to the correction of the historically distorted spatial patterns of settlements and to the optimum use of existing infrastructure in excess of current needs,

2.4.11 encourage environmentally sustainable land Trough effective environmental development practices and processes, management and mitigation of environmental impacts. Refer to Section 1.4.9 (Part B) of this EIAR / EMPr.

2.4.12 take into account special locational factors that might As previously mentioned, the Waterval Mine favour the specific location (e.g. the location of a is an existing mine.

20 Section 3 of the Development Facilitation Act, 1995 (Act No. 67 of 1995) ("DFA") and the National Development Plan refer.

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Section where requirement is Requirement addressed/response

strategic mineral resource, access to the port, access to rail, etc.),

2.4.13 the investment in the settlement or area in question will generate the highest socio-economic returns (i.e. Refer to the SLP attached hereto as Annexure E. an area with high economic potential),

2.4.14 impact on the sense of history, sense of place and The identification and assessment of the heritage of the area and the socio-cultural and environmental and socio-economic impacts cultural-historic characteristics and sensitivities of the has been presented in Section 9 (Part A) area, and below.

2.4.15 in terms of the nature, scale and location of the It is not anticipated that the continued development promote or act as a catalyst to create a operation of the mine will result in a more more integrated settlement? integrated settlement or in additional negative socio-economic impacts. 2.5 How were a risk-averse and cautious approach Settlement patterns will remain relatively unchanged. applied in terms of socio-economic impacts?21 A conservative approach has been followed in terms of the identification and assessing of environmental impacts during the EIA / EMPr phase.

2.5.1 What are the limits of current knowledge (note: the It is believed that no socio-economic related gaps, uncertainties and assumptions must be clearly knowledge gaps exist in terms of the stated)?22 proposed project. Also, no uncertainties have been identified. 2.5.2 What is the level of risk (note: related to inequality, The following assumptions are made: social fabric, livelihoods, vulnerable communities, • That all socio-economic information critical resources, economic vulnerability and provided by the applicant is correct. sustainability) associated with the limits of current • knowledge? That the mitigation measures proposed in this report are implemented correctly and 2.5.3 Based on the limits of knowledge and the level of risk, are effective. how and to what extent was a risk-averse and • cautious approach applied to the development? All research/reference sources are accurate.

That there will be no significant changes to the mining operation that could affect the findings and recommendations of this report. Based on the above descriptions, it is our opinion that the level of risk associated with the limits of current knowledge (in terms of socio-economic aspects) is low.

21 Section 2(4)(a)(vii) of NEMA refers. 22 Section 24(4) of NEMA refers.

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Section where requirement is Requirement addressed/response

How will the socio-economic impacts resulting from this development impact on people's environmental right in terms following:

2.5.4 Negative impacts: e.g. health (e.g. HIV-Aids), safety, social ills, etc. What measures were taken to firstly avoid negative impacts, but if avoidance is not possible, to minimise, manage and remedy negative impacts? The identification and assessment of the 2.5.5 Positive impacts. What measures were taken to environmental and socio-economic impacts enhance positive impacts? has been presented in Section 9 (Part A) below. 2.6 Considering the linkages and dependencies between Refer also to Annexure E for a copy of the human wellbeing, livelihoods and ecosystem Social and Labour Plan. services, describe the linkages and dependencies applicable to the area in question and how the development's socioeconomic impacts will result in ecological impacts (e.g. over utilisation of natural resources, etc.)?

2.7 What measures were taken to pursue the selection of the "best practicable environmental option" in terms of socio-economic considerations?23

2.8 What measures were taken to pursue environmental justice so that adverse environmental impacts shall

not be distributed in such a manner as to unfairly As mentioned previously, Glencore Waterval discriminate against any person, particularly Mine is an existing operational mine. No vulnerable and disadvantaged persons (who are the alternatives are therefore applicable to the mine. beneficiaries and is the development located appropriately)?24 Considering the need for social equity and justice, do the alternatives identified, allow the "best practicable environmental option" to be selected, or is there a need for other alternatives to be considered?

2.9 What measures were taken to pursue equitable access to environmental resources, benefits and services to meet basic human needs and ensure Refer to point 2.6 (of this table) above. human wellbeing, and what special measures were taken to ensure access thereto by categories of persons disadvantaged by unfair discrimination?25

23 Section 2(4)(b) of NEMA refers. 24 Section 2(4)(c) of NEMA refers. 25 Section 2(4)(d) of NEMA refers.

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Section where requirement is Requirement addressed/response

2.10 What measures were taken to ensure that the The identification and assessment of the responsibility for the environmental health and safety environmental and socio-economic impacts consequences of the development has been has been presented in Section 9 (Part A) addressed throughout the development's life cycle?26 below.

What measures were taken to:

2.10.1 ensure the participation of all interested and affected parties,

2.10.2 provide all people with an opportunity to develop the understanding, skills and capacity necessary for achieving equitable and effective participation,27

2.10.3 ensure participation by vulnerable and disadvantaged persons,28

2.10.4 promote community wellbeing and empowerment through environmental education, the raising of

environmental awareness, the sharing of knowledge Refer to the Public Participation report and experience and other appropriate means,29 attached hereto as Annexure F.

2.10.5 ensure openness and transparency, and access to Refer also to Annexure E for a copy of the Social and Labour Plan. information in terms of the process,30

2.10.6 ensure that the interests, needs and values of all interested and affected parties were taken into account, and that adequate recognition were given to all forms of knowledge, including traditional and ordinary knowledge31, and

2.10.7 ensure that the vital role of women and youth in environmental management and development were recognised and their full participation therein were be promoted?32

2.11 Considering the interests, needs and values of all the interested and affected parties, describe how the As mentioned previously, Waterval Mine is development will allow for opportunities for all the an existing mining operation. It is not anticipated that additional opportunities will segments of the community (e.g. a mixture of low-,

26 Section 2(4)(e) of NEMA refers. 27 Section 2(4)(f) of NEMA refers. 28 Section 2(4)(f) of NEMA refers. 29 Section 2(4)(h) of NEMA refers. 30 Section 2(4)(k) of NEMA refers. 31 Section 2(4)(g) of NEMA refers. 32 Section 2(4)(q) of NEMA refers.

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Section where requirement is Requirement addressed/response middle-, and high-income housing opportunities) that occur as a result of the continuation of is consistent with the priority needs of the local area mining. (or that is proportional to the needs of an area)?33 However, the activity will continue to provide job security for employees and contractors working for and on behalf of the mine and socio-economic well-being of the area.

2.12 What measures have been taken to ensure that current and/or future workers will be informed of work All contractors, sub-contractors and workers that potentially might be harmful to human health or attend training and inductions. This training the environment or of dangers associated with the highlights, the dangers associated with the workplace. Procedures relating to work, and what measures have been taken to ensure environmental risks are also in place and will that the right of workers to refuse such work will be be regularly updated. respected and protected?34

Describe how the development will impact on job creation in terms of, amongst other aspects:

2.12.1 the number of temporary versus permanent jobs that will be created,

2.12.2 whether the labour available in the area will be able to take up the job opportunities (i.e. do the required skills match the skills available in the area), According to the mine’s SLP (2014 – 2018) (Annexure E), Waterval Mine has a 2.12.3 the distance from where labourers will have to travel, workforce of 372 employees. Therefore, should mining continue, it would result in the 2.12.4 the location of jobs opportunities versus the location increased job security of the current of impacts (i.e. equitable distribution of costs and employees. benefits), and

2.12.5 the opportunity costs in terms of job creation (e.g. a mine might create 100 jobs, but impact on 1000 agricultural jobs, etc.).

What measures were taken to ensure:

2.12.6 that there were intergovernmental coordination and harmonisation of policies, legislation and actions Refer to the Public Participation report attached hereto as Annexure F. All issues relating to the environment, and and concerns raised by all I&APs, 2.12.7 that actual or potential conflicts of interest between stakeholders and organs of state were addressed in the manner as described in the organs of state were resolved through conflict Public Participation report. resolution procedures?

2.13 What measures were taken to ensure that the environment will be held in public trust for the people, During the Public Participation Process, all issue and concerns raised by the I&APs, that the beneficial use of environmental resources will

33 Section 2(4)(g) of NEMA refers. 34 Section 2(4)(j) of NEMA refers.

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Section where requirement is Requirement addressed/response serve the public interest, and that the environment will stakeholders and the Organs of State are be protected as the people's common heritage?35 taken into account and responses provided.

2.14 Are the mitigation measures proposed realistic and Mitigation measures are realistic. However, what long-term environmental legacy and managed not all will necessarily result in reversible burden will be left?36 impacts or in low significance. Rehabilitation strategies aimed at mine closure have been proposed but the effectiveness of implementation will determine long term environmental legacy. Refer to Part B.

2.15 What measures were taken to ensure that the costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, Refer to the closure cost assessment and financial provision information in Part B. environmental damage or adverse health effects will be paid for by those responsible for harming the environment?37

2.16 Considering the need to secure ecological integrity and a healthy bio-physical environment, describe how the alternatives identified (in terms of all the As mentioned previously, Glencore Waterval different elements of the development and all the Mine is an existing operational mine. No alternatives are therefore applicable to the different impacts being proposed), resulted in the mine. selection of the best practicable environmental option in terms of socio-economic considerations?38

2.17 Describe the positive and negative cumulative socio- economic impacts bearing in mind the size, scale, The identification and assessment of the scope and nature of the project in relation to its environmental and socio-economic impacts has been presented in Section 9 (Part A) location and other planned developments in the below. area?39

35 Section 2(4)(o) of NEMA refers. 36 Section 240(1)(b)(iii) of NEMA and the National Development Plan refer. 37 Section 2(4)(p) of NEMA refers. 38 Section 2(4)(b) of NEMA refers. 39 Regulations 22(2)(i)(i), 28(1)(g) and 31(2)(1) in Government Notice No. R. 543 refer.

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7 Motivation for the preferred development footprint within the approved site including a full description of the process followed to reach the proposed development footprint within the approved site 7.1 Details of the development footprint alternatives considered

Glencore Waterval Mine is an existing operational mine. No alternatives are therefore applicable to the mine. This EIAR / EMPr serves the purpose of containing consolidated information as per Waterval Mine’s various mining rights granted and previous EMPrs compiled, and thus forms part of an amendment application.

Since the existing mining and related activities, related infrastructure and activities formed part of previous approved EMPrs, and such EMPrs are considered to be existing environmental authorisations, the mentioned activities can be considered as being authorised. The identification and assessment of alternatives for the above-mentioned proposed activities have not been included in this EMPr, as the existing and mentioned proposed activities were authorised as part of previous EMPrs (refer to Annexure D).

7.2 Details of the Public Participation Process Followed

A public participation process was undertaken, as contained in Annexure F. The Public Participation Process includes: • Stakeholder identification; • Registration of Interested and Affected Parties (I&AP’s) and key stakeholders; • Methods of notification:

o Newspaper advertisement. o Site notices. o Notification letter including BID. o Electronic (E-Mail) notifications including BID.

• Access and opportunity to comment by I&APs; and • Consultation with the relevant authorities.

Refer also to Annexure F for a full description of the public participation process conducted. 7.3 Summary of issues raised by I&Aps

Table 22 below provides a summary of the comments and issues raised and reaction to those responses. After this EIAR / EMPr has been made available for public review for a period of thirty (30)

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days, any additional comments received will be included into the table below, where after the report will be finalised and submitted to the DMR.

Table 22: Summary of issues raised by I&APs

Section and paragraph reference in Interested Date EAPs Response to this report and comments Issues Raised Issues as mandated where the Affected received by the applicant issues and or Parties responses were incorporated. The table above will be completed once public participation (i.e. the EIAR / EMPr public review period) has been completed and comments have been received from I&APs

7.4 The Environmental attributes associated with the development footprint alternatives. A baseline environment.

7.4.1 The type of environment affected by the proposed activity

A baseline description or “status quo” of the of the environmental situation is provided in this part of the document. The following attributes / aspects have been described in detail, in the following respective chapters:

• Chapter A: Geology; • Chapter B: Climate; • Chapter C: Topography; • Chapter D: Soils; • Chapter E: Vegetation; • Chapter F: Fauna; • Chapter G: Surface water; • Chapter H: Sensitive landscapes (including wetlands); • Chapter I: Groundwater; • Chapter J: Air Quality; • Chapter K: Noise; • Chapter L: Visual; • Chapter M: Protected areas and conservation planning; • Chapter N: Sites of Heritage importance; • Chapter O: Regional socio-economic structures.

Note: Documents as included in this section (and attached in Annexure G) contain existing information (in some cases specialist studies) generated for the Waterval Mine’s previous EMP purposes as well as for environmental management implementation purposes on the mine. It should be noted that the specialist studies specifically were conducted prior to the promulgation

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of the 2014 EIA Regulations, but the content of such studies remain applicable for inclusion into this EIAR/EMPr document.

Chapter A: Geology

Information as contained in this chapter was sourced from the following: • CHEMC Environmental. July 2009. Xstrata Alloys Environmental Management Programme Reports Update (hereafter referred to as the ‘updated EMPR, 2009’); and • MSA Group Services. August 2011. Xstrata Alloys Environment Management Programme for the proposed new tailings dam for Waterval Chrome Mine (hereafter referred to as the ‘Tailings Dam EMP, 2011’).

1. Regional geology The Glencore Alloys Waterval Mine and environs are underlain by layered sequence of mafic rocks, referred to as the Rustenburg Layered Suite of the Bushveld Igneous Complex. The suite was emplaced near the top of the older, predominantly sedimentary Transvaal Supergroup. Quartzite and shales (Magaliesberg Formation) of the Transvaal Supergroup form the floor rocks of the Bushveld Complex and build the prominent range of hills immediately west and to the south of Rustenburg. Norites, which form the Chill Zone of the Complex lie in contact with metamorphosed quartzite and shales and are overlain in the vicinity of Rustenburg and to the south and south east of Rustenburg by a sequence of bronzities and minor hartzburgites. These form the Basal Zone of the Complex.

The succeeding Critical Zone rocks are of more varied composition and contain economically important layers which are mined for their chrome and platinum group metals (“PGM”). A prominent pyroxinite layer which contains the economically important Merensky Reef mined for its PGM to the north of the former Rustenburg Chrome mine, marks the top of the Critical Zone. A thick sequence of gabbro-norite assigned to the Main Zone of the Bushveld Complex overlies the Merensky Reef to the north and north east of Rustenburg.

Chrome ore is mined and occurs as layers in the host rock pyroxenite, in the lower critical zone of the Bushveld Igneous Complex. The Bushveld Complex occurs as younger intruded series into the older Transvaal Sequence sediments as an elliptical basin shaped layered mass, outcropping 61 000 km². The Bushveld Complex is a layered mafic to ultramafic sequence and granitic units. The mafic to ultra- mafic layered sequence, the Rustenburg Layered Suite, is a younger intruded series and is part of the Bushveld Complex.

The Suite is subdivided into 5 zones:

• Upper zone; • Main zone; • Critical zone; • Lower zone; and • Marginal zone.

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Chromitite is present in chromitite seams in the lower part of the Rustenburg Layered suite in the northern and south eastern belts as well as in the western lobe. The chromitite layers are confined to the critical zone and were grouped from the bottom upwards, into lower, middle and upper groups.

2. Site specific stratigraphy Pyroxenites with minor anorthosite layers overlie the bronzitite / hartzburgite sequence and are succeeded by a thick sequence of interlayered norites and anorthosites. It is within this zone that the LG6 chrome seam occurs, which is mined underground at the Xstrata Waterval Mine. The UG1 Chromitite Layer is developed stratigraphically above the LG6 Chromitite Layer and approximately 35m below the UG2 Chromitite Layer. The UG1 vary from a composite layer to a bifurcating layer comprising of several 'split' layers. The UG1 strike northwest to south east across the Xstrata property of Waterval West Mine and dips 10° – 14° to the north east. The sub-outcrop of the UG1 is covered by a sandy soil layer of at least 5m thick, which probably increases in thickness towards the Hex River. At an average dip of 120 and a highwall of 30 m at 700 the strike distance (width) of the open pit on the UG1 layer will be 147m.

3. Site Specific Structural Geology

The Bushveld Complex layers strike south-east to north-west across the whole of the mining area. The layers dip towards the northeast at an estimated average dip of 10° – 14°. The tabular Chromitite layers are interlayered by mainly pyroxenites, norites and anorthosites. This layering is occasionally interrupted by transgressive dykes and IRUPS (Iron Rich Ultramafic Replacement Pegmatoids). The layering is further interrupted by faults and potholing of the layers, causing discontinuities and mining losses within the ore body.

The silicate packages between the Chromitite layers increase in thickness with depth forcing the Chromitite layers further apart with depth. The Chromitite layers vary in thickness from 0.30m - 1.2m and are usually developed as composite Chromitite layers. The LG6, MG2 and MG4 are made up of packages containing up to three or more sub-layers.

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Figure 16: Map depicting the geology of the area associated with the Waterval Mine

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Chapter B: Climate

Climate-related information was obtained from the following sources: • Climate-Data.Org (http://en.climate-data.org), • http://www.windfinder.com/windstatistics/rustenburg, • http://www.saexplorer.co.za/south-africa/climate/rustenburg_climate.asp), • Updated EMPR, 2009, and • Tailings Dam EMP, 2011.

1. Temperature The monthly distribution of average daily maximum temperatures (refer to Figure 17 and Figure 18 below) shows that the average midday temperatures for Rustenburg range from 19.3°C in June to 29.4°C in January. The region is the coldest during July when the mercury drops to 1.7°C on average during the night.

Table 23: Average midday and nigh time temperatures in °C

Jan Feb Mar Apr May June Jul Aug Sep Oct Nov Dec Midday 29 29 27 25 22 18 19 22 26 28 28 29

Night 16 16 14 10 5 2 1 4 9 13 14 15 time

Figure 17: Average midday temperature per Figure 18: Average night-time temperature per month for Rustenburg (source: month for Rustenburg (source: http://www.saexplorer.co.za/ south- http://www.saexplorer.co.za/ south- africa/climate/rustenburg_climate.asp) africa/climate/rustenburg_climate.asp)

2. Rainfall The Mean Annual Precipitation for Rustenburg ranges between 500-600 mm per year, with most rainfall occurring during mid-summer. The table and graph below show the average rainfall values for Rustenburg per month with the lowest rainfall in June, July and August (during the winter months) and the highest in January.

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Table 24: Average rainfall per month (mm)

Jan Feb Mar Apr May June Jul Aug Sep Oct Nov Dec

101 80 75 29 6 0 0 0 7 40 80 95

Figure 19: Average rainfall per Month in Rustenburg (source: http://www.saexplorer.co.za/south- africa/climate/rustenburg_climate.asp)

3. Extreme weather conditions Incidence of extreme weather conditions recorded at Rustenburg weather station (number 05115234) are frost, hail, drought, and high winds. Hail can be expected on an average 4 times a year. The rainfall is somewhat unreliable and in about 12% of all years rather severe drought conditions occur. The incidence of high winds is low. Frost can occur during cold winters when temperatures drop below 0°C.

4. Evaporation The closest, reliable evaporation station is situated at Kroondal (WB station A2E08). The average monthly values for evaporation are presented in Table 25 below. The values show that a net water loss prevails in the region.

Table 25: Evaporation data for Rustenburg region

Evaporation (mm) Month A-pan S-pan

January 225 184

February 189 151

March 187 149

April 148 112

May 129 95

June 113 80

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Evaporation (mm) Month A-pan S-pan

July 123 90

August 154 119

September 192 154

October 215 175

November 213 173

December 223 182

Total 2 110 1 663

A correlation exists between the temperatures and the evaporation rate, therefore the highest temperatures and evaporation occurs during the summer.

5. Wind direction and speed The wind data for Rustenburg shows that the prevailing wind directions are north-east (2.5 m.s-1) for the months January to April, south-west (2.5 m.s-1) for May to September and north-west (2.3 m.s-1) for October to December.

Table 26: Average wind data for Rustenburg

N NE E SE S SW W NW

% 0.0 23.0 16.0 4.0 9.0 6.0 10.0 32.0

Speed 0.0 2.5 2.2 2.2 2.4 2.5 2.5 2.3

Chapter C: Topography

Information as contained in this section was obtained from the following documents:

• Updated EMPR, 2009; and • PGM EMP, 2011.

1. Regional The hydrographic basin of the area is almost entirely formed by the northern slopes of the Magaliesberg mountain range. Four main streams and their tributaries drain the area northwards to the low-lying areas where the whole drainage system enters the Crocodile River. These four streams are the Crocodile River itself (across the area of Brits), the Elandspruit, and the Sterkstroom (across the area of /Marikana) and the Hex River (across the area of Kroondal/Rustenburg). This whole drainage

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system cuts across, perpendicularly, the narrow and elongated strips of the geological, edaphic and vegetation formations of the area. 2. Site-specific The altitude of the area varies from ± 1160 m at the south western corner of the property and slopes downward towards the north west and east reaching altitudes of 1140 m in the vicinity of the Hex River

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(refer to Figure 20

Figure 20below). The natural topography of the Waterval mining area is relatively flat with a gentle, even slope from south to north, with the natural vegetation existing being savannah grasslands.

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Agricultural farming is temporarily sterilised due to mining activities although agricultural farming is minimised in this area due to a lack of groundwater.

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Figure 20: Map depicting the topography of the area associated with the Waterval Mine

Chapter D: Soil

1. General As per Natural Scientific Services (NSS)’s Biodiversity Assessment Report, dated June 2015 (refer to Annexure G2) and the report titled Soil Investigation in Waterval Area, dated November 2007, compiled by the Agricultural Research Council (“ARC”) (Annexure G1), the majority of the Glencore: Waterval Mine to the south is situated within landtype BA8 comprised of mainly loamy soils of the Hutton (34%) and Mispah (20%) series with a low clay content (6-34 %) while the northern parts of Waterval closer to the Hex are zoned under the EA3 landtype which is comprised mainly of black turf soils of the Arcadia (70%) soil series. These are black to dark brown, swelling soils with high clay content (43-68 %) and are classified as vertisols due to their tendency to continuously invert themselves as a result of shrinking, cracking and swelling as moisture content changes. These turf soils also known as cracking clays are commonly associated with the ultramafic rocks of the platinum-bearing geology in this case norite and gabbro (Johnson et al. 2006; AGIS, 2015).

2. Site specific Information as contained in this section was obtained from the following specialist study report:

• B.B. Mabuza and D.G. Paterson. November 2007. Report for Xstrata Mining Division (Pty) Ltd by the Institute for Soil, Climate and Water. Agricultural Research Council. Soil Investigation in the Kroondal area (attached in Annexure G1) (hereafter referred to as Institute for Soil, Climate and Water, 2007); as also contained in the following documents:

o Updated EMPR, 2009; and o Tailings Dam EMP, 2011.

2.1 Soil Analysis The south-eastern portion of Waterval Mine comprises deep soils that are predominantly reddish with light textured (15-20% clay) A horizons and medium textured (20-25% clay) B horizons (Institute of Soil, Climate and Water, 2007) (refer also to Table 27 and Figure 22 below). The central zone predominantly consists of shallow duplex soils, having light textured A horizons on strong textured (30% or more clay) B horizons with varying degrees of wetness in the underlying horizons. The rest of the area has moderately deep, light textured soils with a zone on the northern boundary comprising a shallow, heavy textured B horizon that is wet for the better part of the year. The analysis results show the medium texture of the soils, as well as the neutral pH and low degree of leaching. The evidence of previous fertilization is the higher level of P in the topsoil horizons.

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Figure 21: Map depicting the soils of the area associated with the Waterval Mine

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Table 27: Soil Legend

Map Depth Area Soil characteristics Unit (mm) (ha) Brownish-yellow, moderately structured, sandy clay loam topsoils sKa (l) 300-400 on brownish, mottled clayey subsoil, usually wet. Mainly soils of 2 the Katspruit form.

Yellowish-brown, weakly structured, sandy clay loam topsoils on moderately structured, yellowish sandy clay loam subsoils on mAv (m) 600-900 10 mottled soft plinthite. Mainly soils of the Avalon and (occasionally) Hutton form.

Yellowish-brown, weakly structured, sandy clay loam topsoils on sSe (l) 200-400 moderately structured, yellowishbrown, clay subsoils with signs of 8 wetness. Mainly soils of the Sepane form.

Yellowish-brown, weakly structured, sandy clay loam topsoils on sVa (l) 200-400 moderately structured, brown subsoils without signs of wetness. 5 Mainly soils of the Valsrivier form.

Reddish-brown, weakly structured, sandy clay loam topsoils on dHu (h) 700-1200 reddish, weakly structured, sandy clay loam topsoils on rock. 12 Mainly soils of the Hutton and (occasionally) Avalon form.

Total: 37 Source: Institute of Soil, Climate and Water, 2007

Figure 22: Soil Map (source: Institute of Soil, Climate and Water, 2007)

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2.2 Agricultural potential The soil units as listed above were allocated to a relevant class of agricultural potential. The second part of the symbol (in brackets) refers to the potential class. The limitations are given in Table 28 below.

Table 28: Soil limitations

Potential Map Soil limitations Area Class Unit(s) sKa Occurs in low lying area and is prone to flooding. Low (l) sSe Shallow soil with structured layer restricting water infiltration. 15ha sVa Shallow soil with structured layer restricting water infiltration.

Medium mAv Moderately deep with water restricting layer further down. 10ha (m)

High (h) dHu Deep soil with good permeability 12ha

Total: 37ha Source: Institute of Soil, Climate and Water, 2007

In summary, the area mostly has soils of high and moderate agricultural potential due to sufficient depth with good to moderate permeability.

Chapter E: Vegetation

The information contained in this section has been sourced from the following documents: • Natural Scientific Services cc. July 2015. Terrestrial Biodiversity Assessment. Glencore Alloys Waterval, Rustenburg (attached in Annexure G2) (hereafter referred to as NSS, July 2015); and • Natural Scientific Services cc. April 2015. Glencore Alloys. Land Function Analysis – Waterval (attached in Annexure G2) (hereafter referred to as NSS, April 2015) (attached in Annexure G2).

1. Regional vegetation Glencore: Waterval Mine falls within Mucina & Rutherford’s (2006) Moot Plains Bushveld (SVcb8) and Marikana Thornveld (SVcb6) vegetation types. The Moot Plains Bushveld (“MPB”) is an open to closed, low, often thorny savanna dominated by various species of Acacia in the bottomlands and plains as well as woodlands of varying height and density of the lower hillsides. The Marikana Thornveld (“MT”) extends over North West and Limpopo Provinces, occurring on the plains from the Rustenburg area in the west, through Marikana and Brits, to the Pretoria area in the east, and forms part of the Savanna Biome40 in South Africa. MT consists of open Acacia karroo-dominated woodland, occurring in valleys and slightly undulating plains, and some lowland hills. An increased density of shrubs (and often alien vegetation) occurs along drainage lines, on termitaria, and rocky outcrops or other habitats protected from fire (Mucina & Rutherford, 2006).

40 The Savanna biome covers the northern and eastern parts of South Africa where a continuously shifting balance occurs between the woody and herbaceous vegetation.

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The MPB is considered Vulnerable with only 13% statutorily conserved mainly in the Magaliesberg Nature Area. The MT regional vegetation type is classified as Endangered with less than 1% statutorily conserved in reserves (i.e. the Magaliesberg Nature Area). This vegetation unit is highly impacted, and as much as 48% of the vegetation type has been transformed as a result of agriculture and urban development. Most agricultural development of this unit is in the western regions towards Rustenburg, while in the east (near Pretoria) industrial development is a greater threat of land transformation. (Mucina & Rutherford, 2006).

2. Site specific

Vegetation Communities The Waterval Mine area has been considerably transformed and very little viable land remains between infrastructure, roads and stockpile areas. The small pockets of natural to semi-natural vegetation in Waterval West constitute less than 20% of the site, Waterval East is almost completely transformed and Waterval North is largely rehabilitated areas (Heteropogon - Melinis Transformed Grassland). Due to the disturbances within the area and its transformed nature, 22 vegetation sampling points were recorded. These were located within the remaining natural and semi-natural areas as well as within the rehabilitated areas. These points were analysed using TWINSPAN. Three floral communities (Units A- C) with Unit A and B covering wooded communities including the mixed alien and indigenous bushclumps, and C covering the open grasslands (previously transformed). A gradient of structure (dense woodland to open areas) is evident from this ordination. The identified communities are listed in Table 29 and mapped in Figure 24

Figure 24(Broad vegetation communities within Waterval).

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Figure 23: Vegetation map for Waterval Mine

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Table 29: Broad Habitat/Vegetation communities

Unit Habitat – Vegetation unit AoC Ranking % Cover Moot Plains Bushveld / Marikana Thornveld Habitats A Acacia - Searsia Bushclumps 2.09 Medium A - Mixed Woodland & Alien Bushclumps 4.38 C Heteropogon - Melinis Transformed Grassland Medium – Low 39.18 Wetland / Riparian Habitats B Celtis - Searsia - Ziziphus Riparian Community Very High 1.84 Artificial Drainage Medium 0.41 Transformed Habitats Rehabilitated Open Pit Area Medium – Low 1.60 Alien Bushclumps Low 4.40 Landscaped & Mowed Areas Low 2.74 Mixed Alien & Disturbed Areas Low 8.46 Mining and Related Infrastructure Low – None 24.27 Recently Cleared Low – None 2.68 Dumping Areas Low – None 3.42 TSF and RWDs Low – None 4.53

* AoS: Areas of Significance (Fauna; Flora; Wetland Importance)

Figure 24: Broad Vegetation communities within Waterval (NSS, July 2015)

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A brief description on the natural / semi-natural vegetation communities is highlighted in Table 30 to Table 32 below. The remaining vegetated areas of the site are highly transformed areas, either landscaped or dominated by alien species.

Table 30: Unit A - Acacia - Searsia and Mixed Bushclumps Description

Acacia - Searsia and Mixed Bushclumps

Photographic representation

High Biodiversity Zone- MBG; MPB Vulnerable Habitat; SANBI Bushveld National Bankenveld Zones Priority Area; CBA 2.

Height of Graminoid layer: 25cm – 1.5m (Variable) Veg Structure Shrub-Tree Height: 2-5m

Units and % Acacia -Searsia Bushclumps – 2.09% Site Coverage Mixed Woodland & Alien Bushclumps – 4.38%

This habitat is very limited within the Study boundary. A number of bushclumps have established within the old pit area in the Waterval North section. The bushclumps within Waterval West are largely infested with alien species Condition/ specifically Category 1b species. Fire and grazing has not occurred within Description Waterval West, which has probably assisted in alien growth within the site. The objective of fire is to remove moribund grass material and combat bush encroachment. There is, however, limited maintenance in the form of cutting that has occurred. Dumping of organic garden waste is also evident in this area.

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Acacia - Searsia and Mixed Bushclumps

Garden waste within the open areas of Waterval West

Bonatea antennifera (P) CI Species Huernia cf transvaalensis (P) Scadoxus puniceus (P)

Agave sisalana 2 Argemone mexicana 1b Macfadyena unguis – cati 1b Arundo donax 1b Melia azedarach 1b Bauhinia purpurea 3 Morus alba 3 Canna indica 1b Opuntia ficus-indica 1b Caesalpinia ferrea Pennisetum setaceum 1b Datura ferox 1b Pinus spp 2 Alien species Datura stramonium 1b Ricinus communis 2 E. calmaldulensis 2 Senna didymobotrya Grevillea robusta 3 Solanum mauritianum 1b Ipomeoa purpurea 1b Tecoma stans 1b Jacaranda mimosifolia 1b Tipuana tipu 3 Lantana camara 1b Tithonia rotundifolia 1b Leucaena leucocephala 2 Xanthium strumarium 1b Ligustrum spp 1b

Acacia erubescens Welw. ex Oliv. Euclea crispa (Thunb.) Görke subsp. crispa Acacia karroo Hayne Heteropogon contortus (L.) Roem. & Acacia mellifera (Vahl) Benth. subsp. Schult. Common mellifera Hyperthelia dissoluta (Nees ex species Acacia sieberiana DC. var. woodii (Burtt Steud.) Clayton Davy) Keay & Brenan Lantana rugosa Thunb. Aloe greatheadii Schonland var. davyana (Schonland) Glen & D.S.Hardy Leucosidea sericea Eckl. & Zeyh.

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Acacia - Searsia and Mixed Bushclumps Aristida spp Melinis repens (Willd.) Zizka subsp. repens Asparagus spp Burch. Panicum maximum Jacq. Cenchrus ciliaris Peltophorum africanum Sond. Commelina africana L. var. krebsiana (Kunth) C.B.Clarke Pogonarthria squarrosa (Roem. & Schult.) Pilg. Crabbea hirsuta Harv. Polydora (Vernonia) poskeana Cynodon dactylon (L.) Pers. (Vatke & Hildebr.) H.Rob.sens.lat. Dicerocaryum eriocarpum (Decne.) Abels Searsia lancea (L.f.) F.A.Barkley Dichrostachys cinerea (L.) Wight & Arn. Searsia pendulina (Jacq.) Moffett subsp. africana Brenan & Brummitt var. africana Searsia pyroides (Burch.) Moffett var. pyroides Ehretia rigida (Thunb.) Druce subsp. rigida Urochloa panicoides P.Beauv. Enneapogon cenchroides (Licht. ex Roem. & Schult.) C.E.Hubb. Wahlenbergia (caledonica) undulata (L.f.) A.DC. Ziziphus mucronata Willd. subsp. mucronata

Species Examples

Euphorbia heterophylla Acacia tortilis MBG - Mining and Biodiversity Guidelines; CBA – Critical Biodiversity Area; MPB – Moot Plains Bushveld; P – Protected under the relevant Ordinance; 1b Category 1b Alien Invasive; 2Category 2 Alien Invasive; 3Category 3 Alien Invasive

Table 31: Unit B Celtis - Searsia - Ziziphus Riparian Community Description

Celtis - Searsia - Ziziphus Riparian Community

Photographic representation

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Celtis - Searsia - Ziziphus Riparian Community High Biodiversity Zone- MBG; MT Threatened Ecosystem; SANBI Bushveld National Bankenveld Zones Priority Area; CBA 2; Unclassified FEPA

Height of herbaceous layer: 75cm – 1.2m (Variable) Veg Structure Tree Height: > 7m Coverage: 20-30% herbaceous cover in understory

% Site 9.36% Coverage The tree layer within this unit is a mix of alien and indigenous species. Human movement through the understory is evident as well as harvesting of certain woody species. Condition/ Riparian vegetation regulates river flow, improves water quality, provides habitats Description for faunal species and corridors for their movement, controls river temperatures, provides nutrients and maintains bank stability. A study was conducted on the Hex River by du Plessis (2008) and findings indicated that the current status of the Riparian Vegetation of the Hex River was rated as GOOD, indicating that the ecosystem is in a good state and biodiversity is largely intact (du Plessis, 2008).

CI Species Scadoxus puniceus (P)

Cl Faunal Half-collared Kingfisher (NT) Species Bidens pilosa Jacaranda mimosifolia D.Don 1b outside urban Cardiospermum grandiflorum 1b Melia azedarach L. 1b outside urban Alien species Dolichandra (Macfadyena) unguiscati (L.) A.H.Gentry 1b Solanum mauritianum (edges) 1b Eucalyptus camaldulensis 1b wet Zinnia peruviana (L.).

Asparagus spp Celtis africana Burm.f. Panicum maximum Jacq. Clematis brachiata Thunb. Rhoicissus spp Common Diospyros lycioides Desf. subsp. Searsia lancea (L.f.) F.A.Barkley species lycioides Setaria lindenbergiana (Nees) Stapf Grewia flava Ziziphus mucronata Willd. subsp. Melinis repens (Willd.) Zizka subsp. mucronata repens

Species Examples

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Celtis - Searsia - Ziziphus Riparian Community Setaria lindenbergiana Celtis africana MBG - Mining and Biodiversity Guidelines; CBA – Critical Biodiversity Area; MT - Marikana Thornveld; P – Protected under the relevant Ordinance; 1b Category 1b Alien Invasive; NT – Near Threatened

Table 32: Unit C Heteropogon - Melinis Transformed Grassland Description

Heteropogon - Melinis Transformed Grassland

Photographic representation

National High Biodiversity Zone- MBG; MT Threatened Ecosystem; MPB Vulnerable Zones Habitat; SANBI Bushveld Bankenveld Priority Area; CBA 2. Height of herbaceous layer: 15cm – 1m (Variable) Veg Structure Coverage: Refer to the Landscape Function Assessment (LFA) for a detailed % cover

% Site 39.18% of the Study Area Coverage From the LFA conducted by NSS for the site (NSS, 2015), overall, with the exception of trees which are still sparse, the area under rehabilitation has recovered well with a good mix of grasses of differing heights and structure with the old pit area barely visible in current Google Earth imagery. Patch dynamics and soil surface functionality have increased slightly. The low PAI in both years Condition/ indicates, however, that grass cover is far from its theoretical maximum. Description Historical imagery (below) indicated that prior to the open pit, the northern area was under extensive agriculture, which contributes to the current transformed nature and limited diversity of this unit. Within the small pockets in Waterval West, species richness was considered slightly improved as opposed to the grasslands in Waterval North.

CI Species No CI species detected

Bidens pilosa L. Paspalum urvillei Steud. 1b Campuloclinium macrocephalum Richardia brasiliensis Gomes Conyza bonariensis (L.) Cronquist Schkuhria pinnata (Lam.) Kuntze ex Gomphrena celosioides Mart. Thell. Alien species Hibiscus trionum L. Sesbania bispinosa (Jacq.) W.Wight var. bispinosa Pennisetum setaceum (Forssk.) Chiov. 1b Tagetes minuta L. Portulaca oleracea L. Zinnia peruviana (L.) L.

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Heteropogon - Melinis Transformed Grassland Melinis repens (Willd.) Zizka subsp. Acacia karroo Hayne repens Aristida congesta Roem. & Schult. Neorautanenia ficifolia subsp. congesta Nidorella anomala Steetz Cynodon dactylon (L.) Pers. Nidorella hottentotica DC. Dicerocaryum eriocarpum (Decne.) Abels Perotis patens Gand. Dicoma macrocephala Pogonarthria squarrosa (Roem. & Schult.) Pilg. Common Dichrostachys cinerea (L.) Wight & Arn. species subsp. africana Brenan & Brummitt var. Searsia lancea (L.f.) F.A.Barkley africana Sesbania bispinosa (Jacq.) W.Wight Eragrostis rigidior Pilg. var. bispinosa Heteropogon contortus (L.) Roem. & Sida dregei Burtt Davy Schult. Themeda triandra Forssk. Hyperthelia dissoluta (Nees ex Steud.) Tribulus terrestris L. Clayton Triumfetta sonderi Kalanchoe paniculata Harv. Urochloa panicoides P.Beauv.

Species Examples

Dicoma macrocephala Triumfetta sonderi MBG - Mining and Biodiversity Guidelines; CBA – Critical Biodiversity Area; MPB – Moot Plains Bushveld; MT - Marikana Thornveld; 1b Category 1b Alien Invasive; P – Protected under the relevant Ordinance; *1-Category 1 species; PAI - Patch Area Index

Conservation Important Flora Within this section the Conservation Important (“CI”) species are discussed. These include the National Threatened Plant Species Programme (“TSP”) lists, any Protected species according to the Nature Conservation Ordinance (12 of 1983) and any specific Endemic or Rare species. The Threatened Plant Species Programme (“TSP”) is an ongoing assessment that revises all threatened plant species assessments made by Craig Hilton-Taylor (1996), using IUCN Red Listing Criteria modified from Davis et al. (1986). According to the TSP Red Data list of South African plant taxa (POSA, June 2015), there are 46 Red Data listed species (Table 33) within the North West Province (including Data Deficient

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species) of which 2 species are Critically Endangered (“CR”), 4 Endangered (“EN”) and 8 are Vulnerable (“VU”).

Table 33: Numbers of Conservation Important plant species per Red Data category within South Africa and North West (updated June 2015)

SOUTH NORTH THREAT STATUS 2527CB AFRICA WEST EX (Extinct) 28 0 0

EW (Extinct in the wild) 7 0 0

CR PE (Critically Endangered, Possibly Extinct) 57 2 0

CR (Critically Endangered) 332 0 0

EN (Endangered) 716 4 0

VU (Vulnerable) 1 217 8 0

NT (Near Threatened) 402 8 0

Critically Rare (known to occur only at a single site) 153 1 0

Rare (Limited population but not exposed to any direct or potential 1 212 4 1 threat)

Declining (not threatened but processes are causing a continuing 47 7 0 decline in the population)

LC (Least Concern) 13 856 1 935 248

DDD (Data Deficient - Insufficient Information) 348 0 0

DDT (Data Deficient - Taxonomically Problematic) 904 12 0

Total spp (including those not evaluated) 23 399 2 416 260

From the POSA website (QDS 2527CB) only 1 species has been recorded in the Study Region, Frithia pulcha. The conservation status of this species is considered Rare. Although the sampling was conducted outside of the flowering time for this species, the probability of it occurring on site is extremely low. During the site visit CI species within Waterval West were identified, Huernia transvaalensis and

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Bonatea antennifera (

Figure 25Figure 25). Scadoxus puniceus was identified along the Riparian zone within Waterval North. These three species are considered Protected species under the Nature Conservation Ordinance, 12 of 1983. Protected Species may not be cut, disturbed, damaged, and destroyed without obtaining a permit from North West Province or a delegated authority.

The past studies also yielded limited results in terms of CI species. Within 2007, no CI species were recorded and during the 2011 survey only the then Protected Pellaea calomelanos and the current Protected Scadoxus puniceus were noted. In addition to species that are considered Protected, special mention must be given to Celtis africana, a tree species that under serious threat in certain parts of South Africa due to, amongst others, hybridisation with alien species, C. sinensis and C. australis. Large individuals were located within Waterval West and along the Hex River. These trees along with others in the riparian zone regulates river flow, improves water quality, provides habitats for CI fauna and corridors for their movement, controls river temperatures, provides nutrients and maintains bank stability. The small, round fruits are mass produced and are eaten by numerous bird species, as well as by vervet monkeys. The species is also the host tree for the larvae of the African snout butterfly (Libythea labdaca). This species also has cultural value.

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Figure 25: Locations of observed Conservation Important floral species (NSS, July 2015)

Alien Invasive vegetation NSS conducted an Alien Invasive Plan for Glencore Alloy Operations in 2009, which included Waterval East and West. A large number of alien species were recorded (cover and frequency), with the Top 6 species being: • Arundo donax (Giant reed); • Conyza bonariensis (Flax-leaf Fleabane); • Flaveria bidentis (Smelter's bush (Yellow flower)); • Lantana camara (Common Lantana); • Melia azedarach (Syringa); and • Tagetes minuta (Khakibos).

These species are scattered throughout the Waterval West and East sites, however, are dominant along the fence of the TSF. Arundo donax is located in the northern section of Waterval West and along the settling ponds / RWDs to the north of the TSF. This is still evident in the 2015 study. Lantana camara was prolific and still is abundant along the fence lines as well as in the semi-natural pocket of vegetation in the western corner of the study area.

Combined surveys show approximately 50 species of aliens and 42% of these being Category 1b species that require immediate control and eradication (Table 34). One species not detected in the previous surveys within Waterval North was the Pom Pom Weed (Campuloclinium macrocephalum). This is an aggressive invader and should be eradicated on immediate detection. Currently the Category

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2 species Eucalyptus camaldulensis as well as Casuarina cunninghamiana and the Pinus species are found mainly along the boundaries of the study area and are serving as a visual barrier as well as protection against wind-blown dust during operations and on the TSF. These will require permits if they are to remain.

NSS highlighted in 2009 that in the northern corner of the mine, there was evidence of dumping specifically large Granite slabs and boulders. A number of alien species are growing in between these boulders and in terms of successful removal and control, it was recommended that either the building material was sold off or removed off site to a designated landfill site. In the 2015 study, these were still present within the northern section of Waterval West.

Table 34: The main observed alien invasive plant species within Waterval East, West and North

Family Scientific Name Survey CARA NEMBA AGAVEACEAE Agave sisalana Perrine 2011/2015 2 2

Argemone mexicana / PAPAVERACEAE 2011/2015 1 1b ochroleuca

POACEAE Arundo donax L. 2011/2015 1 1b

FABACEAE Bauhinia purpurea 2011/2015 3 3 in NW

ASTERACEAE Bidens pilosa L. 2015 Weed Weed

MYRTACEAE Callistemon rigidus 2011/2015 3 -

CANNACEAE Canna indica 2011/2015 1 1b

Campuloclinium ASTERACEAE 2015 1 1b macrocephalum

CASUARINACEAE Casuarina cunninghamiana 2011/2015 2

Cardiospermum grandiflorum SAPINDACEAE 2015 1b Sw.

CACTACEAE Cereus jamacaru DC. 2015 1 1b

Conyza bonariensis (L.) ASTERACEAE 2015 Weed Weed Cronquist

SOLANACEAE Datura ferox 2011/2015 1 1b

SOLANACEAE Datura stramonium 2011/2015 1 1b

1b in W Cape & ROSACEAE Eriobotrya japonica 2011/2015 3 Forest only

Eucalyptus camaldulensis 2** and 1b in MYRTACEAE 2011/2015 2 Dehnh. wetlands

1b in riparian MYRTACEAE Eucalyptus grandis 2011/2015 2 areas

EUPHORBIACEAE Euphorbia heterophylla L. 2015 Weed Weed

APOCYNACEAE Gomphocarpus fruticosus (L.) 2015 SA Weed

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Family Scientific Name Survey CARA NEMBA Aiton f. subsp. fruticosus

AMARANTHACEAE Gomphrena celosioides Mart. 2015 Weed Weed

PROTEACEAE Grevillea robusta 2011/2015 1 3

MALVACEAE Hibiscus trionum L. 2015 Weed Weed

CONVOLVULACEAE Ipomoea purpurea 2011/2015 3 1b

BIGNONIACEAE Jacaranda mimosifolia D.Don 2011/2015 3 1b

VERBENACEAE Lantana camara L. 2011/2015 1 1b

FABACEAE Leucaena leucocephala 2011/2015 1 2 in NW

OLEACEAE Ligustrum spp 2011/2015 3 1b

BIGNONIACEAE Macfadyena unguis – cati 2011/2015 1 1b

1b (3 in urban MELIACEAE Melia azedarach L. 2011/2015 3 areas)

MORACEAE Morus alba 2011/2015 3 3

APOCYNACEAE Nerium oleander 2011/2015 1 1b

SOLANACEAE Nicotiana glauca Graham 2011/2015 1 1b

CACTACEAE Opuntia ficus-indica (L.) Mill. 2011/2015 1 1b

Pennisetum setaceum POACEAE (Forssk.) 2011/2015 1 1b Chiov.

POACEAE Paspalum urvilli 2015 Weed Weed

PHYTOLACCACEAE Phytolacca dioica 2011/2015 3 3

PINACEAE Pinus spp 2011/2015 2

PORTULACACEAE Portulaca oleracea L. 2015 Weed Weed

RUBIACEAE Richardia brasiliensis Gomes 2015 Weed Weed

Ricinus communis L. var. EUPHORBIACEAE 2011/2015 2 2 communis

Schkuhria pinnata (Lam.) ASTERACEAE Kuntze 2015 Weed Weed ex Thell.

1b in E & W FABACEAE Senna didymobotrya 2011/2015 1 Cape; KZN, L, M only

Sesbania bispinosa (Jacq.) FABACEAE 2015 Weed Weed W.Wight var. bispinosa

SOLANACEAE Solanum mauritianum 2011/2015 1 1b

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Family Scientific Name Survey CARA NEMBA SOLANACEAE Sorghum halepense 2011/2015 2 2

ASTERACEAE Tagetes minuta L. 2015 Weed Weed

TAMARICACEAE Tamarix ramossisima 2011/2015 3 1b

Tecoma stans (L.) Juss. ex BIGNONIACEAE Kunth 2011/2015 1 1b var. stans

FABACEAE Tipuana tipu 2011/2015 3 3

Tithonia rotundifolia (Mill.) ASTERACEAE 2011/2015 Weed 1b S.F.Blake

ASTERACEAE Xanthium strumarium 2011/2015 1 1b

ASTERACEAE Zinnia peruviana (L.) L. 2015 Weed Weed * Highlights in grey represent Category 1 species through either CARA or NEMBA; L = Limpopo; M = Mpumalanga; KZN = Kwa Zulu Natal; E & W Cape = Eastern & Western Cape; ** Category 2 for plantations, woodlots, bee- forage areas, wind-rows and the lining of avenues.

Chapter F: Fauna

The information contained in this section has been sourced from the following document: • Natural Scientific Services cc. July 2015. Terrestrial Biodiversity Assessment. Glencore Alloys Waterval, Rustenburg (attached in Annexure G2) (referred to as NSS, July 2015). To date five mammals, 59 bird, four reptiles, nine butterfly and six dragonfly species have been observed during all the NSS surveys at Waterval. Context for these figures is provided in Table 35 which compares observed species richness on site with that expected for the site, for the QDS and the greater region.

Table 35: Summary of faunal species richness on site as compared to a regional scale

POTENTIAL OBSERVED FAUNAL GROUP 2007 & REGION* QDS** SITE*** 2015 TOTAL 2011 Mammals 142 27 49 4 4 7

Birds 402 331 252 39 33 59

Reptiles 73 31 37 2 2 4

Frogs 24 12 15 0 0 0

Butterflies 188 43 149 0 9 9

Dragonflies & Damselflies 42 0 36 0 6 6

Megalomorph Spiders 0 0 0 0

Scorpions 12 0 5 0 0 0

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POTENTIAL OBSERVED FAUNAL GROUP 2007 & REGION* QDS** SITE*** 2015 TOTAL 2011 KEY

*Species whose distribution ranges overlap the greater region (2526BB, 2527AC, 2527CA, 2527CB) **Species that have been recorded during attlassing projects within the QDS 2526 BB (ADU, 2015) ***Species that are likely to occur on site (LoO of 2 or 3)

1. Mammals The Marikana Thornveld regional vegetation unit supports a moderate diversity of mammals (78 spp.), but at low densities (0.02 spp./km2) and with few (0.05%) game species (Mucina & Rutherford, 2006; Power, 2014). Species richness within this vegetation type has decreased by 23% in recent times based on historical data (Power, 2014). MammalMap (2015) lists 27 species for the QDS 2527CB covering the study area. Based on distribution and habitat just over 61 species are considered likely to occur. These include mostly hardy and adaptable species that are tolerant of high levels of habitat transformation and disturbance. A total of seven species of mammals have been recorded by NSS to date at Waterval. These include Common Mole-rat, Namaqua Rock Mouse, Red Veld Rat, Scrub Hare, Slender Mongoose, Kudu (habituated individual observed with cows during 2011 visit) and Steenbok. The lack of rocky outcrops precludes numerous ripicolous species (e.g. Rock Hyrax and Klipspringer). Given the extent to which the soil profile has been transformed no golden moles are considered likely to occur. The Hex River that borders the study area to the east provides a valuable corridor for dispersal and genetic exchange of a wide range of locally occurring fauna. The river is of a significant size and more than likely supports Cape Clawless Otter and Water Mongoose. The adjacent open veld west of the river and north of the operations likely supports hardy and ubiquitous species with the exception of a few potentially occurring CI species.

Eight mammal species of conservation importance (“CI”) are likely to occur, none were observed on site. Suitable habitat exists at Waterval, specifically within the office gardens and adjacent veld, for the Southern African Hedgehog (NT) which typically inhabits a diversity of habitats (including gardens) in the temperate to semi-arid interior of South Africa where there is thick, dry vegetation cover for nesting and an abundance of insects and other food items (Skinner & Chimimba 2005; Stuart & Stuart 2007). Hedgehogs are widespread but uncommon in North West Province. Questionnaire surveys yielded 23 records for this species within the Zeerust Thornveld vegetation type (Power, 2014). In terms of CI carnivores Serval (NT) and Cape Fox (PS) may also occur. Past NSS studies in a variety of locations have shown both these species to be fairly resilient to high levels of habitat transformation and human activity.

Table 36: Potentially occurring CI mammal species in the study area

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Conservation Status

6

1 2,4 2,4 S.A. Order & Species Common Name Global S.A. Red 2,4,6 IUCN5 NEM:BA3 Data2,4 LoO 2527CA AFROSORICIDA (Golden moles) Rough-haired Golden Chrysospalax villosus VU (U) CR SCH 4 Mole

Neamblysomus julianae Juliana's Golden Mole VU (U) VU VU 4

Juliana's Golden Mole – Neamblysomus julianae VU (U)* CR VU* 4 Pretoria subpopulation

EULIPOTYPHLA (Hedgehogs & shrews) Crocidura Maquassie Musk Shrew LC (U) VU - 4 maquassiensis

Southern African Atelerix frontalis LC (S) NT PS 2 Hedgehog

CHIROPTERA (Bats) Rhinolophus Hildebrandt's LC (U) NT - 4 hildebrandtii Horseshoe Bat

Geoffroy's Horseshoe Rhinolophus clivosus LC (U) NT - 3 Bat

Darling's Horseshoe Rhinolophus darlingi LC (U) NT - 3 Bat

Blasius's Horseshoe Rhinolophus blasii LC (D) NT - 4 Bat

Bushveld Horseshoe Rhinolophus simulator LC (D) NT - 3 Bat

Percival's Short-eared Cloeotis percivali LC (U) VU - 4 Trident Bat

Miniopterus natalensis Natal Long-fingered Bat LC (U) NT - 3

Pipistrellus rusticus Rusty Pipistrelle LC (U) NT - 3

PHOLIDOTA (Pangolin)

Manis temminckii Pangolin LC (D) VU VU 4

RODENTIA (Rodents) Mystromys White-tailed Rat EN (D) EN - 4 albicaudatus

Dasymys incomtus Water Rat LC (U) NT - 4

CARNIVORA (Carnivores) Hyaena brunnea Brown Hyaena NT (D) NT PS 4

Crocuta crocuta Spotted Hyaena LC (D) NT PS 5

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Conservation Status

6

1 2,4 2,4 S.A. Order & Species Common Name Global S.A. Red 2,4,6 IUCN5 NEM:BA3 Data2,4 LoO 2527CA Acinonyx jubatus Cheetah VU (D) VU VU 5

Panthera pardus Leopard NT (D) LC VU 4 1

Panthera leo Lion VU (D) VU VU 5

Felis nigripes Black-footed Cat VU (D) LC PS 4

Leptailurus serval Serval LC (S) NT PS 3

Lycaon pictus African Wild Dog EN (D) EN EN 5

Vulpes chama Cape Fox LC (S) LC PS 3

Lutra maculicollis Spotted-necked Otter LC (D) NT PS 4

Mellivora capensis Honey Badger LC (D) NT PS 4

PROBOSCIDEA (Elephants) Loxodonta africana African Elephant VU (I) LC PS 5

Equus quagga Plains Zebra LC (S) LC - 5

Ceratotherium simum White Rhinoceros NT (I) LC PS 5

Black Rhinoceros – Diceros bicornis CR (I)* VU EN* 5 Northeastern Race

Black Rhinoceros – Diceros bicornis CR (I)* CR EN* 5 Southwestern Race

RUMINATA (Even-toed ungulates) Hippopotamus Hippopotamus VU (D) LC - 5 amphibius

Connochaetes gnou Black Wildebeest LC (I) LC PS 5

Damaliscus lunatus Tsessebe LC (D) EN EN 5

Hippotragus niger Sable LC (S) VU - 5

Philantomba monticola Blue Duiker LC (S) VU VU 5

Redunca arundinum Reedbuck LC (S) LC PS 5

Ourebia ourebi Oribi LC (D) EN EN 5

KEY Status: CR = Critically Endangered; D = Declining; DD = Data Deficient; EN = Endangered; I = Increasing; LC = Least Concern; NT = Near Threatened; PS = Protected Species; S = Stable; U = Unknown; VU = Vulnerable.

Likelihood of Occurrence (LoO): 1 = Present; 2 = High; 3 = Moderate; 4 = Low; 5 = May occur as a managed population; a = previous survey only; b = both surveys c = current survey only.

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Conservation Status

6

1 2,4 2,4 S.A. Order & Species Common Name Global S.A. Red 2,4,6 IUCN5 NEM:BA3 Data2,4 LoO 2527CA Sources: 1Stuart & Stuart (2007); 2Friedmann & Daly (2004); 3ToPS List (2007); 4Monadjem et al. (2010); 5IUCN (2013.1); 6MammalMap (2015).

Mine shafts in the vicinity may provide suitable habitat for a number of NT bat species that require subterranean roosts namely Geoffroy's Horseshoe Bat, Darling's Horseshoe Bat, Bushveld Horseshoe Bat and Natal Long-fingered Bat. The most likely to occur are Bushveld Horseshoe Bat and Natal Long- fingered Bat both of which have been recorded within the QDS (MammalMap, 2015). Another CI bat species that may occur with a moderate to low likelihood of occurrence is the Rusty Pipistrelle (NT) a small bat frequents savannah woodland and roosts in rock crevices and under tree bark (Stuart & Stuart, 2007). Although no bats were detected (due to the study being limited in time and night work being unfeasible) several widespread and adaptable species almost certainly occur such as Wahlberg's Epauletted Fruit Bat, Egyptian Free-tailed Bat, Yellow-bellied House Bat, Mauritian Tomb Bat and Cape Serotine.

2. Birds Of the 402 regionally occurring bird species 331 have been recorded during SABAP 1 & 2 (2015) surveys in the QDS (2627DB) and pentad (2540_2715) covering Waterval. Most of these species are likely to have been recorded at more significant habitat features in the area and only some 252 species are likely to occur on site. During all visits to Waterval NSS has recorded 59 species. Bird diversity is certainly highest near the main office where the lush setting attracts a wide array of garden birds and bushveld species alike (e.g. Acacia Pied Barbet, Violet-eared Waxbill, African Paradise-flycatcher, Palm Swift, Grey-backed Camaroptera, and Bronze Mannikin). Outside this area in the adjacent veld, diversity is significantly lower but increases towards the Hex River.

Four CI bird species may occur at Waterval. One of these species was detected at Waterval North, the Half-collared Kingfisher (NT). A single individual was observed flying down the Hex River during the current 2015 survey. Throughout its range, this uncommon species occurs at unusually low densities (even in prime habitat) and due to its strict reliance on fast flowing, clear, perennial streams and rivers with an abundance of marginal vegetation the species is highly susceptible to effects that compromise this habitat. Specifically declines in water quality from sedimentation, erosion, pollution and extraction but also from the removal of indigenous vegetation or alien encroachment (Barnes, 2000; Maclean, 1996).

The other potentially occurring species include Lanner Falcon, Lesser Kestrel and Peregrine Falcon. All three of these CI raptor species may occur based on distribution but would only utilise the site for foraging as the Lesser Kestrel is a non-breeding migrant while Lanner and Peregrine falcons typically nest on cliffs and high man-made structures.

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All other regionally occurring CI water bird species are precluded by the lack of significant pans and dams. The large CI raptor species are all unlikely to occur based on a lack of suitable habitat and prey base in the form of large game which also precludes to Red-billed Oxpecker. The site is too small and active to support any of the CI large terrestrial bird species. African Grass Owl is unlikely to occur based on a lack of suitable breeding and foraging habitat in the form of sufficiently dense Imperata cylindrica or other rank grass. Melodious Lark is likely precluded by the lack of its preferred habitat open Themeda climax grassland. Yellow-throated Sandgrouse is unlikely to occur based on the extensive habitat transformation on site and nearby vicinity.

Table 37: Present and potentially occurring CI bird species in the study area

Conservation Status SABAP4,5

Category1 & Common Name4 S.A. Species4 Global S.A. 3 Red 2 IUCN NEM:BA 5 Data6 oO L 2527CB 2540_2715 1. Ocean birds Pelecanus Pink-backed Pelican LC (S) VU EN 4 x rufescens

2. Inland water birds Ciconia nigra Black Stork LC (U) NT VU 4 x

Gorsachius White-backed Night- LC (S) VU - 4 leuconotus heron

Leptoptilos Marabou Stork LC (I) NT - 4 crumeniferus

Mycteria ibis Yellow-billed Stork LC (D) NT - 4 x x

Phoeniconaias Lesser Flamingo NT (D) NT - 4 x minor

Phoenicopterus Greater Flamingo LC (I) NT - 4 x roseus

Rynchops EX African Skimmer NT (D) 4 x flavirostris (Vag)

3. Ducks & wading birds Oxyura maccoa Maccoa Duck NT (D) LC - 4

Rostratula Greater Painted- LC (D) NT - 4 x benghalensis snipe

4. Large terrestrial birds Anthropoides Blue Crane VU (S) VU EN 4 x paradiseus

Ardeotis kori Kori Bustard NT (D) VU VU 4

Eupodotis White-bellied LC (D) VU - 4 senegalensis Korhaan

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Conservation Status SABAP4,5

Category1 & Common Name4 S.A. Species4 Global S.A. 3 Red 2 IUCN NEM:BA 5 Data6 oO L 2527CB 2540_2715 Sagittarius Secretarybird VU (D) NT - 4 x serpentarius

5. Raptors Aquila rapax Tawny Eagle LC (S) VU VU 4

African Marsh- Circus ranivorus LC (D) VU PS 4 x harrier

Falco biarmicus Lanner Falcon LC (I) NT - 3 x

Falco naumanni Lesser Kestrel LC (S) VU (NB) VU 3 x

Falco peregrinus Peregrine Falcon LC (S) NT VU 3 x

White-backed Gyps africanus EN (D) VU EN 4 Vulture

Gyps coprotheres Cape Vulture VU (D) VU EN 4 x

Polemaetus Martial Eagle VU (D) VU VU 4 bellicosus

Lappet-faced Torgos tracheliotos VU (D) VU EN 4 Vulture

6. Owls & nightjars

Tyto capensis African Grass-owl LC (D) VU VU 4

7. Sandgrouse, doves etc Yellow-throated Pterocles gutturalis LC (D) NT - 4 x Sandgrouse

8. Aerial feeders, etc Half-collared Alcedo semitorquata LC (D) NT - 1c Kingfisher

Coracias garrulus European Roller NT (D) LC (NB) - 4 x

9. Cryptic & elusive insect-eaters Certhilauda Agulhas Long-billed NT LC (S) - 4 x brevirostris Lark (End)

NT Mirafra cheniana Melodious Lark NT (D) - 4 (End)

11. Oxpeckers & nectar feeders Buphagus Red-billed Oxpecker LC (D) NT - 4 x erythrorhynchus

KEY

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Conservation Status SABAP4,5

Category1 & Common Name4 S.A. Species4 Global S.A. 3 Red 2 IUCN NEM:BA 5 Data6 oO L 2527CB 2540_2715 Status: D = Declining; EN = Endangered; I = Increasing; LC = Least Concern; NT = Near Threatened; PS = Protected Species; S = Stable; U = Unknown; VU = Vulnerable. Likelihood of Occurrence (LoO): 1 = Present; 2 = High; 3 = Moderate; 4 = Low; 5 = May occur as a managed population; a = previous survey only; b = both surveys c = current survey only. Sources: 1Newman (2002); 2ToPS List (2007); 3IUCN (2013.1); 4SABAP 1 (2013); 5SABAP2 (2015); 6Barnes (2000)

3. Reptiles Some 70 reptile species may occur in the region. Of these 31 species have been recorded within the QDS covering the study area (ReptileMap, 2015). On site, only 37 common and widespread species are considered likely to occur based on distribution and the availability of suitable habitat.

Reptile abundance is likely to be concentrated within the lush gardens and buildings of the main mine office. Two species were detected here during the brief site visit Common Dwarf Gecko and Variable Skink. Species not detected but that are highly likely to around the main offices include Speckled Rock Skink, Rhombic Night Adder, Common House Snake, Snouted Cobra, Mozambique Spitting Cobra, Red-lipped Snake, Boomslang, Spotted Bush Snake, Common Tropical House Gecko, Puff Adder, Transvaal Gecko, Peter's Thread Snake, Tree Agama, and Turner's Gecko. In the adjacent open veld, particularly closer to the Hex River, species such as Brown Water Snake and Savanna Lizard were detected but all of the above mentioned species including several others (e.g. Nile Monitor, Yellow- throated Plated Lizard, Cape Skink, Nile Monitor and Common Flap-neck Chameleon) may well occur.

No CI reptiles were observed during the site visit. Of the two regionally occurring CI species neither Southern African Python nor Nile Crocodile are likely to occur. The former is precluded by a lack of suitable rocky and wetland habitat but also by the perimeter fences and high activity levels while the latter is only likely to occur in reserves and breeding ranches in the greater area.

Table 38: Potentially occurring CI reptile species in the study area

Status

4

1 1 S.A. Family & Species Common Name Global S.A. Red 1,4 IUCN3 NEM:BA2 Data1 LoO 2527CA CROCODYLIDAE (Crocodile) Crocodylus niloticus Nile Crocodile LC 2VU PS 4

PYTHONIDAE (Python) Southern African Python natalensis - 2LC PS 4 Python

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Status

4

1 1 S.A. Family & Species Common Name Global S.A. Red 1,4 IUCN3 NEM:BA2 Data1 LoO 2527CA KEY

Status: LC = Least Concern; PS = Protected Species; VU = Vulnerable. Likelihood of Occurrence (LoO): 1 = Present; 2 = High. Sources: 1Bates et al. (2014); 2ToPS List (2007); 3IUCN (2013.1); 4ReptileMap (2014)

4. Frogs Of the 24 regionally occurring frog species 12 species have been recorded during atlassing surveys in the QDS (FrogMap, 2015). Based on distribution and the availability of suitable habitat around 15 species may occur at Waterval. No frog species have been recorded during any of the NSS site visits. One small shallow artificial depression was encountered in the adjacent open veld that showed signs of holding water for extremely brief periods of time. This habitat is likely to support only those frog species that are capable of breeding in small highly ephemeral, rain-filled puddles such as Tremolo Sand Frog, Natal Sand Frog, Tandy's Sand Frog and Boettger’s Caco. Rain permitting the depression may also support Broad-banded Grass Frog, Plain Grass Frog, Bubbling Kassina and Banded Rubber Frog. This depression appears too vegetated, artificial and ephemeral to support either of the two regionally occurring CI frog species (Table 39) namely Giant Bullfrog (NT) and African Bullfrog (PS) and no suitable habitat for these was encountered elsewhere on site. Other species that may occur include Bushveld Rain Frog (which is not dependant on standing water to breed as tadpoles develop within a burrow kept moist by unfertilized egg capsules) as well as the hardy and ubiquitous species Common River Frog, Platanna, Guttural Toad, Eastern Olive Toad, Raucous Toad and Red Toad.

Table 39: Potentially occurring CI frog species in the study area

Status

4 4 4 5

S.A. Family & Species Common Name Global S.A.

Red 3,5 IUCN2 NEM:BA1 Data3 LoO 2527CA PYXICEPHALIDAE (River, stream, moss & sand frogs)

Pyxicephalus Giant Bullfrog LC (D) NT PS 3 adspersus

Pyxicephalus edulis African Bullfrog LC (U) LC PS 3

KEY

Status: D = Declining; LC = Least Concern; NT = Near Threatened; PS = Protected Species; U = Unknown. Likelihood of Occurrence (LoO): 3 = Moderate.

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Status

4 4 4 5

S.A. Family & Species Common Name Global S.A.

Red 3,5 IUCN2 NEM:BA1 Data3 LoO 2527CA Sources: 1ToPS List (2007); 2IUCN (2013.1); 3Minter et al. (2004); 4Du Preez & Carruthers (2009); 5FrogMap (2015)

5. Terrestrial Macro-invertebrates Butterflies Atlas records from the ADU’s LepiMap (2015) list 43 species for the QDS covering the study area and some 150 species are considered likely to occur. No CI butterfly species are likely to occur on site. The only regionally occurring butterfly of conservation importance, the Marsh Sylph butterfly (RHS), is unlikely to occur based on a lack of habitat and presence of its larval host plant Swamp Rice Grass (Leersia hexandra). In total nine species have been observed on site and include Common Blue, Topaz- spotted Blue, Painted Lady, Bushveld Orange Tip, Citrus Swallowtail, Common Bush Brown, Brown- veined White, Broad-bordered Grass Yellow and African Monarch. Dragonflies and Damselflies Analysis of distribution data provided in Samways (2008) suggests that some 42 species have the potential to occur in the region. None of these species have been assigned a Red List status (Samways, 2006). Of these some 36 species may occur on site based on distribution and habitat. In total 6 dragonfly species have been observed at Waterval. Of greatest significance to the presence of dragonflies is the Hex River, which provide a variety of microhabitats in the form of fast flowing shallow riffles (limited), deep pools with overhanging vegetation, quiet backwaters and shady riparian thicket. During the current 2015 survey this habitat was briefly sampled (ca. 1 hour) in the late afternoon and yielded five species Red-veined Dropwing, Slate Sprite, Machado's Skimmer, Forest Malachite and Dancing Jewel. Certainly more species occur. One of these species Forest Malachite (Chlorolestes tessellatus) although not red-listed does has a Dragonfly Biotic Index (“DBI”) rating of 4. The DBI is based on three criteria: geographical distribution, conservation status and sensitivity to change in habitat and ranges from a minimum of 0 to a maximum of 9. Very common, hardy and widespread species score 0 while a range-restricted, threatened and sensitive endemic species scores 9. Searches in the office gardens yielded Phantom Flutterer and Red-veined Dropwing. Scorpions Eight of the 12 regionally occurring scorpion species are likely to occur on site based on habitat suitability and distribution. Of these two species are of conservation importance, listed as nationally PS (ToPS, 2007) the burrowing scorpions Opistophthalmus glabifrons and Opistophthalmus carinatus. The lack of prime rocky outcrops on site precludes the presence of Hadogenes gunning and Uroplectes planimanus. Additionally, the site lies within an area of range overlap of three stinger scorpion species namely Uroplectes carinatus, Uroplectes vittatus and Uroplectes traingulifer. Both U. carinatus and U. triangulifer are common and widespread and may be found in a variety of habitats while U. vittatus is more likely to be encountered under tree bark and in logs (Leeming, 2003). Other scorpions that may

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occupy this type of microhabitat are the thick-tailed scorpions. These species are of greater medical importance with a particularly potent venom. Two species may occur at Waterval namely Parabuthus mossambicensis and Parabuthus transvaalicus. Megalomorph Spiders These include baboon and trapdoor spiders. Certain members of the baboon spider group (family Theraphosidae) are listed as nationally PS on the ToPS (2007) List. Three genera may occur on site. These include horned baboon spiders (Ceratogyrus sp.), common baboon spiders (Harpactira sp.) and Golden Brown Baboon Spiders (Pterinochilus sp.). No baboon spiders or their burrows were detected during site visits.

Table 40: Potentially occurring CI terrestrial macro-invertebrate species in the study area

SPECIES COMMON NAME LoO STATUS Butterfly Metisella meninx Marsh Sylph 4 RHS

Beetles

Manticora spp. Monster Tiger Beetles 2 PS

Oonotus spp. Stag Beetles 3 PS

Scorpions Hadogenes gunningi Flat rock scorpions 4 PS

Hadogenes troglodytes Flat rock scorpions 4 PS

Opistophthalmus glabifrons Burrowing scorpions 2 PS

Opistophthalmus carinatus Burrowing scorpions 3 PS

Spiders Ceratogyrus sp. Horned Baboon Spiders 3 PS

Harpactira sp. Common Baboon Spiders 3 PS

Pterinochilus sp. Golden Brown Baboon Spiders 3 PS

KEY Status: NT = Near-threatened; PS = Protected Species; RHS = Rare Habitat Specialist; VU = Vulnerable. Likelihood of Occurrence (LoO): 2 = High; 3 = Moderate; 4 = Low Sources: ToPS (2007); Leeming (2003); Dippenaar-Schoeman (2002); Mecenero et al. (2013)

Chapter G: Surface water

Information included in this section of this report was obtained from the following sources: • Updated EMPR, 2009; • PGM EMPr, 2011; and

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• Aquatico Scientific (Pty) Ltd. January to March 2018. Glencore – Western Chrome Mines – Waterval Mine. Quarterly Surface Water Quality Report (Annexure G3).

1. Catchment and general hydrology Waterval Mine falls within the Sandspruit Catchment (A22H Quaternary Catchment of the Crocodile (West) Marico Water Management Area (WMA) 3), that is part of the Elands Sub-management area.

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The catchment is illustrated in Figure 26

Figure 26below.

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The only stream in the immediate vicinity of the mine is a small non-perennial tributary to the Hex River, which flows in a north easterly direction between Waterval East and old Waterval sections. The only perennial watercourse in the area is the Hex River. The Hex River (situated approximately 1km and 700m from Waterval Mine West and Waterval Mine East, respectively, flows north-westwards into the Elands River and further downstream into the Crocodile River (sub-drainage region A2). The Crocodile River flows north-westwards into the Marico River and becomes the Limpopo River at their confluence.

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Figure 26: Map depicting the catchment associated with the Waterval Mine

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2. Mean Annual Runoff

Table 41 below indicates the Mean Annual Runoff (“MAR”) particulars of the primary sub-catchment (A22H).

Table 41: Mean Annual Runoff (MAR)

m) area ) ) ment

3 3

-MAR ) ) ) ) m M 2 2 2 2

6 6 Catch Gross area (km Net (km Forest area (km Irig. (km area Evap.zone EMA (mm) RainZone (m MAP MAR(mm) MAP Resp. Net (10 MAR Gross MAR (10 A22H 579 579 - 0.8 3B 1700 A2F 658 24 8 13.7 13.7

3. Flood peaks The peak flow of the affected sub-catchment was determined using the Rational Method, selected to be the most appropriate method for these specific catchment characteristics (refer to Table 42 below).

Table 42: Flood peaks and volumes (Eko Rehab, 2002)

Flood Peaks and Volumes for Waterval Spruit

Run- Peak flow Flood Area Intensity Modification Recurrence Area m2 off Q=CIA/3.6 volume km2 (mm/h) Factor Factor (m3/s) (m3) 1:20 48.6 0.47 0.9 276 2347866

1:50 56.6 0.47 0.95 339 2734346 48310000 48.31 1:100 61.5 0.47 1 388 2971065

RMF 55 0.58 1 428 2657050

The maximum estimated peak flow that can occur in the closed system for a return period of 100 years with a point intensity of 61.5 mm/h is approximately 338 m3/s. The calculated peak flow for the RMF is thus 428 m3/s. The flood peaks for the recurrence intervals of 1:20 and 1:50 years for the Hex River is as follows:

• 1:20 years: 400 m3/s • 1:50 years: 875 m3/s

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4. Surface water use Water from the stream located in the area is primarily used by farmers for stock watering. In certain areas, in-formal settlements use the water for washing and domestic purposes (updated EMPR, 2009).

5. Surface water quality Glencore Alloys: Waterval Mine has a surface water monitoring programme in place. Surface water quality monitoring is conducted on a monthly basis by a contractor. Refer to Annexure G3 for the 2016 Quarter 1 monitoring reports.

The surface water monitoring points either serve the purpose of monitoring process water or the receiving environment.

Surface water quality monitoring localities Table 43 below provides the detail of the surface water monitoring localities at Waterval Mine. Refer also to Figure 27 below.

Table 43: Surface water monitoring locality details

Coordinates Locality Description Latitude Longitude Underground Water Clear Water Dam North XMS01 S-25.6856 E27.2684 East Corner Lot22

Upstream of Mine Spruit at Low Water Bridge XMS02 S-25.6873 E27.2707 at Road

XMS04 Return Water Dam (Waterval East) S-25.6828 E27.2709

XMS06 Pipe Discharging in Veld Near Magazines S-25.6841 E27.274

XMS07 Upstream of Hex River S-25.6836 E27.2816

XMS08 Downstream of Hex River S-25.6766 E27.2779

XMS09 Return Water Dam (Waterval West) S-25.6777 E27.2686

XMS10 Pipe Discharge Point into Stream S-25.6776 E27.2688

XMS11 Erickson Dam in Waterval-West Shaft Area S-25.6796 E27.2619

XMS12 Erickson Dam in Waterval-East Shaft Area S-25.6863 E27.2665

Spruit Upstream of Mine at Kroondal Road XMS13 S-25.6878 E27.2672 Bridge

XMS14 Spruit Downstream of Mine S-25.6838 E27.2757

XMSAD XMS6 Alternative Discharge S-25.6837 E27.2725

Surface water quality monitoring results Table 44 to Table 45 below details the surface water monitoring results for the first quarter of 2018 (January to March 2018), as per the Aquatico Scientific monitoring report (Annexure G3).

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Figure 27: Map showing the surface water monitoring localities (adapted, from Aquatico Scientific, March 2018).

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Table 44: Quality Average Process Water Quality table for Glencore Chrome Waterval Mine

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Table 45: Quality Average Receiving Environment Water Quality Table for Glencore Chrome Waterval Mine

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6. Aquatic Environment Biomonitoring is conducted at Waterval Mine on a bi-annual basis (in April and October). The latest Biomonitoring Survey report titled: “Glencore Western Chrome Chrome Mines – Waterval Biomonitoring of the Hex River catchment;”, dated June 2018, compiled by Clean Stream Biological Services is attached hereto in Annexure G4. A summary of the results is provided below.

6.1 Biomonitoring sites Biomonitoring sites were selected to be easily accessible, comparable and representative of as many habitats in the upstream and downstream environments, as possible. Two biomonitoring sites were selected within the Hex River (receiving water body). One site (X3) was selected to be upstream and another downstream (X4) of the confluence of the stream that may receive impacts from Glencore Waterval (Table 46 and Figure 28).

Table 46: Latitude / longitude of sampling sites for the purpose of biomonitoring

Biomonitoring protocols Coordinates Monitoring Description Frequency Latitude Longitude site Protocol per annum (South) (East)

Hex River, upstream of In-situ water stream draining potential quality, Twice X3 25,6835 27,2812 mining impacts derived *SASS5 from Waterval Mine. **FAII Once

Hex River, downstream of In-situ water stream draining mining quality, Twice X4 25,6765 27,2777 impacts derived from *SASS5 Waterval Mine. **FAII Once

6.2 In-situ water quality measurements Selected water quality variables were measured on-site at the time of biological sampling. The purpose of this limited water quality analysis is to assist in the interpretation of biological results (refer to Aquatico Scientific Water Quality Report for a detailed water quality assessment). As observed during most of the previous surveys, the EC levels decreased, on a spatial scale, from site X3 (122.4 mS/m) to site X4 (84.8 mS/m), which is an indication that mining activities in the catchment between these sites did not result in increased dissolved salts of this section of the Hex River at the time of sampling.

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Figure 28: Map indicating the biomonitoring localities (adapted from Clean Stream Biological Services, June 2018).

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Table 47: In-situ water quality variables measures at the time at the selected biomonitoring sites (Clean Stream Biological Services, June 2018)

Oxygen Dissolved Monitoring EC Water Turbidity pH saturation oxygen Site (mS/m) Temp (°C) (visual) (%) (mg/l) X3 122.4 8.4 72.5 5.6 13.2 Slight

X4 84.8 8.2 69.1 5.3 15.6 Turbid

Figure 29: Electrical conductivity (EC) values recorded at the different monitoring sites (adapted from Clean Stream Biological Services, June 2018).

The pH values measured 8.4 (X3) and 8.2 (X4) during the June 2018 survey and therefore did not exceed the target water quality pH ranges for fish health, which is between 6.5 - 9.0 (DWAF, 1996).

The lower limit of the median guideline for dissolved oxygen levels (> 5 mg/l, as set by Kempster et.al., 1980) was not exceeded at either of the Waterval biomonitoring sites during the June 2018 survey, measuring 5.6 mg/l (site X3) and 5.3 mg/l (site X4) (Table 3; Figure 4). This is an improvement since March 2018 when the lower limit was not reached at the upstream Hex River biomonitoring site (X3 = 4.4 mg/l) (Report GCW-A- 18). The low dissolved oxygen level was probably related to low flow, possibly coupled with organic enrichment. It was clearly not related to Glencore Waterval activities because it was measured at the upstream site, with a slight improvement measured towards the downstream site (X4 = 5.2 mg/l).

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Figure 30: pH values recorded at the different monitoring sites (adapted from Clean Stream Biological Services, June 2018)

Figure 31: Dissolved oxygen levels recorded at the different monitoring sites (adapted from Clean Stream Biological Services, June 2018).

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6.3 Aquatic invertebrate assessment: South African Scoring System 5 The South African Scoring System (Version 5) (“SASS5”) is a site-specific index, which, together with an associated habitat index (biotope suitability index) gives a general perspective of the biotic integrity (based on macro-invertebrates) and the impact of water quality on the biotic integrity of the specific sites (Thirion et.al., 1995; Dickens and Graham, 2001). The biotope suitability index takes into account the suitability of the different sampled biotopes in terms of quality and availability. It thereby firstly assesses whether the total SASS5 scores of two sites are directly comparable by matching the total biotope suitability scores. In the event that the total biotope suitability scores are largely different this would imply that the total SASS5 scores should not be compared, but instead the most comparable SASS biotope scores. The most comparable SASS biotope scores are identified by comparing the various individual biotope suitability scores. In addition to the biotope suitability index, the Integrated Habitat Assessment System, version 2 (“IHAS”) was also applied and included for the purpose of macro-invertebrate specific habitat descriptions.

June 2018 Survey (spatial variation) During the June 2018 survey, both the total SASS5 and ASPT scores increased from site X3 (38 & 3.45) to site X4 (78 & 4.11). The spatial increase appeared to be at least partly habitat related as reflected by spatially increased IHAS scores and the habitat availability & suitability scores. SASS vegetation scores (most comparable biotopes) however confirmed that water quality improvement may also have contributed to the downstream improvement in biotic integrity. This is in contrast with several of the previous surveys, when notable spatial deterioration was observed between these sites. The June 2018 dataset (also the March 2018 dataset) is therefore encouraging and indicates sustained improvement in this reach of the Hex River. It however remains clear that spatial deterioration often occurs between sites X3 and X4 and continued monitoring and temporal analyses remains important to detect any changes in trends. Toxicity analyses of possible impacts arising from the Glencore Chrome Waterval activities showed some potential hazards during the April 2016 and the October 2016 (significant improvement was however observed since 2017) and various previous surveys (see also September 2009 and December 2010 toxicity reports). Although the risks were consistently observed to be only “slight”, the October 2016 dataset revealed higher hazards (up to Class IV – high acute/chronic ecological hazard). It is again noted that continued and regular toxicity analyses of possible Glencore Chrome Waterval effluents/discharges are important to determine its potential risk and possible contribution to observed changes in biotic integrity.

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Table 48: SASS5 and ASPT index scores as well as individual biotope suitability scores at the different monitoring sites (Clean Stream Biological Services, June 2018)

Biotope availability and suitability SASS5-score per biotope SAS (Scores) Monitori S ASPT SAS 41 ng Site Scor SASSSto S SASSG Ston Vegetati GSM Combin 42 e nes Vegetati SM es on ed on X3 38 3.45 26 28 29 3 4 3 10

X4 78 4.11 41 50 28 4 5 5 14

Figure 32: SASS5, ASPT and total biotope suitability scores at the different biomonitoring sites (Clean Stream Biological Services, June 2018).

Long-term trends To determine the change of biotic conditions over the long-term, the ASPT scores for the different surveys completed up to present (October’06 to June’18) were compared. Due to lowered biota diversity over the past few years, it has become relevant to also assess the total SASS5 score trends. This is important as lowered taxa diversity may lead to ASPT scores being less accurate.

Biotic conditions were generally better at site X4 (as compared to site X3) during the first half of the temporal datasets (based on ASPT scores), but generally lower during the second half. The

41 ASPT = Average Score Per Taxon 42 Gravel, sand and mud

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ASPT polynomial trend (due to the long-term database now amassed, it has become relevant to revert from linear to polynomial trend analyses) is however showing deterioration at both sites, which now appears to be less pronounced at the downstream site. Biotic integrity, however, still appears to be lower at the downstream site, in general. This trend was confirmed by assessment of the total SASS5 scores, despite habitat conditions being generally better at the downstream site (X4). This could very well be an indication that potential impacts originating between sites X3 and X4 are having an adverse impact on the Hex River and/or are increasing over the long-term. As mentioned in this and previous reports, the spatial results (based on numerous previous surveys) also indicate on potential source/s of pollution that caused reduced biotic integrity between sites X3 and X4. For this reason, it is again recommended to continue with the toxicity analyses programme, on a regular basis, on all possible effluents originating from the mine. Regular testing will assist to exclude (or verify) these as impacts and hence long-term hazards to biota of the receiving water body.

6.4 Fish Assemblage Integrity Index (FAII) Fish species expected to occur at the sites under investigation is based on information from Skelton (1993) and Le Roux & Steyn (1968) as well as experience from previous surveys (this biomonitoring programme and various other mining related biomonitoring programmes; also research and Department of Water Affairs reserve determination studies). The expected species list is also updated with the knowledge gained as a result of continuation of this biomonitoring programme. This expected list may vary from previous surveys due to changes in habitat diversity at a site which is the template that determines, together with water quality, the fish community at any given site. The composition of the fish community and the relative FAII (Fish Assemblage Integrity Index) are based on the last two fish surveys. This is done to increase the accuracy of the results and to avoid the co-incidental miss-sampling of a particular species at a particular site. It is furthermore acceptable to use this approach as fish generally take longer to react (as compared to macro- invertebrates) to stressors and is therefore more applicable as an indicator over a period of time (as compared to a snapshot at any given time).

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Figure 33: Temporal variation of ASPT scores at different sites (Clean Stream Biological Services, June 20182015).

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2017/2018 period (Spatial variation) Six naturally occurring (native) fish species (Barbus paludinosus; Barbus unitaeniatus; Clarias gariepinus; Labeobarbus marequensis; Pseudocrenilabrus philander and Tilapia sparrmanii) were sampled at the two respective sites in the Hex River during the 2017/2018 period. A single exotic/invader species was sampled (Micropterus salmoides - Largemouth bass). This is an aggressive predatory species feeding on native macro-invertebrates and other fish species, often leading to serious reduction of biotic integrity. The observed fish species diversity was lower than can be expected under natural conditions at both of the sampling sites, indicating lowered biotic integrity. The reasons for lowered species diversity are outlined in the paragraphs below, which deal with the Fish Assemblage Integrity Index (“FAII”) results.

Table 49: Naturally occurring indigenous fish species expected and observed during 2017/2018 (Clean Stream Biological Services, June 2018)

Sites Native / Species Common name X3 X4 Exotic Exp. Obs. Exp. Obs.

Amphillius uranoscopus Stargazer Native

Barbus paludinosus Straightfin barb Native

Barbus trimaculatus Threespot barb Native

Barbus unitaeniatus Longbeard barb Native

Chiloglanis pretoriae Shortspine Native

Sharptooth Clarias gariepinus Native catfish

Labeo molybdinus Leaden labeo Native

Labeobarbus Largescale Native marequensis yellowfish

Mesobola brevianalis River sardine Native

Largemouth Micropterus salmoides Exotic bass

Oreochromis Mazambique Native mossambicus tilapia

Pseudocrenilabrus Southern Native philander mouthbrooder

Tilapia sparrmanii Banded tilapia Native

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Table 50: Relative FAII scores calculated at different sampling sites (Clean Stream Biological Services, June 2018)

Locality Relative FAII (%) X3 18

X4 37

Table 51: Relative tolerance of each expected fish species towards changes in the environment (Clean Stream Biological Services, June 2018)43

Common Species name Trophic specialisation Habitat specialisation Flow dependence Requirement for high water quality Total intolerance ratings

Amphillius Stargazer 4.7 4.9 4.8 4.8 4.8 uranoscopus

Chiloglanis Shortspine 4.4 4.8 4.8 4.5 4.6 pretoriae

Labeo Leaden labeo 3.3 3 3.3 3 3.2 molybdinus

Labeobarbus Largescale 2.4 2.8 3.2 2.1 2.6 marequensis yellowfish

Mesobola River sardine 3.1 2.2 1.1 2.8 2.3 brevianalis

Barbus Threespot barb 3.1 1.4 2.7 1.8 2.2 trimaculatus

Barbus Straightfin barb 1.6 1.4 2.3 1.8 1.8 paludinosus

Barbus Longbeard 1.1 1.3 2.3 2.2 1.7 unitaeniatus barb

Oreochromis Mazambique 1.2 1.9 0.9 1.3 1.3 mossambicus tilapia

Pseudocrenila Southern 1.3 1.4 1.0 1.4 1.3 brus philander mouthbrooder

Tilapia Banded tilapia 1.6 1.4 0.9 1.4 1.3 sparrmanii

43 Intolerance ratings are colour shaded on a scale from green to red, with green being least intolerant and red being most intolerant species are sorted in descending order from most intolerant (total intolerance rating) to least intolerant 1 – 2 = Tolerant; 2 – 3 = Moderate tolerant; 3 – 4 = Moderately intolerant; 4 – 5 = Intolerant

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Common Species name Trophic specialisation Habitat specialisation Flow dependence Requirement for high water quality Total intolerance ratings

Clarias Sharptooth 1.0 1.2 1.7 1.0 1.2 gariepinus catfish

Long-term trends (Temporal variation) The temporal trend is one of slight deterioration at both sites (X4 and X3), indicating deterioration over time at both sites. The biotic integrity is however consistently higher at the downstream site (X4) over the study period. This is indicative that the impacts on the fish assemblage originates form the upstream (non-Glencore) impacts and that impacts between these two sites have generally not led to a further decrease in biotic integrity. This is in contrast with the macro- invertebrate temporal trend, which is currently indicative of a generally lower biotic integrity at the downstream site. It should be kept in mind that fish and macro-invertebrates tend to react at different rates and types of environmental stressors. Fish assemblages generally take longer to respond while macro-invertebrates, as an indicator react more rapidly. This illustrates the value of using a suite of monitoring indicators to assess biotic response (SASS5 and FAII) in response to environmental stressors (water quality and toxicity testing).

Chapter H: Sensitive Landscapes (including Wetlands)

Ecological sensitivity of a system is based on the determination of the sensitivity of the driving force of the ecosystem to change, and in particular human-induced change (Cowling et al., 1994). Ecological sensitive areas include wetlands, rocky ridges etc.

The information contained in this section has been sourced from the following documents: • Natural Scientific Services cc. July 2015. Terrestrial Biodiversity Assessment. Glencore Alloys Waterval, Rustenburg (attached in Annexure G2) (hereafter referred to as NSS, July 2015); and • Natural Scientific Services cc. April 2015. Glencore Alloys. Land Function Analysis – Waterval (attached in Annexure G2) (hereafter referred to as NSS, April 2015) (attached in Annexure G2).

1. National Freshwater Ecosystem Priority Areas (“NFEPA”)

The NFEPA project has been a multi-partner project between the CSIR, South African National Biodiversity Institute (“SANBI”), Water Research Commission (“WRC”), DWS, Department of Environmental Affairs (“DEA”), Worldwide Fund for Nature (“WWF”), South African Institute of Aquatic Biodiversity (“SAIAB”) and South African National Parks (SANParks). According to Driver et al. (2011), the NFEPA project provides strategic spatial priorities for conserving freshwater ecosystems and supporting sustainable use of water resources in South Africa.

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Freshwater Ecosystem Priority Areas (“FEPAs”) were identified using a range of criteria dealing with the maintenance of key ecological processes and the conservation of ecosystem types and species associated with rivers, wetlands and estuaries. The NFEPA guidelines state that FEPAs should be regarded as ecologically important, and as generally sensitive to changes in water quality and quantity, owing to their role in protecting freshwater ecosystems and supporting sustainable use of water resources. FEPAs that are in a good condition should remain so, and FEPAs that are not in a good condition should be rehabilitated to their best attainable ecological condition. Land- use practices or activities that will lead to deterioration in the current condition of a FEPA as well as land-use practices or activities that will make rehabilitation of a FEPA difficult or impossible are considered unacceptable (Driver et al. 2011).

For the study area, the NFEPA project does not recognise the Hex River or any wetlands in the vicinity of Waterval Mine as FEPA’s. Only the Waterkloofspruit 5km upstream of the mine, is classified as a NFEPA river. Refer to Figure 34 below.

2. Ecological state, importance and sensitivity of the Hex River The Hex River is situated approximately 1km and 700m from Waterval Mine West and Waterval Mine East, respectively. A summary of the Present Ecological State (“PES”), Ecological Importance (“EI”), Ecological Sensitivity (“ES”) and impacts on the Hex River is presented in Table 52 (DWS, 2014). According to DWS (2014) the PES of the Hex River is seriously modified (E category). According to the RHP (2005), the instream habitat integrity is influenced by channel modifications caused by diversions for mining as well as water abstractions for irrigation purposes. The riparian habitat has some vegetation clearing for sand winning activities and some pockets of Sesbania sp. and Blue gums, both of which are very localised. The water quality has between low and intermediate levels of nutrients but is largely free of significant organic pollution. However, high conductivity and salinity levels were recorded due to mining discharges and seepages. The cumulative impacts of reduced water quality, flow and habitat modifications have large impacts on the macro-invertebrate diversity and abundance. The sensitive fish species are lost due to flow modifications and instream obstructions and the water quality problems originating from the mines and agricultural activities also created stress conditions for the fish species (RHP, 2005).

The Hex River, adjacent to Waterval Mine, is a Lower Foothill and Critically Endangered (Driver & Nel, 2012; Driver et al. 2011). The EI of the Hex River is moderate and includes three wetlands and seven riparian habitat types, with 14 different types of vegetation cover, three protected and five endemic species in this Sub-Quaternary (SQ). The size of stream, morphology and geomorphic habitat units determine the ES. The Hex River has a moderate sensitivity to modified flow conditions and water level changes (DWS, 2014).

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Figure 34: Status of wetlands and rivers in the area according to the NFEPA

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Table 52: Summary of the Presence Ecological State (“PES”), Ecological Importance (“EI”) and Ecological Sensitivity (“EIS”) and impacts on the Hex River (DWS, 2014)

Quaternary Water PES EI ES Impacts Catchment Resource SERIOUS: Mining and mining runoff/effluent, water abstraction and inundation. LARGELY: Bed and channel disturbance, small (farm) dams, roads, overgrazing and trampling, runoff from urban areas and sedimentation. A22H Hex River E Moderate Moderate MODERATE: Algal growth, low water crossings, large dams, erosion alien aquatic macrophytes, alien vegetation and vegetation removal. SMALL: Agricultural fields, recreation and grazing (land use).

Chapter I: Groundwater

Information contained in this section was obtained from the following documents: • Updated EMPR, dated July 2009; • The report titled Glencore- Western Chrome Mines; Quarterly groundwater quality report January to March 2018, and compiled by Aquatico Scientific (attached in Annexure G5); and • The report titled Xstrata Alloys South Africa (Pty) Ltd: Report on Geohydrological Investigation as part of the EMPR Amendment for the proposed Waterval Chrome Opencast Mine and tailings facility, dated May 2009 and compiled by Clean Stream Groundwater Services (refer to Annexure G9).

1. Geohydrology The geohydrology of the site associated with Waterval Mine is that of an intergranular and fractured aquifer type, namely the Rustenburg layered suite to the north of the Magaliesberg. Groundwater occurrence is associated mainly with deeply weathered and fractured mafic rocks. More than 80% of the boreholes yield less than 2l/s. This is a result of the low permeability (±10-6 cm/s) of the clay rich soils (i.e. black turf soils) that reduce recharge to underlying aquifers. The depth to groundwater rest level typically occurs between 5m and 40m below surface. The mean water quality for this aquifer type shows that salinity can be a problem in these aquifers (average EC values of 105mS/m).

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2. Aquifer classification and description Recharge There is groundwater recharge of 992.77 Ml/year, calculated as a recharge of rainfall at 3% per year to the groundwater system. Permeability of the aquifer The area is underlain by geological formations which have a low permeability. Groundwater therefore moves slowly. The area is very flat (low gradient) which further causes the groundwater to move more slowly. 3. Groundwater levels Waterval West: Overall deeper groundwater levels were measured in monitoring borehole XMB22 with an average of 15 meters below surface (mbs) respectively. The deeper static level in this borehole is considered to be a direct result of limited dewatering effects since the boreholes are situated within close proximity of the Waterval West decline shaft. An average of ±6 mbs was measured in monitoring borehole XMB30 (refer to Figure 35

below).

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Waterval East: Groundwater levels were only measured in XMB09 and XMB27. Average groundwater levels vary between ± 4 and 9 meters below surface (refer to Figure 35

below).

Figure 35: Groundwater level depth below surface for boreholes

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4. Presence of boreholes and springs As per the updated EMPR, dated 2009, a total of 27 boreholes were identified in the hydrocensus that was conducted for the mine. The area is densely occupied with production boreholes. The reason therefore is due to the small size of plots and the intensive agricultural activities. The 27 identified boreholes thus represent a small quantity of existing boreholes in the area.

No springs were identified during the field visit (hydrocensus survey conducted).

5. Groundwater quality Groundwater quality information is available for 6 boreholes monitored during the first quarter of 2018 evaluation period and their positions are indicated in Figure 36.

Figure 36

Six new monitoring boreholes were drilled in the Waterval West Shaft area in 2009. Three of the new and already existing boreholes (XMB18, 22 and 28) are situated within the shaft area among the offices and workshops, none of these boreholes can be classified directly as source monitoring boreholes. Borehole XMB18 and borehole XMB22 could however be affected to some extent by some leachate formation in the larger shaft area.

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6. Groundwater use Groundwater in the area surrounding the mine is mainly used for domestic supply, watering of gardens and livestock. Groundwater is the sole source of water for many of the surrounding households on farms.

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Figure 36: Positions of monitoring boreholes in the Waterval mining area

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Table 53: Quarterly Groundwater Water Quality Table for Glencore Chrome Waterval Mine.

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Chapter J: Air Quality

Air quality in the Rustenburg area is generally poor (Tailings dam EMP, 2011), a problem which is intensified by the local topography and climatic conditions. Major contributors to air pollution in the area include mine tailings, scheduled processes, domestic fuel burning, transportation, landfills, smaller industrial sources, agriculture and other sources (Rustenburg Local Municipality, 2007).

1. Positioning of the fallout dust monitors Dust monitoring points were established to be sufficient in number to establish the contribution of the mine to dust fall in residential and non-residential areas in the vicinity of the premises, to monitor identified or likely sensitive receptor locations, and to establish the baseline dust fall for the district. The following aspects were taken in consideration:

• The prevailing winds of that specific area – light to moderate and from the north-east direction in summer and from the north-east to north-west direction in winter; • The windy season – August – October; • The locality of the site; • The size of the site – ha; and • Areas where the most dust is visible.

2. Acceptable dust-fall rates A standard for the acceptable dust fall rate for residential and non-residential areas is set out in the National Dust Control Regulations under the National Environmental Management: Air Quality Act 39 of 2004.

Table 54: Acceptable dust fall rates

Dust fall Rate (D) Permitted frequency of Restriction Areas (mg/m2 /day, exceeding dust fall rate 30-day average) Two within a year, not sequential Residential Area D < 600 months.

Two within a year, not sequential Non-Residential Area 600 < D < 1200 months.

3. Airborne particulate sampling results

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Table 55 below provides the sampling results for both the Waterval East and Waterval West sections. Refer to Figure 37

Figure 37for a map showing the localities of the dust monitoring positions.

Table 55: Airborne particulate sampling results

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Figure 37: Map showing the dust fall monitoring localities at Waterval Mine

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Chapter K: Noise

An environmental noise monitoring survey was conducted for the Waterval West Mine in July 2012 by Ashreq Environmental and Occupational Hygiene Consultants. The resultant report titled Report on Environmental Noise Monitoring Waterval West Mine, conducted by Barry de Beer from Ashreq, and dated 16 July 2012 is attached in Annexure G7.

The environmental noise survey was conducted according to the following legal requirements and associated standards: SANS 10103:2003, the Code of Practice for The Measurement and Rating of Environmental Noise with Respect to Land Use, Health, Annoyance and Speech Communication recommends maximum noise levels for residential and non-residential areas as reflected in Table 56 below.

Table 56: Acceptable rating levels for noise in districts (Ashreg, 2012)

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Figure 38: Noise monitoring points on site location at Waterval West Mine

1. Results Table 57 below provides the day time environmental noise results (winter) and Table 58 provides the night time environmental noise results.

Table 57: Day time environmental noise results (winter) (Ashreq, 2012)

Point Sampling GPS Sample A Sample B Sample C Average point coordinates (LAleq) (LAleq) (LAleq) (dBa) 25°40'47.22"S Point 1 54.5 54.6 55.1 54.7 27°15'33.64"E

25°40'55.24"S Point 2 52.8 53.2 53.5 53.2 27°15'52.72"E

25°40'58.64"S Point 3 45.9 45.8 46.2 46.0 27°15'34.37"E

Overall Day Time Average LAleq for Site 51 dBA

Table 58: Night time environmental noise results (winter) (Ashreq, 2012)

Sampling Sample E Point Average GPS coordinates Sample D (LAleq) point (LAleq) (LAleq)

25°40'47.22"S Point 1 48.9 50.2 49.6 27°15'33.64"E

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Sampling Sample E Point Average GPS coordinates Sample D (LAleq) point (LAleq) (LAleq)

25°40'55.24"S Point 2 50.8 51.5 51.2 27°15'52.72"E

25°40'58.64"S Point 3 46.1 45.8 46.0 27°15'34.37"E

Overall Night Time Average LAleq for Site 49 dBA

The premise around Point no. 1-3 may be classed as an industrial district in accordance with SANS 10103:2003 Table 2. As a result, a 70dBA limit and 60dBA limit apply for the control of noise during the day and night-time respectively, in this area.

The main sources of noise may be attributed to the processing activities at the plant (including a surface fan) and intermittent vehicles passing on the main roads.

The results of day and night-time levels measured during this survey were as follows: • Day Time LAIeq: 51dBA (-19). • Night-Time LAIeq: 49dBA (-11).

It may therefore be concluded that both the day and night time levels were well below the noise control limits as set out in SANS 10103:2003. Both levels were similar to that of levels obtained in the summer (Refer to Report 11-1060-05-02).

Chapter L: Visual

Rustenburg is located approximately 3km east and Kroondal 5km west of the Waterval Mine. The shaft, plant structures and some of the dumps are visible from the main road (N4). There is however a strand of trees along the road, which lessens the impact marginally. The Waterval West section is not situated directly next to the road and is not as visible (Updated EMP, 2009).

Chapter M: Protected areas and conservation planning

1. National Terrestrial Priority Areas (NPAs) The National Terrestrial Priority Areas (NPA) assessment was based on integrating data on species, habitats and ecological processes to identify areas of greatest biodiversity significance. This resulted in the identification of nine spatial priority areas for terrestrial biodiversity (Driver et al. 2004). These priority areas represent areas with high concentrations of biodiversity features and/or areas where there are few options for meeting biodiversity targets (Rouget et al. 2004). Waterval Mine and its associated infrastructure is situated in the Bushveld-Bankenveld Priority Area (Error! Reference source not found.), which faces the highest pressure of the nine identified national Priority Areas (NBI, 2004).

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2. NEM:BA National Threatened Terrestrial Ecosystems A list of Threatened Ecosystems within each Priority Area was gazetted on 9 December 2011 under the National Environmental Management: Biodiversity Act (“NEM: BA”) (Act 10 of 2004). The Threatened Ecosystems occupy 9.5% of South Africa, and were selected according to six criteria which included: (1) irreversible habitat loss; (2) ecosystem degradation; (3) rate of habitat loss; (4) limited habitat extent and imminent threat; (5) threatened plant species associations, and (6) threatened animal species associations. Waterval Mine is situated in the Endangered Marikana Thornveld Ecosystem (refer Figure 39 below).

Figure 39: Waterval Mine in relation to national terrestrial Priority Areas and Threatened Ecosystems (NSS, July 2015)

3. Mining and Biodiversity Guideline The mining industry plays a vital role in South Africa’s growth and development. But if mining is not strategically planned and carefully implemented, it has significant negative impacts on biodiversity and ecosystems, in particular, catchments, rivers and wetlands that support water-related services. The Mining and Biodiversity Guideline: Mainstreaming biodiversity into the mining sector (DEA et al. 2013), interprets the best available Biodiversity knowledge and science in terms of the implications and risks for mining in a practical and user-friendly guideline for integrating relevant biodiversity information into decision making. The development of this guideline was initiated by the Chamber of Mines and the SAMBF, in partnership with the DEA, the Department of Mineral Resources (“DMR”), and with technical input and co-ordination by the SANBI Grasslands Programme.

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The northern half of Waterval is classified as having a High biodiversity importance and risk of mining (Figure 40). The Mining and Biodiversity Guideline stipulates the following in areas of High importance for Biodiversity:

“These areas are important for conserving biodiversity, for supporting or buffering other biodiversity priority areas, and for maintaining important ecosystem services for particular communities or the country as a whole. An EIA should include an assessment of optimum, sustainable land use for a particular area and will determine the significance of the impact on biodiversity. Mining options may be limited in these areas, and limitations for mining projects are possible. Authorisations may set limits and specify biodiversity offsets that would be written into licence agreements and/or authorisations.”

Mining Biodiversity Guideline areas of High Biodiversity Importance include: • Buffers around World Heritage sites and other protected areas; • High water yield areas; and • Other identified priorities from provincial spatial biodiversity plans

Figure 40: Mining and Biodiversity Guideline Atlas data for the region (NSS, July 2015)

4. North West Conservation Plan The North West Conservation Plan (“NW: C Plan”) is based on a provincial Biodiversity Assessment (Desmet et al. 2009), and provides important guidance for biodiversity conservation

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and sustainable development in the province. Among other things, the C Plan will be used to inform the development of provincial biodiversity Sector Plans, bioregional plans, Spatial Development Frameworks (“SDFs”), Environmental Management Frameworks (“EMFs”), Strategic Environmental Assessments (“SEAs”) and the Environmental Impact Assessment (“EIA”) process in the province.

According to the NW: C Plan, Waterval Mine (

Figure 41Figure 41) and its associated infrastructure is situated in a Category 2 Critical Biodiversity Area (“CBA 2”). CBAs are areas of the landscape that need to be maintained in a natural or near- natural state to ensure the continued existence and functioning of species and ecosystems, and the delivery of ecosystem services. If these areas are not maintained in a natural or near-natural state, then biodiversity conservation targets cannot be met.

Maintaining an area in a natural state can include a variety of biodiversity-compatible land uses and resource uses. In contrast to Protected Areas which include “natural” landscapes, Category 2 CBAs include “near-natural” landscapes where:

• Ecosystems and species remain largely intact and undisturbed; • Local biodiversity has intermediate irreplaceability or some flexibility in terms of area required to meet biodiversity targets; • The limit of “acceptable change” is being approached, but has not yet been surpassed; and • 60-90% of original vegetation / resources should remain intact following development.

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Figure 41: North West Boundary Conservation Plan (NSS, July 2015)

5. Municipal area challenges and objectives According to the Bojanala District Municipality Integrated Development Plan (“IDP”), 2012-17, large parts of the District Municipality are characterised by high levels of biodiversity as determined in the North West Biodiversity database. These include the areas along the Magaliesberg stretching from the southern parts of Madibeng Local Municipality in the east to Rustenburg and further north westwards up to the north western parts of the Rustenburg Local Municipality. It also includes areas in the central parts of the Kgetlengrivier local municipality, as well as large parts of the Moses Kotane Local Municipality west of the Pilanesberg National Park.

In response to the importance of the Bojanala Platinum District as far as biodiversity is concerned, the North West Parks and Tourism board is also considering the extension of a number of existing nature reserves and conservation areas. The most notable of these include the existing Heritage Park development which is envisaged to link the Game Reserve in the west with the Pilanesberg National Park in the east.

Other proposed initiatives include the possible expansion of the Vaalkopdam nature reserve to link up with the Pilanesberg National Park as well as the expansion of the Borakalalo nature reserve to link up with Vaalkop. This will create a conservation corridor stretching from the Borakalalo nature reserve in the east through Vaalkopdam, Pilanesberg up to the Madikwe Game Reserve in the west.

Other areas of conservation include the Magaliesberg area as well as some of the Norite hills not influenced by mining and quarrying activities.

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An aspect of specific concern within the district is that as much as 10% of the land area is classified as degraded.

Figure 42: Percentage of total municipal area degraded (Bojanala DM IDP, 2012-17)

Key issues/challenges • Protection of natural vegetation and ecosystems and ecologically sensitive zones; • Protection and development of cultural heritage sites; • Protection of unique geological features such as Pilanesberg and the Magaliesberg Mountain Range; • Protection of Red Data fauna and flora species that occur in the district; and • The need for improved air and water quality in the district.

Objectives In terms of the District Environmental Management Policy, council commits itself to continually improve its environmental performance, beyond the requirements of current legislation or regulation. In this respect, it will specifically endeavour to: • Encourage the reduced consumption of water, energy and other natural resources; • Pursue progressive waste reduction, reuse and recycling initiatives to reduce the amount of waste generated from Council activities and within the District; • Ensure and encourage the provision of effective waste management services to all the communities within the District area of jurisdiction; • Encourage the prevention and minimisation of environmental pollution to air, water and land within the District to maintain and improve the health and welfare of the public; • Support the rehabilitation of polluted water and land areas within the District; • Support sustainable agricultural practices within the District; • Safeguard natural habitats and species and preserve the nature and character of the rural areas as well as preserve cultural heritage;

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• Balance the need to enhance the built environment with measures which reduce the environmental impact of development; • Promote sustainable public transport; and • Provide environmental education and training within the Council and its staff on the implementation of the Policy and promote environmental education within the whole community.

Chapter N: Site of Heritage Importance

The following information is extracted from the report A Phase I Heritage Impact Assessment (“HIA”) study for the Waterval Chrome Mine on the farm Waterval 306 JQ near Rustenburg in the Central Bankeveld of the North-West Province dated 2010 and compiled by Dr Julius CC Pistorius. Refer also to Annexure G8_2

1. Methodology This Phase I HIA study was conducted by means of the following activities, namely: • Archaeological data bases kept at institutions such as the African Window and the South African Heritage Resources Authority (“SAHRA”) (Cape Town [national] and Mafekeng [provincial]) were consulted to establish whether any heritage resources occur in the Project Area; • The Project Area was surveyed with a vehicle while sensitive areas were surveyed on foot; • The 1: 50 000 and 1: 250 000 maps were also used to study the Project Area; and • Areas to the north and to the south of the Project Area have been surveyed by the author in the past. Numerous sites have been recorded and at least twenty sites have been excavated.

2. Findings The Phase I HIA study for the Waterval Chrome Mine revealed none of the types and ranges of heritage resources as outlined in Section 3 of the National Heritage Resources Act (No 25 of 1999).

Chapter O: Regional socio-economic structures

Waterval Mine falls within the jurisdiction of the Bojanala District Municipality and the Rustenburg Local Municipality. The Information contained in this section has thus been sourced from the following documents:

• Rustenburg Local Municipality. Integrated Development Plan Review 2014 – 2015. Approved per item 122 of 30 May 2014 (hereafter referred to as ‘Rustenburg LM IDP, 2014-2015’); • Final Version: Bojanala Platinum District Municipality IDP. 2012/17 (hereafter referred to as ‘Bojanala DM IDP, 2012/17’); and • Social and Labour Plan for Glencore Operations South Africa (Pty) Ltd. Waterval Mine. 2014 - 2018 (Annexure E).

Rustenburg Local Municipality is one of five municipalities within the Bojanala District Municipality in the North West Province and is divided into 38 wards. The significant growth in Rustenburg is largely attributed to the impact of the world’s four largest mines in the immediate vicinity of the town, namely, Anglo Platinum, Impala Platinum, Xstrata (Glencore) and Lonmin. Approximately

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97% of the total platinum production occurs in Rustenburg, with the mining sector providing around 50% of all formal employment.

1. Population The total population for the Rustenburg Local Municipality is 549 575 people, comprising of 54% males and 46% females. This phenomenon could be attributed to labour migration to Rustenburg due to more males migrating to the city to obtain job opportunities. Table 59 illustrates the distribution of the various racial groups in the Rustenburg Local Municipality for 2010 and 2011. Between 2010 and 2011, the overall population growth was 86.47% with Africans being the majority population group at 52.23%. The Asians were the highest in % growth by 71% followed by the Coloured at 58%. The White race had decreased by 11%.

Table 59: Population distribution by race

Population group 2010 2011 % Growth / decrease African 410 762 486 411 52.23

White 58 623 51 839 -11

Coloured 2 824 4 862 58

Asian 3 022 4 214 71

Others 2 249 100

Total 475 232 549 575 86.47

Table 60 below shows the ethnic group, gender and age distribution.

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Table 60: Age in completed years by population group and gender (Rustenburg LM IDP, 2014-2015) as per Census, 2011 ETHNIC ETHNIC GROUPS Black African Coloured Indian or Asian White Other Total AGE Male Female Total Male Female Total Male Female Total Male Female Total Male Female Total Male Female Total

0 - 4 26211 25543 51754 268 270 538 201 182 383 2062 2001 4063 119 102 221 28861 28098 56959

5 - 9 18136 17830 35966 196 215 412 179 156 336 1778 1656 3433 47 54 101 20335 19911 40247

10 - 14 15836 15415 31251 185 165 350 136 147 283 1706 1613 3318 28 25 53 17891 17364 35256

15 - 19 17973 17461 35434 190 171 362 131 131 262 1892 1742 3634 49 38 87 20234 19543 39777

20 - 24 28927 24614 53541 277 250 527 245 150 394 2008 1983 3991 240 110 350 31696 27107 58803

25 - 29 34514 26292 60806 290 236 526 341 172 513 2221 2253 4473 299 128 427 37664 29081 66745

30 - 34 31373 20857 52230 249 254 503 245 159 405 2064 1925 3989 232 97 329 34163 23293 57455

35 - 39 24477 16870 41347 197 175 372 215 121 336 2011 2007 4018 138 73 211 27039 19246 46284

40 - 44 19851 14156 34007 187 145 332 151 125 276 2047 2090 4138 104 66 170 22340 16582 38923

45 - 49 18878 11456 30334 164 137 301 128 97 224 2155 1885 4040 77 22 99 21401 13598 34999

50 - 54 14225 8515 22740 115 110 225 93 82 175 1973 1755 3727 60 26 85 16465 10488 26953

55 - 59 8981 5706 14687 84 74 158 94 80 175 1466 1395 2862 46 19 65 10672 7274 17946

60 - 64 4374 3993 8367 43 60 103 78 84 162 1011 1060 2070 10 5 15 5517 5202 10718

65 - 69 2324 2774 5098 25 37 63 56 74 130 727 852 1579 9 8 17 3141 3746 6887

70 - 74 1397 2095 3492 14 24 38 40 46 86 485 644 1129 4 5 9 1941 2814 4755

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ETHNIC ETHNIC GROUPS Black African Coloured Indian or Asian White Other Total

75 - 79 951 1473 2424 7 16 23 17 24 41 276 428 704 1 2 4 1252 1944 3196

80 - 84 500 1004 1504 7 5 12 8 13 21 164 263 427 1 - 1 680 1285 1965

85 + 423 1006 1429 5 12 17 4 8 12 67 177 244 5 - 5 503 1204 1707

250 236 146 Total 269351 217060 486411 2356 4862 1851 4214 26113 25729 51839 780 2249 301795 247780 549575 3 2 9

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2. Education Table 61: The highest level of education by race (Rustenburg LM IDP, 2014-2015) illustrates the level of education between the various racial groups. It is interesting to take note that overall the level of education has increased, with less individuals that have no schooling to Grade 6. Table 62 shows the highest level of education by gender.

Table 61: The highest level of education by race (Rustenburg LM IDP, 2014-2015)

Africans Whites Asian Level of Education 2010 2010 2010 No schooling 18 853 264 20

Grade 0-2 4 394 34 10

Grade 3-6 36 405 340 130

Grade 7-9 77 160 4 244 312

Grade 10-11 71 998 9 602 426

Certificate / diploma without matric 1 911 603 12

Matric only 76 163 20 786 857

Matric & certificate / diploma 14 884 5 310 395

Matric & Bachelor’s degree 2 613 2 491 132

Matric & Postgrad degree 873 1 200 89

Total 305 254 44 874 2 383

Table 62: Highest level of education by gender (Rustenburg LM IDP, 2014-2015)

Highest level of education by Gender Male Female Total

No schooling 11679 9063 20742

Some Primary 38952 26444 65396

Completed Primary 15820 12329 28149

Some Secondary 60202 45357 105559

Matric 60643 51780 112423

Higher 14515 15658 30173

Educational institution Pre-school including day care; crèche; Grade R and Pre-Grade R in an 1539 ECD centre

Ordinary school including Grade R learners who attend a formal school; 94883 Grade 1-12 learners & learners in special class

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Highest level of education by Gender Special school 933

Further Education and Training College FET 2935

Other College 957

Higher Educational Institution University/University of Technology 1636

Adult Basic Education and Training Centre ABET Centre 210

Literacy classes e.g. Kha Ri Gude; SANLI 5

Home based education/ home schooling 574

3. Employment profile Illustrated below is Figure 43,

Figure 43 which indicates that there has been a steady increase in the labour force participation rate between 1996 and 2010.

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Figure 43: Economically active population, 1996 to 2010 (Rustenburg LM IDP, 2014-2015)

Figure 44: Employment statistics per gender (Rustenburg LM IDP, 2014-2015)

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Figure 45Figure 45 provides the formal employment by the Standards Industrial Classification (SIC) sectors. It is clear that half of the people are employed in the mining sector (98 956 individuals), followed by trade (28 075) and community services (15 190). Apart from the mining sector, the Rustenburg Local Municipality is quite diversified in terms of the other sectors found in the area.

Figure 45: Employment by sectors (Rustenburg LM IDP, 2014-2015)

4. Basic services Housing The census statistics stated that the proportion of households living in formal houses on separate stands in proportional terms declined somewhat from 47.4% in 2001 to 42% in 2007. This does not imply that the actual number of households residing in formal structures on separate stands have declined, the actual number increased from 55 146 in 2001 to 61 477 in 2007. It does however indicate that other categories have increased at a faster rate than formal housing in formal settlements, hence the resulting proportional decrease.

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A further notable feature is the large proportional increase in the number of households residing in informal structures in backyards that increased from 13.4% in 2001 to 21% in 2007. According to Stats SA data, the total number of households residing in informal structures in backyards has doubled between 2001 and 2007 (from 15 540 to 30 685 households). A positive feature is the decrease in the number of households residing in informal structures, that declined from 30 094 in 2001 to 23 922 in 2007. This also represents a proportional decrease from 25.9% in 2001 to 16.3% in 2007.

Water Rustenburg Local Municipality as the Water Services Authority provides services in all 38 wards and shared services with the Royal Bafokeng Administration in some of the wards. The municipality receives water from Rand Water and Magalies Water as well as the Rustenburg Water Services Trust. Services provided include provision of new water and sewer services, operation and maintenance thereof. The unit is responsible for the operation of 27 potable water reservoirs that service an area with 16 pump stations as well as Savanna Falls, Marikana and Freedom Park Sewer Pump stations; three borehole water scheme systems in Rankelenyane, Molote City and Mathopestad and treated effluent system for irrigation in the Central Business District. Electricity The Unit Electrical Engineering Services is one of seven interdependent and interacting units that comprise the Directorate of Infrastructure Development and Management of the Rustenburg Local Municipality. The Unit Electrical Engineering Services is operating as the organ of the Rustenburg Local Municipality and of the Directorate of Infrastructure Development and Management for the supply and distribution of electricity in the demarcated area. The client base of the Rustenburg Local Municipality is provided in Table 63 below.

Table 63: Client-base of the Rustenburg Local Municipality (Rustenburg LM IDP, 2014-2015)

CONSUMER QUANTITY Chrome furnaces 2

Residential 1 37 535

Residential 2-4 10 468

Government 9

Industrial 106

Commercial 1725

Mines 8

Agricultural 2063

Pre-paid 43 978

Kroondal substation (Marble Lime)

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Kroondal sub-station is at present supplying the bulk of the rural clients in the area to the South West of the City of Rustenburg. The bulk of the chrome mines and ancillary plants are also fed from this sub-station. As the installed safe transformer capacity of the substation is already exceeded, some of the load was transferred to Industries sub-station. Once the newly constructed Waterkoof sub-station is completed, sufficient load will be transferred from Kroondal substation to Waterkloof sub-station in order to ensure that Kroondal sub-station operates at safe capacity levels. Provision for the installation of Power Factor Correction equipment at Kroondal sub-station will be made in future budgets. Waterkoof substation The RLM established a new sub-station on the Eastern side of Rustenburg in order to meet the constant growth in electricity demand. The sub-station is designed to make provision for another 2 x 40 MVA transformers. These transformers will only be procured and installed once the load requires the installation thereof. Furthermore, the Waterkloof sub-station will also be linked up with the 33 KV backbones of existing sub-stations which will enable the Unit: Electrical Engineering Services to transferred load between Industries sub-station and Waterkloof sub-station. Once the Waterkloof sub-station is fully equipped, it will be able to supply in the expected load growth of Rustenburg for at least the next five years. Refuse removal The Rustenburg Local Municipality currently renders the following waste removal services: • Domestic waste removal • Business/Industrial waste removal • Street cleansing and litter picking service • Garden refuse removal services • Waste Transfer • Waste Treatment • Landfill operation services • Contracted services. • Education and Awareness

The greater Rustenburg area has approximately 120 000 service points of which approximately 70 000 as well as the CBD area is serviced by contractors. Service providers were appointed from the first of December 2012 to render services to 50 000 households. This has reduced backlog of areas not receiving basic waste Management services:

• RDP houses – Newly developed houses are not yet receiving services (+ 1 000 houses) • Informal Settlements (+ 5 000 houses) • Rural areas (6000 settlements).

The Waste Management Unit is in the process of the review of the integrated waste management and alternative service delivery mechanism in a form of a municipal waste entity.

5. Economic profile

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Gross Value Added (“GVA”) The economic profile provides an overview of the economic structure and performance of the Municipal area. Figure 46

Figure 46below provides a comparative overview of the contribution of each sector to the local economy.

Figure 47Figure 47 clearly illustrates that the Mining sector made the most significant contribution towards the Gross Value Added in 2010.

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Figure 46: GVA Sectoral Composition of the municipality (Rustenburg LM IDP, 2014-2015)

Gross Domestic Product (“GDP”)

Figure 47Figure 47 provides a comparative analysis of the GDP growth experienced on a national level and in Rustenburg. The overall trend on both national and local level is more or less the same, except for some exceptions where the Rustenburg Local Municipality outperformed national GDP growth in 2003 and achieved 17.6% contribution. An ultimate low was experienced during 2009 where Rustenburg Local Municipality achieved a negative growth of -3.5%.

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Figure 47: Gross domestic product (Rustenburg LM IDP, 2014-2015)

Main exports According to the Rustenburg LM IDP, 2014-2015, the main contributor towards total exports from the district municipality is platinum in a semi-manufactured form. This product contributes 45.2% towards total exports from the Bojanala Platinum District Municipality. Besides platinum other significant contributors towards exports include Ferro-chromium (28.8%), palladium (6.0%) and rhodium (8.9%).

Figure 48: Top products exported by the Bojanala District Municipality (Rustenburg LM IDP, 2014- 2015)

Local Economic Development (“LED”) Opportunities The following sub-section provides an overview of the opportunities identified within the RLM. The opportunities are identified within their ability to develop the economy of the local municipality and improve the socio-economic conditions of residents within the municipality. This sub-section covers the following economic sectors: • Agriculture; • Mining;

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• Manufacturing; • Utilities; • Trade; • Transport, Storage and Communication; • Finance; • Community and Personal services; • General Government Services; and • Tourism.

The following opportunities have been identified for the mining sector within the Rustenburg Local Municipality.

Table 64: Summary of opportunities identified for the mining sector (Rustenburg LM IDP, 2014- 2015)

Opportunities identified for the mining sector Mining waste beneficiation (SMME’s)

Marketing and support for smaller mines

Small-scale mining of construction related minerals

Opportunities for greater support from mines involved in the reviewing of SLP’s

Establish partnership with Mintek to assist SMME’s with innovative uses of existing minerals

Establish Platinum Excellence Centre/form partnerships with existing research institutions

Recycling/Rehabilitation of mines

Facilitate the potential partnership between Impala and Xstrata (Glencore) to establish business support centres that do not result in the duplication of services

Improve relationships with the mines

Needs of the area in order of priority is provided in Table 65 below.

Table 65: Needs of the area in order of priority (Waterval Mine SLP, 2014 - 2018)

Rustenburg Local Municipality Priority Issues:

1. Construction of new roads and maintenance of internal roads

2. Low cost Housing

3. Shortage of recreational and sports facilities

4. Illegal dumping and general cleanliness of the area

5. Unemployment

6. Poor level of literacy and education

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6. Glencore: Waterval Mine Social and Labour plan

Glencore: Waterval Mine has a Social and Labour Plan (“SLP”) in place that sets new targets for the years 2014-2018. Waterval Mine will, through its Social and Labour Plan, attempt to contribute to a safe, healthy, productive and competitive industry. Waterval Mine has a vision of fostering a legacy of sustainability. Kroondal Mines’ mission is to work towards growth and prosperity through the investment in people and the advancement of diverse and self-reliant economies. Waterval Mine can only achieve this through genuine partnership with employees, communities and other stakeholders, which are based on integrity, co-operation, transparency and mutual value creation. The Social and Labour Plan is aligned to the principles of the relevant legislation and the prescribed undertakings and objectives of the Mineral and Petroleum Resources Development Act (“MPRDA”), Act 28 of 2002.

Through the Social and Labour Plan Waterval Mine aims on developing and implementing comprehensive Human Resources Development Programmes, a Mine Community Development Plan, a Housing and Living Conditions Plan, an Employment Equity Plan and Processes to save jobs and manage downscaling and/or closure. The above programmes are aimed at promoting employment and advancement of the social and economic welfare of all South Africans whilst ensuring economic growth and socio-economic development. Waterval Mine will strive to fulfil the following objectives in developing and implementing the Social and Labour Plan:

• Promote economic growth and mineral and petroleum resources development in the Republic; • Promote employment and advance the social and economic welfare of all South Africans; • Contribute towards the socio-economic development of the areas in which Waterval Mine is operating as well as the areas from which the majority of the workforce is sourced; and • To utilise and expand the existing skills base for the empowerment of HDSA’s and to serve the community.

The Mine is aware of the socio - economic pressure on the hosting community and that alternative work in the surrounding area is limited as well as the additional needs for Municipal services and infrastructure. To limit the negative impact of the mining operation on the area, the mine has a resilient focus on local recruitment and undertakes to retain this focus. Table 66 below reflects the Labour Sending Areas of the current workforce.

Table 66: Labour sending areas of Current Workforce as at 31 December 2013 (Waterval SLP, 2014-2018)

Labour sending areas Count % Local 307 82.5%

In Province 36 9.7%

Inter-Provincial 27 7.3%

Foreign 2 0.5%

Total: 372 100%

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7.4.2 Description of the current land uses

Land use and development at the site The majority of the surrounding land use is either arable or mining. Rustenburg town is situation 3km to the east of Waterval Mine and Kroondal 5km to the west (Updated EMP, 2009). The predominant pre-mining land use was natural grassland. Land on Waterval-West could have been used for arable land due to the present vegetation occurring on the land. Most of the present land uses are mine related quarries, discard dumps, tailings storage facilities, water retention dams, soils and waste rock stockpiles and shafts (Updated EMP, 2009). According to the 2009 SANBI land cover data the Farm Waterval has a number of classifications. It is classified as mining in the south-east, as urban built-up in the north-west and the remainder as a mix of natural and cultivated land (

Figure 49Figure 49). Waterval is discussed in this section as Waterval West, Waterval East and Waterval North (rehabilitated area north of Waterval Mine and Offices) (Figure 50).

Operations take place in two separate areas to the west (ca. 21 ha) and east (ca. 24 ha). Infrastructure within the operational areas include an office block (Glencore Alloy’s head-office), mine training facilities, engineering and environmental offices, two Tailings Storage Facilities (“TSFs”), two Return Water Dams (“RWDs”), two explosive storage areas and two shaft complex sections as well as chrome and waste rock stockpiles. The perennial Hex River flows to the north east of the non-operational area, which has been subject to past mining, stockpiling and cultivation practices. Parts of this area especially along the Hex River are currently used as motorcycle track while other areas are used for dumping of building waste. Current land uses on and surrounding the site are summarised in Table 67.

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Figure 49: Positioning of Water East, West and North (NSS, July 2015)

Table 67: Current land uses for the site associated with Waterval Mine, and surrounds

Direction Land use Fragmentation Land in and amongst operations is highly fragmented and degraded, some viable habitat The study remains in the gardens around the main office Chrome mining, processing and site block. Outside this area is a large (ca. 105 ha) stockpiling. Waste dumping and (Waterval undeveloped stretch of rehabilitated fallow land motorcycle track. Mine) that connects to a 770 m reach of the Hex River which provides important corridor for biodiversity

Open land along Hex River, mostly cultivated but some natural areas remain. Extends for Eastwards Cultivation and natural. about 2.4 km to the start of the Waterkloof settlement.

Highly fragmented almost all natural habitat South Residential, Waterval East has been transformed.

Highly fragmented almost all natural habitat Westwards Industrial, Rustenburg has been transformed.

Mining and tailings (Anglo Fair amount of open fallow and natural land North Platinum) remains but fragmented by several tar roads, and past cultivation railway lines and mines. Source: NSS, July 2015

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Office park gardens: (Waterval West) Stockpiling area (Waterval West)

Motorcycle track along Hex River (Waterval Rehabilitated area (Waterval North) North)

Figure 50: Current land use for the site and surrounds (NSS, July 2015)

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Figure 51: 2009 Land cover data for Waterval Mine and surrounds (NSS, July 2015)

Agricultural potential

The soil units as listed in Chapter D above, were allocated to a relevant class of agricultural potential. The limitations are given in Table 68 below.

Table 68: Soil limitations

Potential Class Map Unit(s) Main limiting factor(s) Area (ha)

Occurs in low lying area and is prone to sKa flooding. sSe Shallow soil with structured layer restricting Low (l) 15 ha water infiltration. sVa Shallow soil with structured layer restricting water infiltration

Moderately deep with water restricting layer Medium (m) mAr 10 ha further down.

High (h) dAr Deep soil with good permeability 12 ha

Total: 37 ha Source: Institute of Soil, Climate and Water, 2007

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In summary, the area mostly has soils of high and moderate agricultural potential due to sufficient depth with good to moderate permeability.

Land use options The study area comprises a small zone of moist duplex soils that could be prone to waterlogging due to the restricting layer in the subsoil (map units sSe and sKa). These soils have a low agricultural potential and should at best be left in their natural state. The map unit sVa in the central part of the site comprises shallow soils with moderate structure in the subsoil and have a low potential for agriculture. These areas are, at best, suitable only for grazing.

Moderately deep soils of the Avalon and Hutton forms (map unit mAv) are found predominantly in the north-western zone of the property and have a slight depth restriction that places them in a moderate potential for agriculture.

The map unit dHu in the south-east corner of the site comprises deep, freely drained soils which have a high potential for agriculture. These soils should be retained as prime agricultural land.

It should, however, be borne in mind that the long-term average annual rainfall of 619 mm is marginal for dryland cultivation, especially when coupled with the often intense nature of the precipitation and the variation between rainfall seasons. Without supplementary irrigation, this area should be considered as having a moderate to high risk for rain-fed agriculture.

Landscape Function Analysis Natural Scientific Services cc conducted a Land Function Analysis for Waterval Mine (dated April 2015). The resultant report is attached in Annexure G2. The Landscape Function Analysis (“LFA”) seeks to assess the conservation or loss of vital resources such as soil, water, and nutrients from a landscape. Functional landscapes essentially conserve their resources and are self-sustainable. They typically support many vegetated patches, such as grass tufts, in an arrangement that allows for the effective trapping and infiltration of resources that are moving though the system, while dysfunctional landscapes are typically those characterised by numerous bare soil patches that provide little obstruction to the overland movement of water and soil resources which are thus effectively lost from the system (Tongway & Hindley, 2003; 2004).

Any changes to the composition, structure or appearance of a landscape will alter its functionality from that moment onwards. The Landscape Function Assessment used in the study provides a tool for monitoring the consequences of land management practices and the effects of mining activities on the functionality of landscapes. The LFA report seeks to draw comparisons and establish trends between the past (NSS, 2011a) and current landscape functionality of the rehabilitated areas at Waterval Chrome Mine.

As with the proceding LFA field work took place in early summer (14 October 2014) when plants were in an active state of growth and many species were flowering or actively producing seed.

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The LFA process involved four principal steps:

1. Description of the geographic setting of the site; 2. Characterising landscape organisation, the spatial distribution of the fertile-patches and inter patches; 3. The soil surface assessment (“SSA”) of each of the patch/inter-patch type; 4. Analysis of data.

The exact location and date of the LFA sampling points are provided in Table 69.

Table 69: Location and date of LFA sampling points at Waterval Mine

Sampling Sampling Location Date Location Date Point Point

Waterval-1 25.67511S; 07 Oct Waterval-1 25.720473S; 14 Oct (Rehabilitated) 27.27179E 2010 (Rehabilitated) 27.325085E 2014

Waterval-2 25.67953S; 07 Oct Waterval-2 25.722926S; 14 Oct (Rehabilitated) 27.27615E 2010 (Rehabilitated) 27.330507E 2014 Source: NSS LFA, 2015

Patch / inter-patch functionality has increased at both transect sites. Although soil functionality has increased at Waterval 2 it has decreased significantly at Waterval 1 thereby lowering the overall soil functionality of the premises since 2010. The increase in patchiness and landscape organisation index suggests the recruitment of new grass tufts while a higher total patch area means that more of the land is covered with grass than in 2010. The drop in soil functionality is mainly attributable to a lower nutrient and infiltration capacity of soils beneath grass tufts at Waterval 1. Despite this, soil stability has increased overall likely due to the increased recruitment of grasses. The low patch area index in both 2010 and 2014 means that grass cover is far from its theoretical maximum.

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Figure 52: Changes in soil surface functionality at Waterval between sampling periods (NSS LFA, 2015)

Although a good mix of grasses has established over the years within the rehabilitated area the woody component is still very low with only a few scattered bush clumps. The red sandy soil likely plays a role in the slower recovery as compared to the black turfs. Currently, however, the veld is underutilised and would benefit from grazing by bulk grazers such as cattle which, through trampling, would increase infiltration and the pressure on the grassy component thus favouring the recruitment of woody species. There are still a number of disturbances on site of most significance being the dumping of refuse in and around the riparian zone of the Hex River that borders the site to the east. Here there are also a number of old open trenches.

Overall, with the exception of trees which are still sparse, the area under rehabilitation has recovered well with a good mix of grasses of differing heights and structure with the old pit area barely visible in current Google Earth imagery (Figure 53).

A small stand of the highly invasive Pompom weed (Campuloclinium macrocephalum) was noticed and must be removed forthwith before it spreads.

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Figure 53: Historical Google Earth imagery for Waterval (NSS LFA, 2015)

7.4.3 Description of specific environmental features and infrastructure on the site

Refer to detailed discussions under Section 7.4 above for the specific environmental features at Waterval Mine. Also refer to Section 4.2 above for a discussion on the infrastructure on site.

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7.4.4 Environmental and current land use map

Refer to

Figure 54below for the environmental and current land use map.

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Figure 54: Environmental and current land use map

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7.5 Impacts and Risks Identified

7.5.1 Impacts and risks associated with the Updated EMPR, 2009

The following information was obtained from the approved Environmental Management Programme report for the Xstrata Waterval Chrome Mine, dated July 2009 and compiled by CHEMC environmental.

Table 70: Impacts and Risks identified including mitigation/management measures included in the Updated EMPR, 2009

SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

To minimise the destruction In compliance of the with the Mining Mining of non- Alteration of the geology due to Construction and Site only Disruption of geology is expected during mining geological Rights issued in 1 Geology renewable underground mining and N Y Operational Control Operational Phase Mining Right operations and no mitigation is possible. strata and to terms of the High High High High High resources possible opencast mining Phase Hight area Definite Definite prevent the MPRDA (2002) unnecessary and the EMPr. loss of geology

All mine infrastructure not required post closure Alteration of topography due to be broken down and removed from site. Mine building Decommissioning 2 construction of mine Y N Control Areas levelled to a free draining topography

infrastructure Low phase infrastructure Definite Definite Medium Medium Medium Medium before being ripped, grassed and seeded as per Medium Probable Probable the rehabilitation plan.

Construction and To minimise Operational Site only Topsoil stockpiles are to be preserved in line impacts on with the closure plans. General Phase topography implementation of Stockpiles shaped to a natural angle of repose activities taking as per final closure designs. Dumps topsoiled Mining and Alteration of topography due to and seeded to encourage natural sustainable Biodiversity Mine deposits construction of tailings dam & vegetation cover. Decommissioning 3 Topography N Y Control Guidelines into and stockpiles waste rock dumps, stockpiles account. phase

Definite Definite Correct shaping and placement of material in the Medium Medium Medium Medium Medium Medium Medium

etc. Probable tailings during the LOM will ensure the final Rehabilitation in closure topography is managed and closure is terms of MPRDA more sustainable. This aspect is to be controlled and NEMA in the design and operation of the tailings dams principles. as included in the closure plan.

All mine infrastructure not required post closure Removal of mine infrastructure Decommissioning be broken down and removed from site. To minimise Decommissioning 4 Rehabilitation and rehabilitation will alter the Y N and closure Site only Control Areas levelled to a free draining topography impacts on Low Low Low Low Low Low phase topography. phase topography Medium Medium

before being ripped, grassed and seeded as per Possible Probable Probable the rehabilitation plan.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Rehabilitation monitoring to be Topsoil initially removed to correct depth and undertaken by stockpiled correctly. Topsoil replaced in areas to suitably qualified rehabilitation standards with correct ripping, rehabilitation fertilisers and seeding. Compaction and soil specialist (in degradation due to Construction and Mining footprint and operation to be kept as To minimise consultation with Decommissioning 4 construction of infrastructure, Y Y Operational Site only Control small as possible as per the mining plan to degradation of ecologist). and Closure Phase concrete foundations, roads Phase reduce compaction. soil Definite Definite Medium Medium Medium Medium Medium Medium Medium General etc Probable During rehabilitation where stockpiled topsoil is implementation of being used (i.e. at closure) topsoil placed must activities taking be ripped correctly prior to seeding and Mining and fertilization. Biodiversity Guidelines into account.

Long-term topsoil stockpiles (i.e. stockpiled greater than 2 years) should be correctly shaped and seeded to reduce erosion. Rehabilitated areas must make use of adequate water management canals and cut off trenches Rehabilitation to prevent erosion. monitoring to be undertaken by Final topsoil placement on rehabilitated areas suitably qualified should where possible be done in the winter rehabilitation early spring, to allow time for proper fertilization specialist (in and seeding prior to the season’s first rains. This To minimise Erosion and soil loss due to no Construction and consultation with will maximize seed growth throughout the and prevent 5 Soil Construction stormwater controls around N Y Operational Site only Control ecologist). Operational Phase summer and reduce long-term erosion. degradation of dumps. Phase Definite Definite Medium Medium Medium Medium Medium Medium Medium General Rehabilitation designs should aim to maximize Probable soil implementation of the 1:7 and 1:5 gradients to reduce overall activities taking erosion potential. Mining and All newly top soiled areas must ripped and then Biodiversity analysed for nutrient deficiencies and this Guidelines into corrected prior to seeding to maximize plant account. growth. Correct landscaping will be implemented to ensure that an acceptable slope gradient is used to minimize soil erosion.

Rehabilitation monitoring to be undertaken by suitably qualified Mining footprint and operation to be kept as rehabilitation Compaction and soil small as possible as per the mining plan to specialist (in degradation due to Construction and reduce compaction. To minimise consultation with Operational, ecologist). 6 construction of stockpiles, Y Y Operational Site only Control During rehabilitation where stockpiled topsoil is degradation of Decommissioning waste dumps and slimes Phase soil and Closure Phase Definite Definite Medium Medium Medium Medium Medium Medium being used (i.e. at closure) topsoil placed must Medium General Probable Probable dams. be ripped correctly prior to seeding and implementation of fertilization. activities taking Mining and Biodiversity Guidelines into account.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Rehabilitation monitoring to be undertaken by suitably qualified Demarcated areas for vehicles need to rehabilitation identified, to ensure no compaction of specialist (in unnecessary areas. Loss of soil fertility due to Construction and To minimise consultation with Operational, ecologist). 7 construction, compaction and Y Y Operational Site only Control Limited movement and use of equipment onto of degradation of Decommissioning pollution potential Phase High soil and Closure Phase

Definite Definite the soil stockpile should be allowed. Medium Medium Medium Medium Medium General Probable Probable implementation of Areas requiring soil stripping will be delineated. activities taking Stripping may only occur where soils are to be Mining and disturbed, and an end-use for the stripped soil Biodiversity needs to be identified. Guidelines into Stockpile areas must be clearly demarcated and account. sufficient stormwater controls need to be implemented. Rehabilitation monitoring to be The stockpile areas must be designed in undertaken by accordance with Government Notice 704. suitably qualified rehabilitation Topsoil will be stockpiled, and this will be done specialist (in separately to subsoil. Construction and To minimise consultation with Operational, Loss of soil structure due to 8 Y Y Operational Site only Control Stockpiles will be vegetated, and no waste degradation of ecologist). Decommissioning removal of topsoil Phase High material will be placed on these stockpiles. soil and Closure Phase Definite Definite Medium Medium Medium Medium Medium General Probable Probable Equipment movement will be limited, so as to implementation of minimise compaction of the stockpiles. activities taking Mining and Biodiversity Guidelines into account.

Pollution resulting from spills/breakdowns will be cleaned-up immediately in accordance with the mine’s incident reporting procedure. Adequate clean-up procedures will be implemented, according to the type of waste. All hazardous waste will be cleaned-up according to the relevant procedure. Rehabilitation monitoring to be An oil absorbent fibre emergency kit will be undertaken by issued to the site supervisor to clean accidental suitably qualified oil pollution. rehabilitation specialist (in Chemical contamination due to Oil spills will be removed and handled according Construction and To minimise consultation with Operational, pipeline spillages / to waste management procedure. 9 Y Y Operational Site only Control contamination ecologist). Decommissioning

breakdowns / diesel spillages / Low Low Phase Vehicles will only be permitted to be serviced on of soil and Closure Phase

Medium Medium Medium General oil spillages Probable Probable concrete floors, and drip trays used during implementation of repairs. activities taking Re-fuelling will be done in allocated areas Mining and (bunded with a concrete floor). Biodiversity Guidelines into Oils and hydrocarbons will be kept in bunded account. areas. Equipment containing oil and diesel must be stored on a concrete floor and drain to an oil trap. All spills from the explosives magazine should be cleaned-up with immediate effect.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Rehabilitation plan to be drafted with end land Rehabilitation use in mind, plan to include final slopes, free monitoring to be draining topography, water management undertaken by structures (e.g. drains) and topsoil thicknesses. suitably qualified Plan also requires a schedule of activities to rehabilitation keep abreast with the mining operations. specialist (in To minimise Disturbance of soils and Construction and consultation with Operational, A topsoil layer of 300 mm or more will be used disturbance of 10 Construction vegetation due to Construction Y Y Operational Site only Control ecologist). Decommissioning on rehabilitated areas. soils and of mining infrastructure. Phase and Closure Phase Definite Definite Definite Medium Medium Medium Medium Medium Medium vegetation General Rehabilitation designs of mine reside dumps to implementation of ensure effective final landform is obtained that is activities taking freed draining, manages surface water run-off, Mining and reduced infiltration and mitigates soil erosion. Biodiversity All residue dumps to be shaped, top soiled, Guidelines into fertilized and seeded as per rehabilitation plan. account. Where mine residue dumps are removed, the Rehabilitation soil will be analysed to determine rehabilitation monitoring to be capability. undertaken by suitably qualified Dumps to be operated during the LOM with final rehabilitation closure in mind where possible, in order to specialist (in Disturbance of soils and ensure minimal rehabilitation at the end of the To minimise Construction and consultation with Operational, Construction and vegetation due to construction LOM. disturbance of 11 Y Y Operational Site only Control ecologist). Decommissioning operation of tailings dams and waste soils and High High High Phase High Rehabilitation plan/designs to be implemented High and Closure Phase rock dumps. Definite Definite vegetation General once closure of mine is finalised and no future implementation of commercial value of the dump is obtainable. activities taking Effective indigenous seed mixes should be used Mining and Land at all times. The seed mixtures used must take Biodiversity capability account the availability of seed, different soil Guidelines into and land use situations and the prevailing climatic conditions account. of the area. Erosion control measures will be implemented in order to ensure that topsoil is not washed away and erosion gulleys do not develop in arable land. Rehabilitation monitoring and auditing will be implemented to ensure conformance with the Rehabilitation rehabilitation plan on an annual basis. monitoring to be undertaken by Rehabilitation plan must detail goals for slopes suitably qualified angles, species composition, topsoil thickness rehabilitation and basal cover per rehabilitation area of the specialist (in Construction and mine. To prevent the consultation with Operational, Change of land use due to the 12 Operation N Y Operational Site only Rectification loss of valuable ecologist). Decommissioning operation of the mine A post-closure monitoring programme will be High High High Phase High High land and Closure Phase Definite Definite instituted for a minimum period of 5 years in Definite General order to ensure that the area has been implementation of successfully rehabilitated and there are no latent activities taking impacts. Mining and Biodiversity As far as is practical, all of the rehabilitated areas Guidelines into will be grassed prior to the start of the rainy account. season. Should no topsoil be available for placement in residue or tailings dams then a tailings analysis will be performed prior to seeding and soil ameliorants and additives will be added accordingly.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable The seed mix will be evaluated, giving consideration to include indigenous grasses, herbaceous and bulbous species in order to restore to a diverse as possible state as per the closure plan objective. Protected plant species should be demarcated to prevent disturbance to the plants. Should avoidance of impact on the protected species not be possible, a permit for removal / relocation must be obtained from the responsible authority. The importance of conservation of protected plant species must be included in general awareness programmes for Waterval Mine. All employees should be trained on the importance of all aspects of the environment (including fauna). No employees will be allowed to hunt or poach animals within or around the Waterval Mine area. Prohibiting terrestrially-mobile fauna from accessing the operational areas, by upgrading the fencing around these areas to be as impermeable to fauna as possible (by e.g. using fine Bonnox mesh in addition to current fences). Conserving the physical habitat integrity of the Hex River. It is important that the dense riparian vegetation fringing the Hex be maintained along with the general geomorphology and hydrology of the river. Ideally the system should remain as a quiet, well wooded, slow flowing and clear river with the occasional riffle at rocky knick points. Alien vegetation should also be controlled in the riparian zone while being mindful not to open the riparian canopy too extensively. Conserving the water quality of the Hex River: Half-collared kingfishers are particularly susceptible to deterioration in water quality and rely heavily on the presence of clear water. As such efforts should be made to prevent the sedimentation, erosion or pollution (especially by chromium) of the Hex river. Water quality should be tested regularly especially for the following parameters, total dissolved solids, suspended solids, electrical conductivity, pH, oxygen reducing potential, heavy metals especially chromium (both total chromium and CrVI), aluminium, cadmium, manganese, lead, zinc) and E.coli. Snakes that are encountered on site should be safely captured and relocated away from working areas, by staff members who are appropriately trained and qualified to do so (for more information see www.africanreptilesvenom. co.za). Reducing road kill by restricting vehicle access to the non-operational operational areas.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Mine activities and development limited to as small a footprint as possible, hence reducing immediate impact on surrounding fauna and flora. This will include clearly designated roads, plants, mine offices/admin and residue deposits. Must be clearly indicated on a site plan, and General activities outside of these areas must not be implementation of Loss of ecosystems due to the Construction and allowed. To prevent the activities taking Operational, removal of natural vegetation 13 Y Y Operational Site only Control loss of Mining and Decommissioning for plant, shaft, road and Mine to conduct regular ecological evaluations of High High Phase High biodiversity Biodiversity and Closure Phase Definite Definite Medium Medium Medium Medium

tailings dams construction. the site to be used to monitor impacts on Probable Guidelines into biodiversity. account. Mine to develop a biodiversity action plan to address the protection of the sensitive areas identified on the site, species composition on rehabilitated areas in relation to post mining land use and capability.

General Spillages will be reported as per the incident implementation of Construction, reporting procedure and cleaned-up in Construction, Degradation of surrounding To prevent the activities taking Operational and accordance with the clean-up procedure as soon Operational, 14 ecosystems due to the N Y Site only Remedy loss of Mining and Decommissioning as practically possible in order to prevent Decommissioning spillages and contamination biodiversity Biodiversity Medium Medium Medium Medium Medium Medium

Phase Probable damage to vegetation and compromise the Probable and Closure Phase Guidelines into functioning of ecosystems. Biodiversity Mining account.

General implementation of Construction, Construction, Dust covering vegetation due Water will be sprayed on the access roads To prevent the activities taking Operational and Operational and 15 to trucks and equipment on dirt N Y Site only Control (gravel) to reduce the amount of dust covering loss of Mining and

Decommissioning Low Low Decommissioning roads as well as blasting. surrounding vegetation biodiversity Biodiversity Medium Medium Medium

Phase Probable Probable Phase Guidelines into account.

General implementation of activities taking Mining and Construction, Biodiversity Construction, Degradation of surrounding An alien and invasive species eradication To prevent the Operational and Guidelines into Operational and 16 ecosystems due to the Y N Local Control programme will be implemented, and progress loss of Decommissioning account. Decommissioning propagation of alien invaders monitored on a regular basis. biodiversity Medium Medium Medium Medium Medium Medium Medium Possible Possible Phase Probable Biodiversity and Phase alien invasive management in accordance with NEMBA, 2004

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Mine to regularly update its mine water balance Surface water to ensure all uses and quantities are captured as quality mining plan changes. monitoring. The mine will maximize return water use from Compliance with tailings facilities and water from other dirty water DWS’s Best Practice storage facilities. To conserve Guideline Series the surface The amount of water recycled must be in in terms of Construction, Pollution due to polluted Construction and water resource proportion to the water balance of the area integrated water Operational and 17 groundwater recharge into N Y Operational Regional Control and prevent and waste Decommissioning surface resources Phase impact on Medium Medium Medium Medium Medium Medium The mine will ensure compliance with the Medium Possible Possible

Probable Probable management and Phase downstream National Water Act and GN 704 will be enforced monitoring. at all times. water users. Water Surface water quality and borehole quality and management levels will be monitored in order to quantify the measures in effect that mining and deposition has on the compliance with water quality. Total suspended solids will be NWA, 1998 and added to the surface water quality monitoring GN 704, 1999 programme, as silt is considered to be the most significant pollutant. Surface water The groundwater model will be updated in line quality with the Water Use Licence requirements. Extra monitoring. monitoring boreholes will be drilled where and Compliance with when required. DWS’s Best Practice Groundwater monitoring will be continued to To conserve Guideline Series determine the effects of the residue deposits on the surface Chemical and physical in terms of Construction, Construction and groundwater with the results of such monitoring water resource Surface contamination due to flash Remedy / integrated water Operational and 18 Mining N Y Operational Regional submitted to the DWS, in accordance to the and prevent water floods resulting in overflow of Control and waste Decommissioning Phase approved Water Use Licence (“WUL”). impact on Unlikely Unlikely Medium Medium Medium Medium Medium Medium Medium contaminants. Possible management and Phase downstream All water management systems (clean and dirty monitoring. water users. water) will be designed for the 1:50 year flood event to prevent dirty water spillages from the Water dirty water system to the clean water system and management vice versa. measures in compliance with Run-off from the tailings dams and waste rock NWA, 1998 and dumps will be contained in order to decrease the GN 704, 1999 silt-load from these areas into ground and surface water resources. Walls to be constructed Surface water around the base of all stockpiles, in order to quality achieve this. These trenches will accommodate monitoring. all potential flow, without any spillage. These trenches will be inspected on a regular basis. Compliance with DWS’s Best Collection points (with a conveyance system) for Practice To conserve standing surface/storm flow will be constructed, Guideline Series the surface in order to ensure that the clean surface water is in terms of Construction, Physical contamination as a Construction and water resource Control / not directed into the dirty water system. integrated water Operational and 19 result of increased silt load due N Y Operational Regional and prevent Remedy and waste Decommissioning to dust deposition Phase High Structures such as diesel storage tank etc. will impact on Definite Definite Medium Medium Medium Medium Medium Medium Possible Possible management and Phase downstream be bunded with adequate capacity4. Oil traps monitoring. and cut-off trenches to be constructed at the water users. workshops, wash bays, brake test shop and Water stores. management measures in Pollution resulting from spills/breakdowns will be compliance with cleaned-up immediately in accordance with the NWA, 1998 and mine’s incident reporting procedure. GN 704, 1999

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

The underground septic tanks located at the Surface water Waterval Mine are serviced by a contractor for quality safe disposal. monitoring. Toe drains/paddocks around the tailings dam to Compliance with be maintained in an acceptable condition, and to DWS’s Best be inspected on a weekly basis for Practice To conserve erosion/cracks Guideline Series the surface in terms of Construction, Physical contamination as a Operational and The water levels in the return water dam, water resource integrated water Operational and 20 result of overflow of the return N Y Decommissioning Regional Control conservancy tanks and water storage dams will and prevent Low Low Low Low and waste Decommissioning water dam Phase be monitored on a regular basis in order to impact on Unlikely Unlikely Medium Medium Medium Medium

Probable Probable management and Phase ensure that there is sufficient capacity to prevent downstream monitoring. overflow. All storage dams will have a freeboard water users. of 0.8 metres. Water Stormwater management on site will be management managed in accordance with the Storm Water measures in Management Plan. compliance with NWA, 1998 and Mining footprint areas will be adequately GN 704, 1999 rehabilitated as per the standard defined in the closure plan. Rehabilitation will be undertaken in Surface water accordance with the rehabilitation plan, and quality dumps will be sloped, grasses and seeded in monitoring. order to reduce erosion and infiltration. Compliance with A bio-monitoring programme will be instituted. DWS’s Best Should the bio-monitoring indicate a further Practice To conserve deterioration in the ecological integrity of the Guideline Series the surface stream, the necessary actions will be taken to in terms of Construction, Chemical contamination as a Operational and water resource address this (for issues that the mine has control integrated water Operational and 21 result of nitrification due to Y Y Decommissioning Regional Control and prevent over). and waste Decommissioning explosives. Phase High impact on Definite Definite Medium Medium Medium Medium Medium Medium Possible Possible management and Phase downstream Where applicable, the mine to investigate monitoring. methods of removing excess nitrogen from the water users. water system. Water management The mine will have a back-up system in order to measures in ensure that adequate pollution control can be compliance with implemented during load shedding. NWA, 1998 and The removal of sewage tanks post-closure will GN 704, 1999 reduce the pollution potential from the septic tanks. Surface water quality The cessation of mining will result in the monitoring. cessation of dewatering. This will impact on the water balance. Compliance with DWS’s Best An oil absorbent fibre emergency kit will be Practice To conserve issued to the site supervisor to clean accidental Guideline Series the surface Flow alteration as a result of oil pollution. Oil spills will be removed and in terms of Construction, Operational and water resource the of waste rock dumps in Control / handled according to waste management integrated water Operational and 22 N Y Decommissioning Regional and prevent non-perennial tributary's Remedy procedure. and waste Decommissioning High High High Phase High High impact on floodline. Definite Definite management and Phase downstream Vehicles will only be permitted to be serviced on monitoring. concrete floors, and drip trays used during water users. repairs. Refuelling will be done in allocated Water areas (bunded with a concrete floor). Oils and management hydrocarbons will be kept in bunded areas. measures in Equipment containing oil and diesel must be compliance with stored on a concrete floor, and drain to an oil NWA, 1998 and trap. GN 704, 1999

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Water monitoring and management reports are Surface water to be submitted to the DWS, in accordance to the quality approved WUL. monitoring. Compliance with DWS’s Best Practice To conserve Guideline Series the surface Physical contamination due to in terms of Construction, Operational and water resource uncontained run-off from Control / integrated water Operational and 23 N Y Decommissioning Regional and prevent waste rock dump and tailings Remedy and waste Decommissioning Phase impact on Medium Medium Medium Medium Medium Medium dams Possible Possible management and Phase downstream monitoring. water users. Water management measures in compliance with NWA, 1998 and GN 704, 1999

Groundwater monitoring

Chemical contamination due to Operational and To prevent Water Operational and Control / 24 seepage of AMD from N Y Decommissioning Regional groundwater management Decommissioning Remedy stockpiles and tailings dams Phase High High pollution measures in Phase Unlikely Unlikely Unlikely Medium Medium Medium compliance with NWA, 1998 and GN 704, 1999.

Groundwater monitoring Change in water balance, loss Operational and To prevent Water Operational and of yield as a result of Control / 25 Groundwater Mining Y Y Decommissioning Regional groundwater management Decommissioning groundwater abstraction and Remedy Phase pollution measures in Phase Medium Medium Medium Medium Medium Medium Medium Possible Possible dewatering Probable compliance with NWA, 1998 and GN 704, 1999.

Groundwater monitoring

Chemical contamination as a Operational and To prevent Water Operational and 26 result of nitrification from N Y Decommissioning Regional Control groundwater management Decommissioning

blasting activities Phase High pollution measures in Phase Definite Definite Medium Medium Medium Medium Medium Medium Probable Probable compliance with NWA, 1998 and GN 704, 1999.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Groundwater monitoring

Chemical contamination as a Operational and To prevent Water Operational and 27 result of seepage from N Y Decommissioning Regional Control groundwater management Decommissioning

contaminated soils & dumps Phase High pollution measures in Phase Medium Medium Medium Medium Medium Medium Possible Possible Probable Probable compliance with NWA, 1998 and GN 704, 1999.

The mine will ensure legislative compliance, in particular with the Air Quality Act and Mine Dust fallout Health and Safety Act. To reduce air monitoring Construction, quality impacts Operational and Air pollution from vehicular Operational and Vehicle exhaust gases will be minimized by the Air quality 28 N Y Regional Control from mining management Decommissioning Low Low emissions Decommissioning Low maintenance of effective exhaust systems on and related Phase Definite Definite Medium Medium Medium measures in Phase mine vehicles. Probable activities. compliance with Equipment will be maintained, and employees NEM: AQA. versed in the operation thereof.

The mine will continue to monitor the dust fallout levels emanating from the mining activities, and will institute mitigatory measures should the dust fallout levels be too high. The mine will continue to apply dust suppression Dust fallout measures where, and when, necessary. These To reduce air monitoring Construction, measures will be revised if the dust fallout levels quality impacts Operational and Operational and become too high. Air quality 29 Dust pollution from haul roads N Y Local Control from mining management Decommissioning Low Low Decommissioning Low Where dust assessment indicates high dust and related Phase Definite Definite Medium Medium Medium measures in Phase fallouts within operational areas, the mine will Probable Air Quality Mining activities. compliance with ensure that all employees are adequately trained NEM: AQA. in the use of personal protective equipment. Dust suppression measures that include the watering of/use of chemical palliatives on the haul roads and water sprays in the beneficiation process. The topsoil stockpiles will be seeded.

Ore will be kept wet where possible to prevent dust generation. The mine will continue to monitor the dust fallout levels emanating from the mining activities, and Dust fallout will institute mitigatory measures should the dust To reduce air monitoring Dust pollution from ore transfer fallout levels be too high. The mine will continue quality impacts Operational Air quality 30 points, stockpiles, crushing & N Y Local Control to apply dust suppression measures where, and from mining management Operational Phase Low Low Phase Low screening when, necessary. These measures will be and related Definite Definite Medium Medium Medium measures in Probable Probable revised if the dust fallout levels become too high. activities. compliance with Where dust assessment indicates high dust NEM: AQA. fallouts within operational areas, the mine will ensure that all employees are adequately trained in the use of personal protective equipment.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Dust fallout Dust suppression measures that include the monitoring watering of/use of chemical palliatives on the To reduce air Dust pollution from topsoil Operational and haul roads, dust suppression (wetting) on the quality impacts Air quality 31 stockpile, ore stockpiles, waste N Y Decommissioning Local Control waste rock dumps and tailings dams, water from mining management Operational Phase Low Low rock dump Phase Low and related

Definite Definite sprays in the beneficiation process. Medium Medium Medium measures in Probable Probable activities. compliance with The topsoil stockpiles will be seeded. NEM: AQA.

Dust suppression measures that include the watering of/use of chemical palliatives on the haul roads, dust suppression (wetting) on the Dust fallout waste rock dumps and tailings dams, water monitoring sprays in the beneficiation process. The topsoil To reduce air Operational and quality impacts Dust pollution from tailings stockpiles will be seeded. Air quality 32 N Y Decommissioning Local Control from mining management Operational Phase

dam Low Low Phase Footprint areas will be adequately rehabilitated. and related

Medium Medium Medium measures in Probable Probable Probable activities. The waste rock dumps and the tailings dams will compliance with be rehabilitated according to the specifications of NEM: AQA. the rehabilitation plan, and concurrent rehabilitation will take place as far as is possible.

For transport on public roads truck tyres carrying Dust fallout ore will be make use of a tarpaulin in order to To reduce air monitoring reduce dust from the use of these vehicles. quality impacts Dust pollution from transport of Operational Air quality 33 N Y Local Control The cessation of mining activities will result in from mining management Operational Phase

ore Phase Low Low and related

Medium Medium diminished vehicular traffic, and the transport of Medium measures in Probable Probable Probable ore will cease, thus reducing the dust generation activities. compliance with potential. NEM: AQA.

The mine will ensure legislative compliance, in particular with the Mine Health and Safety Act. The mine currently has a noise monitoring programme (as part of the Occupational Hygiene programme) and mitigatory measures will be implemented should the noise levels be too high. Vehicles and machinery will be well maintained and serviced on a regular basis in order to To reduce Noise control Noise generation from minimize noise generation. noise impacts measures in Noise and machinery, screens & Operational 34 Mining Y N Local Control from mining compliance with Operational Phase Low Low vibration crushers, pumps, pipeline Phase Low Employees will be trained in the correct use of and related Code SABS 0328 Definite Definite Medium Medium Medium operation machinery in order to minimize the generation of Possible activities of 2008 noise. A complaints register will be maintained. The mine will ensure legislative compliance, in particular with the Mine Health and Safety Act. Where required, vehicles will be fitted with vibration control devices on machines that are found to affect the health of the operator/driver

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

The mine currently has a noise monitoring To reduce Noise control programme (as part of the Occupational Hygiene noise impacts measures in Noise generation from Operational 35 Y N Local Control programme) and mitigatory measures will be from mining compliance with Operational Phase Low Low conveyor belt siren Phase Low implemented should the noise levels be too high. and related Code SABS 0328 Definite Definite Medium Medium Medium Possible Possible A complaints register will be maintained. activities of 2008

A blasting procedure shall be drafted to include blasting times and techniques shall be employed to minimize noise will be applied at all times. To reduce Noise control noise impacts measures in Vibration from blasting Operational Blasting techniques to minimize vibration will be 36 Y N Local Control applied at all times. Blasting times will be limited from mining compliance with Operational Phase Low Low activities. Phase Low and related Code SABS 0328 Definite Definite Medium Medium to the start of each shift, and only take place Medium Probable Probable during daylight hours. Blasting activities will be activities of 2008 closely monitored, and corrective and mitigatory measures implemented as necessary.

To reduce Noise control Vehicles and machinery will be well maintained noise impacts measures in Noise generation from Operational 37 Y N Local Control and serviced on a regular basis in order to from mining compliance with Operational Phase Low Low vehicular traffic Phase Low minimize noise generation. and related Code SABS 0328 Definite Definite Medium Medium Medium Probable Probable activities of 2008

The mine currently has a noise monitoring programme (as part of the Occupational Hygiene programme) and mitigatory measures will be implemented should the noise levels be too high. To reduce Noise control Decommissioning Vehicles and machinery will be well maintained noise impacts measures in Noise generation from 38 Y N and closure Local Control and serviced on a regular basis in order to from mining compliance with Operational Phase Low Low rehabilitation activities Low phase minimize noise generation. and related Code SABS 0328 Definite Definite Medium Medium Medium Probable Probable Employees will be trained in the correct use of activities of 2008 machinery in order to minimize the generation of noise. A complaints register will be maintained.

39 Traffic Mining The impacts that may arise from vehicular traffic are detailed in the ‘air pollution’ and ‘noise, vibration and shock’ sections.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Heritage No heritage resources are expected to be found during future operation, however, should artefacts or remains be discovered on the mine, 40 Mining No heritage resources have been identified. resources this must be immediately reported the South African Heritage Resources Council prior to further damage or removal.

Sensitive 41 Mining The Hex River (and its associated riparian zone and habitats) has been classified as a sensitive area. Refer to surface water. landscapes

Rehabilitation in terms of MPRDA and NEMA principles. To control Aesthetics altered due to the Operational and Operational and visual impacts General 42 construction of mine Y N Decommissioning Local Control implementation of Decommissioning

Low Low associated with infrastructure. Phase Refer to mitigation measures for topography and Phase Definite Definite Definite Medium Medium Medium Medium air pollution as they have implicit relevance to Medium the mine activities taking managing the atheistic impacts. Mining and Biodiversity The rehabilitation, and the associated Guidelines into demolishing and grassing of structures, will account. Visual Construction and improve the aesthetics of the area as the land is aspects operation returned to the pre-mining land use. Rehabilitation in terms of MPRDA The tailings dams and waste rock dumps will be and NEMA rehabilitated in a manner as to decrease the final principles. Aesthetics altered due to the aesthetic impact resulting from the permanent To control Operational and Operational and construction of tailings dams, presence of these structures. visual impacts General 43 Y N Decommissioning Local Control implementation of Decommissioning

stockpiles, waste rock dumps Low Low associated with Phase Phase Definite Definite Definite & topsoil stockpile. Medium Medium the mine activities taking Mining and Biodiversity Guidelines into account.

The mine will undertake an annual audit of its Social and Labour Plan in order to determine the effectiveness, and progress, of the programmes being implemented. The mine has appointed a Skills Development Prevent socio Conflict may result from the Operational and Facilitator to allow for the effective economic Implementation of Operational and Socio- 44 Mining creation of varying wealth Y N Decommissioning Regional Control implementation of the skills training impacts by approved Social Decommissioning Low Low economic Low classes Phase programmes. Waterval has registered with the employment and Labour Plan. Phase Medium Medium Medium Possible Possible Probable Probable Mine Qualification Authority (MQA), and pays opportunities. the relevant skills levies. The mine’s HR Training and Development Centre has been registered as a fully accredited Training and Development Centre with the MQA.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable The mine will recruit local labour as far as is possible. Discussions will be held with community leaders when recruitment takes place, and it is anticipated that these discussions will sensitize the local community to the presence of migrant workers in the area. Migrant workers will be encouraged to stay in formal housing, and settlement into informal settlements will be discouraged. Mine workers will receive education as to the prevention of the spread of communicable diseases. The local recruitment strategy, as well as the implementation of the procurement programme, will encourage economic diversification of the area. SMMEs that are established as part of the Local Economic Development Programme will need to be sustainable. The mine will have exit strategies in order to encourage this sustainability post-closure. Employees who are retrenched will be redeployed within the group. Should this not prove to be feasible, the mine will attempt to find employment in the mining industry on their behalf. Employees will be re-skilled in order to encourage job seeking outside of the mining industry. The Health, Safety, Environmental, and Community Standards identify key community risks and opportunities and manage those effectively to prevent adverse impacts, and deliver sustained benefits to the communities in which the Company operates.

The mine will undertake an annual audit of its Prevent socio Increased unemployment as a Operational and Social and Labour Plan in order to determine the economic Implementation of Operational and 45 result of influx of job seekers Y N Decommissioning Regional Control effectiveness, and progress, of the programmes impacts by approved Social Decommissioning Low Low into the local area. Phase Low employment and Labour Plan. Phase

Medium Medium being implemented. Medium Possible Possible Probable Probable opportunities. The mine’s HR Training and Development Centre has been registered as a fully accredited Training and Development Centre with the MQA. The mine will recruit local labour as far as is possible.

Discussions will be held with community leaders Prevent socio Conflict may arise due to an Operational and when recruitment takes place, and it is economic Implementation of Operational and 46 influx of job seekers into the N Y Decommissioning Regional Control anticipated that these discussions will sensitize impacts by approved Social Decommissioning Low Low local area. Phase the local community to the presence of migrant Low employment and Labour Plan. Phase Medium Medium Medium Possible Possible Probable Probable workers in the area. opportunities.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Increased spread of communicable diseases due to Operational and Mine workers will receive education as to the Prevent socio Implementation of Operational and 47 an influx of job seekers into the N Y Decommissioning Regional Control prevention of the spread of communicable economic approved Social Decommissioning High High local area and disruption of Phase High diseases. impacts. and Labour Plan. Phase Definite Definite Medium Medium Medium Medium family units. Possible

Operational and The adequate rehabilitation of the mining Prevent socio Implementation of Operational and Loss of agricultural and Control / 48 Y N Decommissioning Regional footprint will return the land to its former economic approved Social Decommissioning grazing land Remedy High High Phase High agricultural and grazing potential. impacts. and Labour Plan. Phase Definite Definite Medium Medium Medium Medium Possible Possible

The mine will undertake an annual audit of its Social and Labour Plan in order to determine the effectiveness, and progress, of the programmes being implemented. The mine has appointed a Skills Development Operational and Facilitator to allow for the effective Prevent socio Implementation of Operational and 49 Skills transfer to employees Y N Decommissioning Regional Enhancement implementation of the skills training economic approved Social Decommissioning Phase programmes. Waterval has registered with the impacts. and Labour Plan. Phase Positive Positive Mine Qualification Authority (MQA), and pays Positive the relevant skills levies. The mine’s HR Training and Development Centre has been registered as a fully accredited Training and Development Centre with the MQA.

The mine will undertake an annual audit of its Social and Labour Plan in order to determine the effectiveness, and progress, of the programmes Prevent socio Implementation of Operational and Operational being implemented. 50 Job creation Y N Regional Enhancement economic approved Social Decommissioning Phase The mine has appointed a Skills Development impacts. and Labour Plan. Phase Positive Positive Facilitator to allow for the effective Positive implementation of the skills training programmes. Waterval has registered with the Mine Qualification Authority (MQA), and pays the relevant skills levies. The mine’s HR Training and Development Centre has been registered as a fully accredited Training and Development Centre with the MQA. Prevent socio Implementation of Operational and Operational 51 Increase in local employment Y N Regional Enhancement The mine will recruit local labour as far as is economic approved Social Decommissioning Phase possible. impacts. and Labour Plan. Phase Positive Positive Positive Discussions will be held with community leaders when recruitment takes place, and it is anticipated that these discussions will sensitize

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, SIZE AND ACTIVITY PHASE remedy, STANDARD COMPLIANCE ASPECTS SCALE control, or TIME PERIOD FOR NO. whether listed in which impact MITIGATION MEASURES TO BE WITH AFFECTED of stop) IMPLEMENTATION or not listed is anticipated ACHIEVED STANDARDS disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable the local community to the presence of migrant workers in the area. Migrant workers will be encouraged to stay in formal housing, and settlement into informal Prevent socio Implementation of Operational and Operational 52 Income generation Y N Regional Enhancement settlements will be discouraged. economic approved Social Decommissioning Phase impacts. and Labour Plan. Phase

Positive Positive Mine workers will receive education as to the Positive prevention of the spread of communicable diseases. The local recruitment strategy, as well as the implementation of the procurement programme, will encourage economic diversification of the area. SMMEs that are established as part of the Local Economic Development Programme will need to be sustainable. Prevent socio Implementation of Operational and Increase in economic Operational 53 Y N Regional Enhancement economic approved Social Decommissioning diversification Phase The mine will have exit strategies in order to encourage this sustainability post-closure. impacts. and Labour Plan. Phase Positive Positive Positive Employees who are retrenched will be redeployed within the group. Should this not prove to be feasible, the mine will attempt to find employment in the mining industry on their behalf. Employees will be re-skilled in order to encourage job seeking outside of the mining industry. Prevent socio Implementation of Operational and Operational 54 Community upliftment Y N Regional Enhancement economic approved Social Decommissioning Phase The Health, Safety, Environmental, and impacts. and Labour Plan. Phase

Positive Positive Community Standards identify key community Positive risks and opportunities and manage those effectively to prevent adverse impacts, and deliver sustained benefits to the communities in which the Company operates.

Construction, Loss of renewable resources Energy consumption will be monitored and Operational and Prevent socio Implementation of Operational and Energy due to energy uses for tracked. 55 operation & N Y Decommissioning National Control economic approved Social Decommissioning

consumption construction, mining & Low phase High Energy saving equipment (i.e. lights, geysers High impacts. and Labour Plan. Phase Definite Definite Definite decommissioning decommissioning activities. etc.) will be investigated over the Life of Mine. low Very

7.5.2 Impacts and risks associated with the PGM EMPR, 201144

The following information was obtained from the approved Environmental Impact Assessment and Environmental Management Programme, Waterval PGM plant EMPr, dated 2011 and compiled by Environmental and Energy Services.

Table 71: Impacts and Risks identified including mitigation/management measures included in the PGM EMPR, 2011

44 The impacts, risks and mitigations provided in this section were extracted from the original approved EMPr (dated 2011). The approved EMPr provided for the rating of each respective risk and impact, however, there is no rating of the risks and impacts for post-mitigation.

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable

The tailings dam will be used to store potentially chemically dangerous To minimise the In compliance Construction substances (chrome). Construction, destruction of the with the Mining and operation Operational and geological strata and to Rights issued in 1 Geology The probability exists that N Y District Control Ensure the tailings dam is constructed as per design. Operational Phase of the tailings the chrome may seep into Decommissioning prevent the terms of the

dam the underlying rock if the Phase Low Very unnecessary loss of MPRDA (2002) necessary preventative geology and the EMPr. measures are not implemented

General implementation of activities The infrastructure related to taking Mining the tailings dam will have a and Biodiversity definitive impact on the Construction Construction, Guidelines into and operation topography. Operational, Remove structures which are not needed for the efficient operation of To minimise impacts account. Decommissioning 2 Topography of the waste N Y Decommissioning District Control the mine. Change in landform: on topography phase rock dump and and Closure

Medium Medium Ensure the tailings dam is constructed as per design. tailings dam Topographical changes can Phase Rehabilitation in be expected from the waste terms of rock dump and tailings dam. MPRDA and NEMA principles.

Visually inspect the terrain for signs of erosion and stability of surface Rehabilitation Soil Soil Erosion: run-off control structures. monitoring to be disturbance on undertaken by Although the soils are not the different Usable soil for the purposes of rehabilitation will be stripped from areas suitably highly erodible (there is no disturbed to be cleared for construction and operation and stored in designated qualified significant increase in clay areas. soil stockpiles. rehabilitation from subsoil to topsoil, while Construction, specialist (in Stripped soil will be stockpiled and stored using the following Lack of proper there are large areas with Operational, To minimise and consultation Control / conservation principles: 3 water rock outcrops acting as N Y Decommissioning Site prevent degradation of with ecologist). Operational Phase stabilisers), this impact is Low Remedy management and Closure Soil will be stockpiled by means of end-tipping to avoid compaction; soil structures. potentially significant due to Phase General the topography of the area Stockpile areas will have their soils stripped to conserve the seed bank; implementation Un- (increased speed of water of activities rehabilitated from slopes) and the nature Single handling will be practiced; taking Mining areas and lack of rainfall in the area (mostly and Biodiversity Stockpiles that are likely to remain unused for more than 12 months will of vegetation. thundershowers). Guidelines into be revegetated to manage dust and erosion and to maintain the soil's account. viability (further principles regarding rehabilitation will be contained in the soil utilisation plan. Soil Soil Compaction: Usable soils will be re-spread with a minimum of compaction; Rehabilitation Structures such as the monitoring to be Site establishment of roads and Land to which soil has been reapplied will be revegetated. undertaken by preparation, the hauling of material to the suitably Stockpiles and newly spread soil will be kept clear of invasive the plant cause compaction of qualified vegetation. construction of soil. The process during rehabilitation which the integrity of the soil access roads Minimise the area to be cleared that is safe for construction and specialist (in structure is altered from its Construction, and other operation activities, thereby minimising the disturbed footprint and its To minimise and consultation natural state is called Operational and Control / 4 infrastructure. Y N Site vulnerability to erosion, pollution of storm water and dust generation. prevent degradation of with ecologist). Operational Phase compaction. This change Decommissioning Low Remedy Areas to be disturbed will be cleared as close to the start of construction soil Vehicles may result in reduced water Phase General as possible so that bare areas are not left exposed for long periods of travelling on holding capacity and ability implementation time. undisturbed of the soil to release this of activities land compacts water to plants. It could Rehabilitation will be progressive throughout the life of mine and will taking Mining the soil therefore further lead to the commence as soon as the disturbing activity has ceased. and Biodiversity loss of a growth medium Guidelines into and the plant alienation of a Roads to be constructed as part of the mine will be designed and built account. particular surface area to minimise erosion.

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable

Seepage from Prevent contamination of soils due to leaching of contaminants from the return the mine residue deposits and plant area during operation and decommissioning Rehabilitation water dam, the monitoring to be tailings dam, undertaken by Soil Contamination: and waste rock suitably dump; Possible contaminants and qualified Earth moving their impacts will depend on rehabilitation Construction, equipment the nature of the seepage or specialist (in Operational, To minimise and breakages and loss, as well as the buffering Control / consultation 5 N Y Decommissioning Site prevent degradation of Operational Phase oil / lubricant / capacity of the soil. Remedy with ecologist). However, in severe cases and Closure High soil diesel spills General there can be a sterilisation Phase may implementation effect on the soil and a contaminate of activities subsequent loss of land soil. taking Mining capability. Poor and Biodiversity housekeeping Guidelines into at the account. workshops

Rehabilitation monitoring to be undertaken by suitably qualified rehabilitation In the process of removing Construction, specialist (in To minimise and Topsoil topsoil the soil layers are Operational and consultation 6 N Y Site Control prevent degradation of with ecologist). Operational Phase

stripping mixed and the structure may Decommissioning Low soil be disturbed. Phase General implementation of activities taking Mining and Biodiversity Guidelines into account.

Rehabilitation Temporary loss of land Disturbed areas will be rehabilitated as soon as possible in accordance monitoring to be capability to support with the rehabilitation principles of the mine. The grazing: undertaken by construction of Ensure the natural vegetation cover between the sections receives the suitably roads and The land capability on the highest level of protection to ensure proper plant material remains. qualified buildings. new tailings dam will be lost. rehabilitation An invasive and alien control programme must be drafted and Construction, specialist (in Removal of The land capability on the implemented by the operation. All illegal exotic or invader plants and Operational, Land Operational and Control / To prevent the loss of consultation 7 soil covering haul roads and plant area is N Y Site weeds shall be eradicated as legislatively required. Decommissioning capability Decommissioning Remedy valuable land with ecologist). the tailings also alienated until the area and Closure Phase Phase dam changes is rehabilitated. Moderate Awareness program to all staff must include alien and exotic species General the land identification (species expected on this site only) and eradication implementation capability of Prior to mining the land was measures. of activities the mining used mostly as a wilderness taking Mining Unpaved roads will be constructed and maintained using a dust area. area. After rehabilitation the and Biodiversity suppressant. Regularly grading will take place and, if necessary, the land will still be able to be Guidelines into roads will be watered to suppress dust. used as a wilderness area. account.

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable Establish a temporary network of dust fallout monitoring points along Change in land use: Rehabilitation The current boundary around the tailings dam and plant areas (including waste rock monitoring to be mining Land use impacts are dumps) to identify hotspot areas for dust impacts and use the results undertaken by activities integrally linked with soils to establish permanent continuous monitoring stations. suitably already and land capability, along Monitoring of air quality. qualified affected the with the visual and socio- rehabilitation previous land economic aspects. Records of dust suppression interventions. specialist (in use and the Construction, consultation Operational, The demarcated mining Control / To prevent the loss of 8 Land use construction of N Y Operational Local with ecologist). Decommissioning

Low Low Remedy valuable land the new shaft areas lost their original land Phase and Closure Phase and waste rock use (wilderness). This plus General dump will have the proposed new shaft and implementation an additional waste rock dump area will of activities impact on the be alienated for agricultural taking Mining land use purposes. The rest of the and Biodiversity potential. area will keep its original Guidelines into capability. account.

Vegetation clearance, disturbance and trampling: Species diversity can be General The clearance negatively influenced by the implementation of the footprint fragmentation of vegetation of activities for the new communities. waste rock taking Mining dump. Denuded areas and and Biodiversity Construction, Construction, invasion of invaders and Control / To prevent the loss of Guidelines into Operational and 9 The footprint of Y Y Operational Local exotic species may follow Remedy biodiversity account. Decommissioning the new incline Phase High due to the disturbed soil. Phase shaft. Biodiversity and Large areas of undisturbed alien invasive All existing vegetation will remain and management in mine they should serve as accordance with infrastructure reference for vegetation NEMBA, 2004 success and source of Vegetation natural plant material and seed.

Earthmoving equipment, General light vehicles, Dust coverage of plants implementation loading and of activities hauling Most plants are known to be taking Mining operations are resistant to dust pollution, and Biodiversity Construction, responsible for which normally washes Construction, Control / To prevent the loss of Guidelines into Operational and 10 dust away after a small Y Y Operational Local account.

Low Low Remedy biodiversity Decommissioning generation downpour. This may Phase Phase inside the become a problem during Biodiversity and boundaries of extended dry periods or alien invasive the mine. It is when excessive dust is management in also generated present. accordance with and spread by NEMBA, 2004 wind.

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable

General implementation The removal of of activities natural taking Mining vegetation and and Biodiversity Construction, soil Habitat change, loss of Construction, Control / To prevent the loss of Guidelines into Operational and 11 disturbance sensitive species, spread of N Y Operational Local Remedy biodiversity account. Decommissioning due to mining alien and invasive species Phase Phase activities and Moderate Biodiversity and improper alien invasive rehabilitation management in accordance with NEMBA, 2004

The flora, which normally serves as General habitat for implementation animals, birds of activities and insects will taking Mining be destroyed and Biodiversity Construction, Construction, during mining. Wildlife habitat destruction / Control / To prevent the loss of Guidelines into Operational and 12 N Y Operational Local Re-establish trees and grass cover as soon as possible during and The increase change / disturbance Remedy biodiversity account. Decommissioning Phase after mining. in activity will Phase Moderate Moderate Biodiversity and Where breeding nests are found and where required, the necessary temporarily alien invasive demarcations must be erected. scare other management in animals. The Killings etc. must be reported in the incident register. accordance with area will NEMBA, 2004 Wildlife recover after Game catching, hunting, traps, snares, poaching and any other rehabilitation unnecessary disturbance of animals inside the boundaries of the operation must be a disciplinary offence. General Machine operators and drivers to undergo appropriate level of implementation environmental impact training to ensure they understand their impact of activities on the environment. taking Mining The Construction, and Biodiversity Construction, movement of Implement Environmental Awareness program Operational and Control / To prevent the loss of Guidelines into Operational and 13 vehicles Injury and killing of fauna N Y Site account.

decommissioning Low Remedy biodiversity Decommissioning Snares and Phase Phase traps Biodiversity and alien invasive management in accordance with NEMBA, 2004

Regularly grading will take place and, if necessary, the roads will be Any watered to suppress dust. unmitigated construction or The mine will plant trees, in consultation with a vegetation specialist, to Dust fallout loading and act as windbreakers. monitoring hauling activity PM 10 dust pollution: Construction, (monthly) or vehicles Establish a temporary network of dust fallout monitoring points along To reduce air quality Operational and Operational and Control / 14 Air quality travelling on The IAP’s raised this aspect N Y Local boundary around the tailings dam and plant areas (including waste rock impacts from mining Air quality Decommissioning

decommissioning Low Remedy dirt roads will and the dust outfall needs to dumps) to identify hotspot areas for dust impacts and use the results and related activities. management Phase Phase generate an be monitored. to establish permanent continuous monitoring stations. measures in compliance with impact. These Daily inspections of plant and equipment. impacts will be NEM: AQA. aggravated by Monitoring of air quality. high winds. Records of dust suppression interventions.

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable

Excessive noise pollution: Heavy vehicles The mine is located in a traversing the rural environment with the The majority of construction with high noise potential will take place area, nearest residences many during daylight hours when the ambient noise level is higher, for compressors, kilometres away. Excessive example braking of concrete, compaction, steel works and heavy Noise control Construction, ventilation noise may have an impact vehicle transport along the access road. To reduce noise measures in Operational and Control / 15 Noise fans, the on the mine residences. Y N Local impacts from mining compliance with Operational Phase decommissioning Remedy Construction equipment will be maintained in good working order. Non- crusher and High and related activities Code SABS Phase compliance machinery will be removed from service until repaired. the plant The impact will also be of 0328 of 2008 importance regarding the equipment will All vehicle exhaust units will be maintained in good working order. Non- direct worker environment be the main compliant vehicles will be removed from service until repaired. sources of that should adhere to the noise. requirements in terms of the Mine Health and Safety Act.

Although no known site will be affected by the development, the following aspects must however be considered during the life of mine: Fence off archaeological sites within the mine Notify SAHRA timeously in the event that additional sites are located during construction and operation. Allow extended archaeological investigations to be conducted if sites deemed unique are identified within the mine area and are likely to be disturbed by mining activities. The mine is already Apply for necessary permits from SAHRA and implement the developed. requirements of the National Heritage Act should any of the sites need To reduce impacts The new to be destroyed or if graves need to be exhumed. from mining and Compliance to Operational and Archaeological infrastructure related activities on the National 16 N/A N/A N/A N/A N/A N/A Where it is necessary to exhume and re-bury bodies the mine will apply Decommissioning

and cultural will not affect N/A cultural and Heritage Phase any of the for the necessary permissions. (This will include acquisition of permits archaeological Resources Act. identified from SAHRA, national and provincial health departments, community artefacts sensitive (and next of kin) consultation, and collaboration with a forensic areas. archaeologist if new graves are located during construction or operation). The mine will implement an education programme for construction and operational staff to ensure that they are aware of and respect the cultural significance of known sites. This requirement will be included in contractor tender documentation. If it becomes known that a site of archaeological or cultural significance within the mine area is likely to be visited, then provision for access will be made to ensure the safety of visitors and the security of the mine.

No sensitive Sensitive 17 landscapes N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

landscapes N/A are present

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable

The plant is pre-existing and only the tailings-dam will add to the Rehabilitation in visual impact terms of that already MPRDA and The visibility of the waste exists at the NEMA rock dump and plant were site. Construction, Consideration will be given to appropriate planting trees, in consultation principles. identified as specific To control visual Operational and Operational and Control / with a vegetation specialist, at sensitive areas. 18 Visual Impacts The in-mine problem areas by IAP’s. Y Y Local impacts associated General Decommissioning decommissioning Remedy roads, shaft High Focused lighting will be implemented to direct light towards the mine, implementation Lights from the mine are with the mine Phase infrastructure, Phase to reduce the impact of light pollution at night. of activities also very visible at night waste rock taking Mining time. dump, power and Biodiversity lines and other Guidelines into infrastructure account. in and around the operation will create a visual impact.

Increase in Socio – economic activity at local level. Additional employees are Unemployment is present sourced from within the communities. Ensure the SLP is developed and implemented. the Construction, Prevent socio Implementation Operational and Socio surrounding The mining and agricultural Operational and See that all contracts with employees, contractor, SMME’s, farmers economic impacts by of approved 19 Y N Local Enhance Decommissioning Economic communities sectors employ most of the decommissioning etc. take all these commitments into consideration. employment Social and Phase in line with employed population. Phase Positive opportunities. Labour Plan. objectives of Ensure compliance with all Health and Safety requirements. The company’s Social the social and investment programme as labour plan. listed in the Social and Labour plan should assist the communities.

Ensure the complaints registration process is implemented and treated at the highest level. Employment, Ensure the SLP is implemented. procurement, services etc, Impact of activities on I& Make sure the community forums are implemented and functional. AP’s impacts on the Ensure all the commitment made during the consultation process are community A portion of the expected implemented or adhered to. individually expenditure for the project Construction, Prevent socio Implementation Interested and Operational and and as a will go to the community. Operational and The mine will have a dedicated community liaison officer to co-ordinate economic impacts by of approved 20 Affected Y N Local Control Decommissioning whole. This will also bring long-term decommissioning communications with the surrounding interested and affected parties. employment Social and Parties Phase employment and financial Phase The community liaison officer will: a) be sensitive to socio-economic opportunities. Labour Plan. Visual Moderate spin-offs. issues; b) be experienced in community liaison; c) have good impacts, dust communication skills; d) have conflict management and facilitation and noise Noise, traffic and dust could skills, e) is fluent in the local languages. could become become a nuisance factor. a nuisance The mine will participate in relevant local forums and bodies which may factor. be established from time to time. The mine will operate in accordance with the agreed commitments in its SLP.

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable

Storm water control measures must be implemented to divert clean Surface water water away from the site and contain contaminated water. and Potential contaminants are groundwater most likely to arise from the Water control structures must be well designed and constructed to monitoring transport of tailings slurry or ensure a minimum down wash of topsoil. quality return water. monitoring. Stilling ponds, silt traps and energy dissipating structures must be used The dirty water will be where and when necessary. Compliance reused in the process to with DWS’s Best The mine will maximise on opportunities to recycle water. It is intended To conserve the Pollution of minimise the need for Construction, Practice that all process water will be recycled with no direct release to the surface water and Construction, surface waters additional make-up water Operational, Guideline Local to environment. Storm water will be contained and reused up to the 1:50 groundwater resource Operational and 21 from the requirements. N Y decommissioning Control Series in terms

Regional Low year 24 hour storm event in accordance with Regulation 704. and prevent impact on Decommissioning Tailings Dam and Post-closure of integrated An additional risk is the downstream water Phase Complex Phase water and waste failure of the tailings dam or Visual inspection to identify any risk. users. return water dam, where management Provision of spill cleaning kits. quality is likely to be poor. and monitoring. Training to ensure awareness of this risk and action plans for Design of the tailings dam Water emergencies. can ensure that these management measures in impacts are adequately The disturbed surface area must be rehabilitated in accordance with compliance with managed. the rehabilitation plan to ensure normal drainage. NWA, 1998 and Minimal clean water run-off should end-up in silt traps and return water GN 704, 1999 dam but will become part of the ground water regime due to seepage. Surface water Ensure water management structures are designed and constructed in and such a way as to allow the maximum amount of “clean” water to be groundwater diverted away from the operations and into natural drainage channels. monitoring quality Regular water sampling and monitoring to be done. The Bushveld Complex monitoring. Aquifer is considered a non- Mine vehicles to be inspected to ensure no oil and hydraulic fluid leaks Compliance Water aquifer with low occur. with DWS’s Best resources transmissivities and yields. To conserve the Construction, Practice Ground water All oil spills must be cleaned up immediately. surface water and Construction, The Dam will not be placed Operational, Guideline contamination Local to groundwater resource Operational and 22 in close proximity to any N Y decommissioning Control All process water and return water from tailings dams should be Series in terms from Tailings Regional and prevent impact on Decommissioning faults. and Post-closure High contained and reused. All other ‘dirty’ water generated on site should of integrated Dam Complex downstream water Phase Phase be used preferentially to ‘clean’ make up water. water and waste users. Monitoring will be essential management to establish whether or not Linear infrastructure (roads and pipelines) will be inspected on a and monitoring. significant contamination is regular basis. occurring. Water All surface water management infrastructure constructed from soil management (berms, canals and bunds) will be inspected on a regular basis, with measures in more frequent inspections during periods of high rainfall and after major compliance with rainfall events. NWA, 1998 and All drainage facilities will be checked regularly during the rainy season GN 704, 1999 and any undue erosion or siltation, especially at discharge points, will be noted and repaired. The mine will identify the cause of such undue Surface water and Due to the ephemeral erosion or siltation and suitable remedial measures will be implemented. groundwater nature of the stream, monitoring downstream water users Loss of Stormwater berms will be provided downslope of areas recently quality are not solely reliant on the To conserve the catchment, Construction, stripped of vegetation to ensure that silt-laden stormwater does not flow monitoring. surface water. surface water and Construction, reducing Operational, directly into the watercourses. Local to groundwater resource Compliance Operational and 23 availability The impact cannot be Y N decommissioning Control Regional Energy dissipaters, such as rock packs and logs, will be placed in and prevent impact on with DWS’s Best Decommissioning downstream mitigated, except by and Post-closure High footpaths where there are signs of erosion. The footpaths will be downstream water Practice Phase from Tailings minimising the infrastructure Phase inspected on a regular basis, with more frequent inspections during users. Guideline Dam Complex footprints. periods of high rainfall and after major rainfall events. Series in terms of integrated In a stressed catchment all Clean water diversions and dirty water collection facilities will be contributions are important. water and waste established before land clearing and construction commences, to management prevent clean rainfall runoff becoming contaminated by construction and monitoring. activities. The measures envisioned are simple soil berms to prevent

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable clean runoff entering dirty areas and others to divert dirty water to Water settlement paddocks. management measures in Dirty water drains will be sized to manage the ‘dirty’ water generated compliance with by a 1:50 year storm arising on contaminated areas (plant, shaft, pits, NWA, 1998 and tailings dam, waste rock dumps, stockpiles, stores, workshops etc). GN 704, 1999 Dirty water will be directed into sumps or retention ponds, from where it can be returned to the process water circuit. The storage facilities will have a minimum freeboard of 0.8m above full supply level. Dirty water systems will prevent water containing waste from entering water resources. The dirty water drains will be constructed of concrete Surface water or have an impermeable liner to ensure impermeability. and groundwater Clean water diversion canals will be sized to divert runoff from monitoring upstream catchments around all contaminated areas. The clean runoff quality will be released into the natural watercourses downstream or the dirty monitoring. Water infiltration will area. Ideally, the release will be into the same catchment from which generate a hydraulic head the water was diverted. Compliance with DWS’s Best Alteration to under the dam which will To conserve the Construction, Clean water diversion canals will be sized to safely divert the 1:50 year Practice hydraulic head cause water to move away surface water and Construction, Operational, flood event. Guideline affecting from the dam. groundwater resource Operational and 24 N Y decommissioning Regional Control Series in terms

aquifer system Low and prevent impact on Decommissioning The tailings dam is located and Post-closure Construction material for clean water diversions will be at least of integrated from Tailings downstream water Phase some distance from any Phase compacted earth for areas with level gradients. These will be grassed water and waste Dam Complex users. such feature and thus no to limit erosion. In steeper areas, the canals will be constructed from management such impact is foreseen concrete, inert rock or other suitable material to act as erosion control and monitoring. here. and energy dissipaters. Water The width and height of the drains will be determined to ensure management compatibility with identified hydraulic requirements of the drain. measures in The mine will keep water systems clear of obstructions, so drains will compliance with be inspected regularly. Unless problems are encountered during these NWA, 1998 and inspections, the drains will be cleaned and maintained annually, as GN 704, 1999 necessary. Surface water The water levels in the dirty water storage facilities will be kept low by and recycling into process water circuit. This ensures the facility has groundwater enough capacity in the event of another severe rainfall event. monitoring quality Unused roads will be rehabilitated after construction while high traffic monitoring. If storm water runoff is not roads (access road) will be surfaced. Other roads still used by the mine managed then erosion can will be maintained and any new roads will have proper engineered Compliance occur along clean and dirty designs to prevent erosion. This may include contour banks, erosion with DWS’s Best To conserve the water drainage systems. Construction, control measures such as stone walls across gullies and dongas and Practice Erosion and/or surface water and Construction, Operational, proper stormwater diversion measures. As access roads will stretch Guideline scouring from Eroded material can Local to groundwater resource Operational and 25 Y Y decommissioning Control along steep topography, road surfaces need to be properly maintained, Series in terms Tailings Dam contribute to the pollution of Regional and prevent impact on Decommissioning and Post-closure High and any runoff channelled from the surfaces via properly sized and of integrated Complex surface waters. downstream water Phase Phase designed culverts, to minimise erosion. water and waste users. management Clean water diversion Road crossings will be sized to meet the National Drainage Manual and monitoring. release points are requirements. particularly vulnerable. Water Embankments at watercourse crossings, within the flooding zone, will management be protected against erosion. measures in compliance with NWA, 1998 and GN 704, 1999

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable

Where culverts are used at crossings, the culverts will have Surface water downstream erosion protection and energy dissipaters to reduce flow and rates to their original velocities. groundwater Mine residue deposits, water storage facilities and plant infrastructure monitoring will be located above the 1:100 year floodline or at least 100 m from a quality watercourse, whichever is the greater. monitoring. Drainage lines in the area of The mine will not conduct any mining within the 1:50 year flood line or Compliance with DWS’s Best the tailings dam will be 100m of a watercourse, whichever is the greater. To conserve the Construction, Practice Changes to affected and thus surface water and Construction, Operational, All mine residue deposits will be designed and operated in accordance Guideline watercourses constitutes a Section 21 Local to groundwater resource Operational and 26 Y Y decommissioning Control with the requirements of SABS 0286:1998 and the Mandatory Code of Series in terms due to Tailings water use. Regional and prevent impact on Decommissioning and Post-closure High Practice for the Operation of Mine Residue Deposits. of integrated Dam Complex downstream water Phase Only real significance Phase water and waste users. relates to loss of catchment, The tailings pipeline will be designed to minimise the risk to soils and management as discussed earlier. watercourses along the pipeline route and monitoring. Existing and proposed mine residue deposits and water storage Water facilities will be designed and constructed under the supervision of management appropriately qualified professional engineers. All mine deposits and measures in water storage facilities will be maintained in a stable state and comply compliance with with relevant legislation. NWA, 1998 and The return water dams will be sized to accept seepage from the under GN 704, 1999 drainage systems and decant systems for up to the 1:50 year rainfall event, over and above normal operating conditions. Surface water and Spillways will be constructed in all mine residue return water dams and groundwater mine water storage facilities to ensure safe overflow of runoff arising monitoring from storm with a recurrence interval greater than 1:50. quality monitoring. The mine will not locate any sanitary convenience (sewage works), fuel depot or storage facility for anything which may cause pollution within Compliance the 1:50 year flood line of a watercourse. with DWS’s Best Potential contaminants To conserve the Pollution of Practice Construction, surface water and Construction, surface waters Pollution only likely to arise All spillages within the reagent storage and makeup areas will be Guideline Operational and Local to groundwater resource Operational and 27 from the from spills/leaks associated N Y Control retained by the construction of bund walls. The bund will be capable of Series in terms

decommissioning regional Low and prevent impact on Decommissioning tailings with poor housekeeping and containing the bulk reagents independently and the bund wall will be of integrated Phase downstream water Phase pipelines incorrect management of lined/treated to ensure that the reagents do not affect the integrity of water and waste users. pipeline bursts. the bund wall (e.g. acid proofing). Spillages within the bund can then management be cleaned up and disposed of appropriately. and monitoring. Spillages within the make-up areas will be pumped to the process water Water system. management The ore stockpiles will be kept on concrete or other impermeable hard- measures in standing, to prevent entry of pollutants into soils and groundwater and, compliance with through recharge, into surface water. NWA, 1998 and GN 704, 1999 Oil/fuel storage facilities will be adequately bunded (110%), with no outlets to external drainage systems. Oil/fuel filling points will be Surface water located within the bund wall. Spilt or leaked oil will be contained and and either reused or disposed of by a suitably qualified waste oil contractor. groundwater monitoring Workshop areas where oil/fuel spills can occur, will be located within a quality Potential contaminants fully contained catchment area. All drainage from the area will report to To conserve the monitoring. Ground water an oil/silt separator. ‘Treated’ drainage will then report to the ‘dirty’ Pollution only likely to arise Construction, surface water and Construction, contamination water system for reuse/recycling. Waste oil collected in the separator Compliance from spills/leaks associated Operational and groundwater resource Operational and 28 from the N Y Regional Control must be disposed of by a suitably qualified waste oil contractor. with DWS’s Best with poor housekeeping and decommissioning Low and prevent impact on Decommissioning tailings Practice incorrect management of Phase downstream water Phase pipelines The mine will develop a monitoring programme that defines: a) the Guideline pipeline bursts. users. objectives of the monitoring exercise; b) the water quality compliance Series in terms criteria, guidelines or targets to be used as a basis for assessing quality of integrated and fitness for use; c) the sampling points to be used; d) the collection water and waste method for samples; e) sample storage/preservation procedures; f) management and monitoring.

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable constituents to be analysed for; g) quality control procedures for Water analyses; h) reporting and data storage format. management measures in Surface and ground water monitoring sampling points will be sited to compliance with ensure that adequate baseline information can be collected, both NWA, 1998 and upstream/ upgradient of the mine. During operation, the monitoring GN 704, 1999 points will ensure information is collected to enable the mine to determine its potential impacts to surround water users and to identify problems before they occur, if possible. To ensure consistency in monitoring, a sampling protocol will be prepared and adhered to. This will detail: a) where samples will be taken; b) the frequency of sampling; c) how samples will be taken; d) Surface water how flows will be measured at the time of sampling; e) the preparation and of samples for analysis; f) the range of analysis required; g) the method groundwater of analysis; h) quality control on all aspects of the monitoring monitoring programme; i) how results will be interpreted, stored and reported. quality The people taking the samples, the laboratory carrying out the analysis monitoring. and the people assessing the results will be kept informed of changes Compliance to the sampling protocol. If storm water runoff is not with DWS’s Best managed then erosion can To conserve the An accredited laboratory, with the necessary quality assurance, will Practice Erosion and/or occur along linear Construction, surface water and Construction, carry out analysis of key samples and will have quality control Guideline scouring at the infrastructure. Operational and Local to groundwater resource Operational and 29 Y Y Control measures in place (blanks, standards, duplicates, cation-anion Series in terms

tailings decommissioning regional Low and prevent impact on Decommissioning of integrated pipelines Eroded material can Phase balances etc). This will ensure consistency in monitoring and the downstream water Phase water and waste contribute to pollution of verification and validation of water quality data. users. surface waters. management Should contamination (concentrations exceeding guideline values) be and monitoring. detected, the mine will immediately notify the Regional Director of DWS. The mine will then: a) identify the source of the contamination; Water b) identify, and if necessary implement, measures for the prevention of management this contamination (short and long term); c) determine, and if necessary measures in implement, any remediation measures. compliance with NWA, 1998 and Data from water quality monitoring and flow monitoring will be stored GN 704, 1999 together electronically to enable trend analysis and waste load calculations to be carried out. Surface water and Monitoring of the water quality in the mine workings will take place until groundwater it can be demonstrated that the potential for contamination of the monitoring regional aquifer by poor quality leachate is low. quality monitoring. Compliance with DWS’s Best Pipeline crossing To conserve the Changes to Practice constitutes a Section 21 Construction, surface water and Construction, watercourses Guideline water use. Operational and groundwater resource Operational and 30 from the N Y Local Control Series in terms

decommissioning Low and prevent impact on Decommissioning tailings Inadequate design can lead of integrated Phase downstream water Phase pipelines to flooding of mine or other water and waste users. infrastructure. management and monitoring. Water management measures in compliance with NWA, 1998 and GN 704, 1999

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable

Surface water and groundwater monitoring Potential contaminants quality monitoring. Acid Rock Drainage (ARD) tests indicate non-acid Compliance generating, low heavy metal with DWS’s Best To conserve the Pollution of mobilisation potential and Practice Construction, surface water and Construction, surface waters low salt concentrations. Guideline Operational and Local to groundwater resource Operational and 31 from the N Y Control Series in terms

decommissioning regional Low and prevent impact on Decommissioning Waste Rock Rehabilitation of the dump of integrated Phase downstream water Phase Dump will help minimise rainfall water and waste users. infiltration and assist in management getting water off the dump and monitoring. as quickly as possible, with less chance of picking up Water contaminants. management measures in compliance with NWA, 1998 and GN 704, 1999

Surface water and groundwater monitoring quality Underlying aquifer is monitoring. considered a non-aquifer, Compliance with low transmissitives and with DWS’s Best To conserve the Ground water yields. Construction, Practice surface water and Construction, contamination Operational, Guideline Rehabilitation of the dump Local to groundwater resource Operational and 32 from the N Y decommissioning Control Series in terms will help minimise rainfall regional and prevent impact on Decommissioning Waste Rock and Post-closure High of integrated infiltration and assist in downstream water Phase Dump Phase water and waste getting water of the dump as users. quickly as possible, with management less chance of picking up and monitoring. contaminants. Water management measures in compliance with NWA, 1998 and GN 704, 1999

Surface water and Leads to a loss in MAR. groundwater monitoring Rehabilitation of the dump quality post-closure could enable To conserve the Loss of Construction, monitoring. some runoff to be surface water and Construction, catchment Operational, considered “clean” hence groundwater resource Compliance Operational and 33 reducing N Y decommissioning Regional Control reducing the loss of and prevent impact on with DWS’s Best Decommissioning availability and Post-closure High catchment postclosure. downstream water Practice Phase downstream Phase users. Guideline This would need to be Series in terms confirmed by adequate of integrated surface water monitoring. water and waste management and monitoring.

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SIGNIFICANCE MITIGATION POTENTIAL IMPACT if not mitigated TYPE (modify, ACTIVITY SIZE AND PHASE remedy, COMPLIANCE ASPECTS whether SCALE control, or STANDARD TO BE TIME PERIOD FOR NO. in which impact MITIGATION MEASURES WITH AFFECTED listed or not of stop) ACHIEVED IMPLEMENTATION is anticipated STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Reversible Reversible Probability Probability Significance Significance Irreplaceable loss Irreplaceable Water management measures in compliance with NWA, 1998 and GN 704, 1999

Surface water and groundwater monitoring If the storm water runoff is quality not managed then erosion monitoring. can occur along clean and dirty water drainage Compliance with DWS’s Best systems. To conserve the Construction, Practice Erosion and/or surface water and Construction, Eroded material can Operational, Guideline scouring at the groundwater resource Operational and 34 contribute to pollution of Y Y decommissioning Regional Control Series in terms Waste Rock and prevent impact on Decommissioning surface waters. and Post-closure High of integrated Dump downstream water Phase Phase water and waste users. Post closure maintenance management will be required until the and monitoring. dump and associated storm water drains are considered Water stable and safe. management measures in compliance with NWA, 1998 and GN 704, 1999

7.5.3 Impacts and risks associated with the Millsell - Waterkloof EMPR, 2010

The following information was obtained from the approved Environmental Management Programme Report for Samancor Chrome Limited (Western Chrome Mines): Millsell - Waterkloof Section on various portions of the farm Waterkloof 305 JQ, North West Province, dated 2010 and compiled by M2 Environmental Connections cc.

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Table 72: Impacts and Risks identified including mitigation/management measures included in the Millsell - Waterkloof EMPR, 2010

SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, ACTIVITY SIZE AND PHASE remedy, STANDARD COMPLIANCE ASPECTS whether SCALE control, or TIME PERIOD FOR NO. in which impact MITIGATION MEASURES TO BE WITH AFFECTED listed or not of stop) IMPLEMENTATION is anticipated ACHIEVED STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Altering of geology

By the nature of mining projects To minimise the geology is exploited for the the In compliance target minerals therefore the Care will be taken that no unnecessary ore is mined. destruction of with the Mining impact on the geology as a the geological Underground Ensure that mining is limited to the target mineral only. Rights issued in 1 Geology whole is high and this cannot N Y Operational Site Control strata and to Operational Phase mining terms of the be mitigated. In this project the High High prevent the Ensure that mining is conducted within the approved MPRDA (2002) chrome ore in the middle group unnecessary Mining Right boundary area only and the EMPr. series is the target mineral. Any loss of other minerals that occur in the geology exploited middle group series could be negatively affected.

Adequate support will be provided in the underground Surface subsidence workings to ensure that there is no subsidence above these workings. A professional rock engineer will In compliance There will be no surface with the Mining Operational and design pillar dimensions for underground support to To minimise Underground subsidence above the ensure no subsidence above the workings occurs. Rights issued in Decommissioning 2 Topography underground workings. Y N Decommissioning Site Control impacts on

mining Low terms of the phase Phase High topography Support will be provided in the The mine will monitor subsidence. If subsidence is MPRDA (2002) underground workings to detected, the mine will immediately identify the cause and the EMPr. ensure this. and then implement appropriate measures to prevent further subsidence.

Progressive development of underground mine and extraction of ore Groundwater monitoring During the operational phase (quarterly) and for a long time after closure Drilling and monitoring of boreholes for groundwater the mine acts as a groundwater To prevent Water Operational and Underground Operational level and quality aspects will be undertaken to quantify 3 Groundwater sink. Groundwater will thus flow N Y Local Control groundwater management Decommissioning mining phase impacts from all potential sources and to verify the radially inwards towards the pollution measures in Phase mine and the natural Medium predicted impacts on the groundwater. Medium compliance groundwater flow direction will with NWA, 1998 be increased, decreased, and GN 704, altered or reversed, depending 1999. on the position in the depression cone.

Job creation plays a major role in increasing the economic well Implementation Prevent socio Operational and Socio- Continuation being of employees and their Operational of approved 4 N N Region Enhance Enhancement of positive impact. economic Decommissioning economic of mining dependants. The mining of the Phase Social and impacts. Phase additional mining area will Positive Positive Labour Plan. result in increased job security.

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SIGNIFICANCE MITIGATION SIGNIFICANCE POTENTIAL IMPACT if not mitigated TYPE If mitigated (modify, ACTIVITY SIZE AND PHASE remedy, STANDARD COMPLIANCE ASPECTS whether SCALE control, or TIME PERIOD FOR NO. in which impact MITIGATION MEASURES TO BE WITH AFFECTED listed or not of stop) IMPLEMENTATION is anticipated ACHIEVED STANDARDS listed disturbance through e.g. noise Impact description control measures) Magnitude Magnitude Magnitude Magnitude Reversible Reversible Probability Probability Probability Probability Significance Significance Significance Significance Irreplaceable loss Irreplaceable

Both premature and planned Promotion of diversification in the local communities closure of the project could by investment in small and medium enterprises, have serious impacts on local through advice and encouragement for employees on Implementation Planned and communities reliant on the Prevent socio Operational and how to take responsibility of their futures in their own of approved 5 premature project however; there are a N Y Closure phase Region Control economic Decommissioning hands, and appropriate rehabilitation of the project site Social and closure number of other mines in the High impacts. Phase to enable the grazing potential of the land to be Labour Plan. area that provide a source of exploited post closure of the project. income to the communities in medium - Low the vicinity of the project. Where feasible, relocate employees.

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7.6 Methodology used in determining and ranking potential environmental impacts and risks

7.6.1 Methodology applied in the exiting approved Updated EMPR, 2009

The impacts have been assessed according to the following:

• Nature of the impact, • Extent of the impact, • Duration of the impact, and • Probability of the impact.

Each of the above parameters have been rated, and the impacts classified as follows:

• Low – no/negligible need for mitigatory measures. Rating between 0-6. • Medium – mitigation measures necessary, will not prevent the project from going forward. Rating between 7-12. • High – mitigatory measures necessary, and may prevent the project from going forward. Rating between 13-16.

Table 73: Impact and risk rating methodology

Rating Parameter 0 1 2 3 4

Adjacent Extent None Site specific Regional National area/local

Duration None Short-term Medium-term Long-term Permanent

Medium Low High (Environment Negligible (Environment (Environment altered and altered but altered and Severity None (Environment systems systems systems not altered) temporarily continue to irrevocably cease to function) damaged) function)

Unlikely Possible Probable Definite Probability None (0-10%) (10-50%) (50-90%) (>90%)

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7.6.2 Methodology applied in the exiting approved PGM EMPR, 2011

Table 74: Impact and risk rating methodology

Methodology PROBABILITY / LIKELIHOOD of occurrence of impact Very low: <20% sure of particular fact or likelihood of impact occurring. Low: 20 to 39% sure of particular fact or likelihood of impact occurring. Moderate: 40 to 59% sure of particular fact or likelihood of impact occurring. High: 60 to 79% sure of particular fact or likelihood of impact occurring Very high: 80 to 99% sure of particular fact or likelihood of impact occurring. DURATION of impact EXTENT of impact (spatial scope) Very short: On site < 1 year Local: Short term: Neighbouring properties 1 – 5 years District: Medium term: 0 – 5 km from the site 6– 12 years Regional: Long term: Elias Motsoaledi Local Municipality 13 – 50 years National Irreversible SIGNIFICANCE of impact No impact: There would be no impact at all - not even a very low impact on the system or any of its parts. Very low: Impact would be negligible. In the case of negative impacts, almost no mitigation and/or remedial activity would be needed, and any minor steps, which might be needed, will be easy, cheap and simple. In the case of positive impacts, alternative means would almost all likely to be better, in one or a number of ways, than this means of achieving the benefit. Low: Impact would be of a low order and with little real effect. In the case of negative impacts, mitigation and/or remedial activity would be either easily achieved or little would be required, or both. In case of positive impacts, alternative means for achieving this benefit would likely be easier, cheaper, more effective, less time-consuming, or some combination of these. Moderate: Impact would be real but not substantial within the bounds of those, which could occur. In the case of negative impacts, mitigation and/or remedial activity would be both feasible and fairly easily

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Methodology possible. In the case of positive impacts, other means of achieving these benefits would be about equal in time, cost and effort. High: Impacts of a substantial order. In the case of negative impacts, mitigation and/or remedial activity would be feasible but difficult, expensive, time-consuming or some combination of these. In the case of positive impacts, other means of achieving this benefit would be feasible, but these would be more difficult, expensive, time-consuming or some combination of these. Very high: Of the highest order possible within the bounds of impacts which could occur. In the case of negative impacts, there would be no possible mitigation and/or remedial activity to offset the impact at the spatial or time scale for which it was predicted. In the case of positive impacts, there is no real alternative to achieving the benefit.

7.6.3 Methodology applied in the exiting approved Millsell - Waterkloof EMPR, 2010

Table 75: Impact and risk rating criteria

Criteria Extent Classification of the physical and spatial scale of the impact

The impacted area extends only as far as the activity, such as Footprint footprint occurring within the total site area.

The impact could affect the whole, or a significant portion of the Site site.

The impact could affect the area including the neighbouring farms, Regional the transport routes and the adjoining towns.

The impact could have an effect that expands throughout the National country (South Africa).

Where the impact has international ramifications that extend International beyond the boundaries of South Africa.

Duration The lifetime of the impact that is measured in relation to the lifetime of the proposed development.

The impact will either disappear with mitigation or will be mitigated Short through a natural process in a period shorter than that of the construction phase.

The impact will be relevant through to the end of a construction Short to Medium phase (1.5 years)

The impact will last up to the end of the development phases, Medium where after it will be entirely negated.

The impact will continue or last for the entire operational lifetime Long i.e. exceed 30 years of the development, but will be mitigated by direct human action or by natural processes thereafter.

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Criteria This is the only class of impact, which will be non-transitory. Mitigation either by man or natural process will not occur in such a Permanent way or in such a time span that the impact can be considered transient.

Intensity The intensity of the impact is considered by examining whether the impact is destructive or benign, whether it destroys the impacted environment, alters its functioning, or slightly alters the environment itself. The intensity is rated as

The impact alters the affected environment in such a way that the Low natural processes or functions are not affected.

The affected environment is altered, but functions and processes Medium continue, albeit in a modified way.

Function or process of the affected environment is disturbed to the High extent where it temporarily or permanently ceases.

Probability This describes the likelihood of the impacts actually occurring. The impact may occur for any length of time during the life cycle of the activity, and not at any given time. The classes are rated as follows:

The possibility of the impact occurring is none, due either to the Improbable circumstances, design or experience. The chance of this impact occurring is zero (0 %).

The possibility of the impact occurring is very low, due either to the Possible circumstances, design or experience. The chances of this impact occurring is defined as 25 %.

There is a possibility that the impact will occur to the extent that Likely provisions must therefore be made. The chances of this impact occurring is defined as 50 %.

It is most likely that the impacts will occur at some stage of the Highly Likely development. Plans must be drawn up before carrying out the activity. The chances of this impact occurring is defined as 75 %.

The impact will take place regardless of any prevention plans, and only mitigation actions or contingency plans to contain the effect Definite can be relied on. The chance of this impact occurring is defined as 100 %.

The status of the impacts and degree of confidence with respect to the assessment of the significance must be stated as follows:

• Status of the impact - A description as to whether the impact would be positive (a benefit), negative (a cost), or neutral. • Degree of confidence in predictions - The degree of confidence in the predictions, based on the availability of information and specialist knowledge.

Other aspects to take into consideration in the specialist studies are:

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• Impacts should be described both before and after the proposed mitigation and management measures have been implemented. • All impacts should be evaluated for the full-lifecycle of the proposed development, including construction, operation and decommissioning. • The impact evaluation should take into consideration the cumulative effects associated with this and other facilities which are either developed or in the process of being developed in the region. • The specialist studies must attempt to quantify the magnitude of potential impacts (direct and cumulative effects) and outline the rationale used. Where appropriate, national standards are to be used as a measure of the level of impact.

Determination of Significance – Without Mitigation Significance is determined through a synthesis of impact characteristics as described in the above paragraphs. It provides an indication of the importance of the impact in terms of both tangible and intangible characteristics. The significance of the impact “without mitigation” is the prime determinant of the nature and degree of mitigation required. Where the impact is positive, significance is noted as “positive”. Significance is rated on the following scale:

Table 76: Determination of Significance – Without Mitigation

Determination of Significance – Without Mitigation No significance The impact is not substantial and does not require any mitigation action.

Low The impact is of little importance, but may require limited mitigation.

The impact is of importance and is therefore considered to have a negative Medium impact. Mitigation is required to reduce the negative impacts to acceptable levels.

The impact is of major importance. Failure to mitigate, with the objective of High reducing the impact to acceptable levels, could render the entire development option or entire project proposal unacceptable. Mitigation is therefore essential.

Determination of Significance – With Mitigation Determination of significance refers to the foreseeable significance of the impact after the successful implementation of the necessary mitigation measures. Significance with mitigation is rated on the following scale:

Table 77: Determination of Significance – With Mitigation

Determination of Significance – With Mitigation No significance The impact will be mitigated to the point where it is regarded as insubstantial.

Low The impact will be mitigated to the point where it is of limited importance.

The impact is of importance, however, through the implementation of the correct Low to Medium mitigation measures such potential impacts can be reduced to acceptable levels.

Medium Notwithstanding the successful implementation of the mitigation measures, to reduce the negative impacts to acceptable levels, the negative impact will remain

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Determination of Significance – With Mitigation of significance. However, taken within the overall context of the project, the persistent impact does not constitute a fatal flaw.

The impact is of major importance but through the implementation of the correct Medium to High mitigation measures, the negative impacts will be reduced to acceptable levels.

The impact is of major importance. Mitigation of the impact is not possible on a cost effective basis. The impact is regarded as high importance and taken within High the overall context of the project, is regarded as a fatal flaw. An impact regarded as high significance, after mitigation could render the entire development option or entire project proposal unacceptable.

For each impact under scrutiny, a scaled weighting factor is attached to each respective impact. The purposes of assigning such weights serve to highlight those aspects considered the most critical to the various stakeholders and ensure that each specialist’s element of bias is taken into account. The weighting factor also provides a means whereby the impact assessor can successfully deal with the complexities that exist between the different impacts and associated aspect criteria.

Table 78: Rating criteria

Weighting Significance Extent Duration Intensity Probability Factor Rating (SR) (WF) 0- Footprint 1 Short 1 Low 1 Probable 1 Low 1 Low 19

Short to Low to Low to 20- Site 2 2 2 Possible 2 2 medium medium medium 39

40- Regional 3 Medium 3 Medium 3 Likely 3 Medium 3 Medium 59

Highly Medium Medium 60- National 4 Long 4 4 4 4 likely to High to High 79

80- International 5 Permanent 5 High 5 Definite 5 High 5 High 100

Mitigation Efficiency (ME) Significance Following Mitigation (SFM)

High 0,2 Low 0-19

Medium to High 0,4 Low to medium 20-39

Medium 0,6 Medium 40-59

Low to Medium 0,8 Medium to High 60-79

Low 1,0 High 80-100

Simply, such a weighting factor is indicative of the importance of the impact in terms of the potential effect that it could have on the surrounding environment. Therefore, the aspects considered to have a relatively high value will score a relatively higher weighting than that which is of lower importance.

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Identifying the Potential Impacts without Mitigation Measures (WOM) Following the assignment of the necessary weights to the respective aspects, criteria are summed and multiplied by their assigned weightings, resulting in a value for each impact (prior to the implementation of mitigation measures).

Significance Rating (WOM) = (Extent + Intensity + Duration + Probability) x Weighting Factor

Identifying the Potential Impacts with Mitigation Measures (WM) In order to gain a comprehensive understanding of the overall significance of the impact, after implementation of the mitigation measures, it was necessary to re-evaluate the impact.

Mitigation Efficiency (ME) The most effective means of deriving a quantitative value of mitigated impacts is to assign each significance rating value (WOM) a mitigation effectiveness (ME) rating. The allocation of such a rating is a measure of the efficiency and effectiveness, as identified through professional experience and empirical evidence of how effectively the proposed mitigation measures will manage the impact.

Thus, the lower the assigned value the greater the effectiveness of the proposed mitigation measures and subsequently, the lower the impacts with mitigation.

Significance Rating (WM) = Significance Rating (WOM) x Mitigation Efficiency

Significance Following Mitigation (SFM) The significance of the impact after the mitigation measures are taken into consideration. The efficiency of the mitigation measure determines the significance of the impact. The level of impact is therefore seen in its entirety with all considerations taken into account. 7.7 Positive and negatives that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and community affected

As mentioned previously, Glencore: Waterval Mine is an existing operational mine. No alternatives are therefore applicable to the mine. This EIAR / EMPr serves the purpose of containing consolidated information as per Waterval Mine’s various mining rights granted and previous EMPr’s compiled, and thus forms part of an amendment application. Therefore, the comparison of positives and negatives of a proposed activity and alternatives is not applicable, in this case. 7.8 Possible mitigation measures that could be applied and the level of risk

The impact management measures and level of risk have been included under Section 7.5 of Part A. Table 79 below provides for a summary of the issues and concerns as raised by affected parties and an assessment 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.

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Table 79: Summary of issues and concerns raised by I&Aps

Concerns as raised by affected parties Mitigation measures or site alternative

Refer to Section 7.3 (Part A)

7.9 Motivation where no alternative sites were considered

As mentioned previously, Glencore: Waterval Mine is an existing operational mine and therefore no alternative sites could be considered. This EIAR / EMPr serves the purpose of containing consolidated information as per Waterval Mine’s various mining rights granted and previous EMPr’s compiled, and thus forms part of an amendment application. 7.10 Final site layout plan

The final site layout plan is presented in Figure 5. Refer also to Annexure B.

8 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

All impacts and risks as identified are contained within Section 7.5 (Impacts and risks identified). As further provided is 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 and risks of the activities were identified through consultation with the applicant regarding the activities undertaken, as well as by means of GIS data and spatial tools. Existing documentation was reviewed and site visits were also conducted for orientation purposes and to understand the nature of the activities against the baseline environment of the area.

A number of specialist studies and monitoring programmes (as initiated by Glencore) have been conducted previously (some of which were conducted recently). Since Glencore: Waterval Mine is an existing operational mine, information as contained within such specialist studies were used for inclusion into this EIAR / EMPr as baseline information and / or for the assessment of environmental impacts. Such studies include the following:

• Natural Scientific Services CC. June 2015. Biodiversity Assessment Report. • Agricultural Research Council. November 2007. Soil Investigation in Waterval Area. • Natural Scientific Services CC. April 2015. Land Function Analysis – Waterval. • Aquatico Scientific (Pty) Ltd. January 2018, February 2018 and March 2018. Waterval Mine - Monthly Water Quality Reports.

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• Clean Stream Biological Services (Pty) Ltd. April 2015. Glencore Chrome RTB (Merafe) – Kroondal; Biomonitoring of the Hex River catchment. • Groundwater Complete. December 2014. Glencore Chrome, Rustenburg area - Annual report on groundwater monitoring results for 2014. • Clean Stream Groundwater Services. May 2009. Xstrata Alloys South Africa (Pty) Ltd: Report on Geohydrological Investigation as part of the EMPR Amendment for the proposed Waterval Chrome Opencast Mine and tailings facility. • National Occupational Health & Safety Consultants. January 2015 to June 2015. Fallout Dust Sample Reports. • Ashreq. July 2012. Report on Environmental Noise Monitoring Waterval West Mine. • J van Schalkwyk. 2009. Heritage Impact Assessment for the Proposed Tailings Facility, Waterval Mine, Rustenburg Municipal District, North West Province.

An assessment of each identified potentially significant impact and risk is provided in Section 9 below. The methodology applied in assessing and ranking the impacts and risks is described in Section 7.6.

9 Assessment of each identified potentially significant impact and risk

Refer to the full risk assessment and mitigation measures table provided in Section 7.5 (Part A) above.

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10 Summary of specialist reports

Table 80: Recommendations made by specialists

Specialist recommendations that Reference to applicable have been included in section of report where List of specialist studies Recommendations of specialist reports the EIA report specialist recommendations have (Mark with an X where been included applicable) • Ensure persistence of Half-collared Kingfisher on site by:

‹ Conserving the physical habitat integrity of the Hex River.

Natural Scientific Services CC. ‹ Conserving the water quality of the Hex River. Refer to the Risk June 2015. Biodiversity X Assessment. Assessment Report. • Minimise chromium toxicity on fauna and downstream aquatic ecosystems. • Minimise habitat loss, degradation and fragmentation. • Minimise sensory disturbance of fauna

• Care should be taken, wherever possible, not to include significant amounts of underlying rock in the soil fraction. • The soil stockpile should not be higher than 2 metres, and Agricultural Research Council. lower than this if at all possible. Refer to the Risk November 2007. Soil X • Assessment. Investigation in Waterval Area. Before being rehabilitated, the soil should not be stored for more than a period of 2 years, and shorter than this if possible. “Cut and fill” rehabilitation practices are recommended.

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Specialist recommendations that Reference to applicable have been included in section of report where List of specialist studies Recommendations of specialist reports the EIA report specialist recommendations have (Mark with an X where been included applicable) • When the soil is rehabilitated, it should immediately be irrigated, fertilized and re-vegetated with a mixture of species that are native to the area. Expert advice from a suitable specialist as to species composition should be obtained.

Natural Scientific Services CC. • Implement a plant alien invasive eradication programme at Refer to the Risk April 2015. Land Function X Waterval Mine. Assessment Analysis – Waterval.

Aquatico Scientific (Pty) Ltd. January 2018, February 2018 • No recommendations provided. N/A N/A and March 2018. Waterval Mine - Monthly Water Quality Reports

Clean Stream Biological Services • It is recommended to continue with the biomonitoring (Pty) Ltd. April 2015. Glencore Refer to the Risk Chrome RTB (Merafe) – programme on a bi-annual schedule and with toxicity testing X Assessment Kroondal; Biomonitoring of the on a quarterly schedule. Hex River catchment.

Additional boreholes are required for source monitoring at Kroondal Mine (to replace demolished boreholes) because the Groundwater Complete. December 2014. Glencore impact from (potential/conceptual) pollution sources cannot be Refer to the Risk Chrome, Rustenburg area - X quantified from the few existing boreholes. It is recommended Assessment Annual report on groundwater monitoring results for 2014. that the monitoring program be re-evaluated to ensure that all sources are covered adequately.

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Specialist recommendations that Reference to applicable have been included in section of report where List of specialist studies Recommendations of specialist reports the EIA report specialist recommendations have (Mark with an X where been included applicable) Clean Stream Groundwater Services. May 2009. Xstrata • Mitigation measures were proposed by the specialist as part Alloys South Africa (Pty) Ltd: of the risk assessment undertaken during the study. These Report on Geohydrological Refer to the Risk X Investigation as part of the EMPR mitigation measures were used in the compilation of the Risk Assessment Amendment for the proposed Assessment accompany this EMPr. Waterval Chrome Opencast Mine and tailings facility.

National Occupational Health & Safety Consultants. January No recommendations provided. N/A N/A 2015 to June 2015. Fallout Dust Sample Reports.

Ashreq. July 2012. Report on Environmental Noise Monitoring No recommendations provided. N/A N/A Waterval West Mine. • Known sites should be clearly marked in order that they can be avoided during construction activities. • The contractors and workers should be notified that J van Schalkwyk. 2009. Heritage Impact Assessment for the archaeological sites might be exposed during the Proposed Tailings Facility, Refer to the Risk construction work. X Waterval Mine, Rustenburg Assessment Municipal District, North West • Should any heritage artefacts be exposed during excavation, Province. work on the area where the artefacts were discovered, shall cease immediately and the Environmental Control Officer shall be notified as soon as possible;

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Specialist recommendations that Reference to applicable have been included in section of report where List of specialist studies Recommendations of specialist reports the EIA report specialist recommendations have (Mark with an X where been included applicable) • All discoveries shall be reported immediately to a museum, preferably one at which an archaeologist is available, so that an investigation and evaluation of the finds can be made. Acting upon advice from these specialists, the Environmental Control Officer will advise the necessary actions to be taken; • Under no circumstances shall any artefacts be removed, destroyed or interfered with by anyone on the site; and • Contractors and workers shall be advised of the penalties associated with the unlawful removal of cultural, historical, archaeological or palaeontological artefacts, as set out in the National Heritage Resources Act (Act No. 25 of 1999), Section 51. (1).

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11 Environmental impact statement 11.1 Summary of the key findings of the environmental impact assessment

A detailed description of the methodology utilised to determining the environmental impacts and their respective probability, magnitude and severity is provided in Section 7.6 above.

Significant environmental impacts During the risk assessment process it was found that the activities at Waterval Mine would result in a limited number of impacts with a “High” severity rating, and these impacts include impacts on geology, land use and capability, flora, surface and groundwater and socio-economic aspects (influx of job seekers). The impact on geology will be permanent in nature and is inevitable consequence of mining. The impact will however be local (within mining rights area) and control mechanisms (to limit the disturbance of geological strata) will be implemented. The operation of mine infrastructure, the tailings dams and the waste rock dumps has resulted in the disturbance of soils and vegetation, and in turn resulted in a change in land use (from agriculture to mining). The tailings dams and waste rock dumps will remain after closure, permanently altering the land use and land capability of the area. Remediation measures will be implemented as far as practically possible to return the land to an agreed end land use. Further, protected species have been identified at the Waterval Mine, specifically the Water West Mine.

Contaminated surface water runoff from all operational areas at Waterval Mine may enter and pollute the surrounding environment. In addition, the discharge of poor-quality groundwater into the Hex River may result in pollution of this surface water resource. Storm water management measures will be implemented to prevent the release of affected water to the environment and control measures will be put in place to ensure water discharged to the Hex River is of acceptable standards.

During the closure phase when all pumping has ceased, the water in the shafts may rise towards the Environmentally Critical Level (“ECL”) where, if contaminated and affected, may pollute aquifers or surface drainages. Control measure will be implemented to maintain the water level, within the basin, below the ECL. Monitoring will also be implemented to determine the quality of the groundwater and provide a trend analysis overtime.

During the risk assessment process, it was further determined that impacts with a “High" severity rating are likely to occur on socio-economic aspects. The mining activities at Waterval Mine may lead to an influx of jobseekers to the area. As previously described, the mine currently employees approximately 372 employees. Control measures will be implemented to limit impact of the influx of jobseekers (refer to the Risk Assessment).

Several other impacts on the bio-physical and socio-economic environment have been identified and assessed, and include impacts on the following:

• Soil.

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• Flora and fauna • Sensitive landscapes. • Air quality. • Noise. • Heritage. • Visual aspects.

Refer also to Section 11.3 below for a summary of the negative and positive environmental impacts, after mitigation. 11.2 Final site map

The final site layout plan is presented in Figure 5. Refer also to Annexure B.

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11.3 Summary of the positive and negative implications and risks of the proposed activity

11.3.1 Summary of the positive and negative implications and risks of the Updated EMPR, 2009

Table 81: Summary of implications and risks, post-mitigation.

No. Aspect affected Potential impact Significance 1 Geology Alteration of the geology due to underground mining and possible opencast mining Hight

2 Alteration of topography due to construction of mine infrastructure Medium

3 Topography Alteration of topography due to construction of tailings dam & waste rock dumps, stockpiles etc. Medium

4 Removal of mine infrastructure and rehabilitation will alter the topography. Low

4 Compaction and soil degradation due to construction of infrastructure, concrete foundations, roads etc Medium

5 Erosion and soil loss due to no stormwater controls around dumps. Medium

6 Compaction and soil degradation due to construction of stockpiles, waste dumps and slimes dams. Medium Soil 7 Loss of soil fertility due to construction, compaction and pollution potential Medium

8 Loss of soil structure due to removal of topsoil Medium

9 Chemical contamination due to pipeline spillages / breakdowns / diesel spillages / oil spillages Medium

10 Disturbance of soils and vegetation due to Construction of mining infrastructure. Medium

11 Land capability and land use Disturbance of soils and vegetation due to construction of tailings dams and waste rock dumps. High

12 Change of land use due to the operation of the mine High

13 Loss of ecosystems due to the removal of natural vegetation for plant, shaft, road and tailings dams construction. Medium

14 Degradation of surrounding ecosystems due to the spillages and contamination Medium Biodiversity 15 Dust covering vegetation due to trucks and equipment on dirt roads as well as blasting. Medium

16 Degradation of surrounding ecosystems due to the propagation of alien invaders Medium

17 Surface water Pollution due to polluted groundwater recharge into surface resources Medium

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No. Aspect affected Potential impact Significance 18 Chemical and physical contamination due to flash floods resulting in overflow of contaminants. Medium

19 Physical contamination as a result of increased silt load due to dust deposition Medium

20 Physical contamination as a result of overflow of the return water dam Low

21 Chemical contamination as a result of nitrification due to explosives. Medium

22 Flow alteration as a result of the of waste rock dumps in non-perennial tributary's floodline. High

23 Physical contamination due to uncontained run-off from waste rock dump and tailings dams Medium

24 Chemical contamination due to seepage of AMD from stockpiles and tailings dams Medium

25 Change in water balance, loss of yield as a result of groundwater abstraction and dewatering Medium Groundwater 26 Chemical contamination as a result of nitrification from blasting activities Medium

27 Chemical contamination as a result of seepage from contaminated soils & dumps Medium

28 Air pollution from vehicular emissions Medium

29 Dust pollution from haul roads Medium

30 Dust pollution from ore transfer points, stockpiles, crushing & screening Medium Air Quality 31 Dust pollution from topsoil stockpile, ore stockpiles, waste rock dump Medium

32 Dust pollution from tailings dam Medium

33 Dust pollution from transport of ore Medium

34 Noise generation from machinery, screens & crushers, pumps, pipeline operation Medium

35 Noise generation from conveyor belt siren Medium

36 Noise and vibration Vibration from blasting activities. Medium

37 Noise generation from vehicular traffic Medium

38 Noise generation from rehabilitation activities Medium

39 Traffic The impacts that may arise from vehicular traffic are detailed in the ‘air pollution’ and ‘noise, vibration and shock’ sections.

40 Heritage resources No heritage resources have been identified.

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No. Aspect affected Potential impact Significance 41 Sensitive landscapes The Hex River (and its associated riparian zone and habitats) has been classified as a sensitive area. Refer to surface water.

42 Aesthetics altered due to the construction of mine infrastructure. Medium Visual aspects 43 Aesthetics altered due to the construction of tailings dams, stockpiles, waste rock dumps & topsoil stockpile. Medium

44 Conflict may result from the creation of varying wealth classes Medium

45 Increased unemployment as a result of influx of job seekers into the local area. Medium

46 Conflict may arise due to an influx of job seekers into the local area. Medium

47 Increased spread of communicable diseases due to an influx of job seekers into the local area and disruption of family units. Medium

48 Loss of agricultural and grazing land Medium

49 Socio-economic Skills transfer to employees Positive

50 Job creation Positive

51 Increase in local employment Positive

52 Income generation Positive

53 Increase in economic diversification Positive

54 Community upliftment Positive

55 Energy consumption Loss of renewable resources due to energy uses for construction, mining & decommissioning activities. High

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11.3.2 Summary of the positive and negative implications and risks of the PGM EMPR, 201145

Table 82: Summary of implications and risks, pre-mitigation.

No. Aspect affected Potential impact Significance The tailings dam will be used to store potentially chemically dangerous substances (chrome). 1 Geology The probability exists that the chrome may seep into the underlying rock if the necessary preventative measures are not Very Low implemented

The infrastructure related to the tailings dam will have a definitive impact on the topography. 2 Topography Change in landform: Medium Topographical changes can be expected from the waste rock dump and tailings dam.

Soil Erosion:

3 Although the soils are not highly erodible (there is no significant increase in clay from subsoil to topsoil, while there are large Low areas with rock outcrops acting as stabilisers), this impact is potentially significant due to the topography of the area (increased speed of water from slopes) and the nature of rainfall in the area (mostly thundershowers).

Soil Compaction: Structures such as the establishment of roads and the hauling of material to the plant cause compaction of soil. The process 4 Low Soil during which the integrity of the soil structure is altered from its natural state is called compaction. This change may result in reduced water holding capacity and ability of the soil to release this water to plants. It could therefore further lead to the loss of a growth medium and the plant alienation of a particular surface area

Soil Contamination: 5 Possible contaminants and their impacts will depend on the nature of the seepage or loss, as well as the buffering capacity High of the soil. However, in severe cases there can be a sterilisation effect on the soil and a subsequent loss of land capability.

6 In the process of removing topsoil the soil layers are mixed and the structure may be disturbed. Low

Temporary loss of land capability to support grazing: The land capability on the new tailings dam will be lost. 7 Land capability The land capability on the haul roads and plant area is also alienated until the area is rehabilitated. Moderate Prior to mining the land was used mostly as a wilderness area. After rehabilitation the land will still be able to be used as a wilderness area.

45 The impacts, risks and mitigations provided in this section were extracted from the original approved EMPr (dated 2011). The approved EMPr provided for the rating of each respective risk and impact, however, there is no rating of the risks and impacts for post-mitigation.

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No. Aspect affected Potential impact Significance Change in land use: Land use impacts are integrally linked with soils and land capability, along with the visual and socio-economic aspects. 8 Land use Low The demarcated mining areas lost their original land use (wilderness). This plus the proposed new shaft and waste rock dump area will be alienated for agricultural purposes. The rest of the area will keep its original capability.

Vegetation clearance, disturbance and trampling: Species diversity can be negatively influenced by the fragmentation of vegetation communities. 9 Denuded areas and invasion of invaders and exotic species may follow due to the disturbed soil. High Large areas of undisturbed vegetation will remain and they should serve as reference for vegetation success and source of Vegetation natural plant material and seed. Dust coverage of plants 10 Most plants are known to be resistant to dust pollution, which normally washes away after a small downpour. This may Low become a problem during extended dry periods or when excessive dust is present.

11 Habitat change, loss of sensitive species, spread of alien and invasive species Moderate

12 Wildlife habitat destruction / change / disturbance Moderate Wildlife 13 Injury and killing of fauna Low

PM 10 dust pollution: 14 Air quality Low The IAP’s raised this aspect and the dust outfall needs to be monitored.

Excessive noise pollution: The mine is located in a rural environment with the nearest residences many kilometres away. Excessive noise may have 15 Noise an impact on the mine residences. High The impact will also be of importance regarding the direct worker environment that should adhere to the requirements in terms of the Mine Health and Safety Act.

16 Archaeological and cultural N/A N/A

17 Sensitive landscapes N/A N/A

The visibility of the waste rock dump and plant were identified as specific problem areas by IAP’s. 18 Visual Impacts High Lights from the mine are also very visible at night time.

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No. Aspect affected Potential impact Significance Increase in Socio – economic activity at local level. Unemployment is present within the communities. 19 Socio Economic Positive The mining and agricultural sectors employ most of the employed population. The company’s Social investment programme as listed in the Social and Labour plan should assist the communities.

Impact of activities on I& AP’s A portion of the expected expenditure for the project will go to the community. This will also bring long-term employment and 20 Interested and Affected Parties Moderate financial spin-offs. Noise, traffic and dust could become a nuisance factor.

Potential contaminants are most likely to arise from the transport of tailings slurry or return water. The dirty water will be reused in the process to minimise the need for additional make-up water requirements. 21 Low An additional risk is the failure of the tailings dam or return water dam, where quality is likely to be poor. Design of the tailings dam can ensure that these impacts are adequately managed.

The Bushveld Complex Aquifer is considered a non-aquifer with low transmissivities and yields. 22 The Dam will not be placed in close proximity to any faults. High Monitoring will be essential to establish whether or not significant contamination is occurring.

Due to the ephemeral nature of the stream, downstream water users are not solely reliant on the surface water. 23 The impact cannot be mitigated, except by minimising the infrastructure footprints. High In a stressed catchment all contributions are important. Water resources Water infiltration will generate a hydraulic head under the dam which will cause water to move away from the dam. 24 Low The tailings dam is located some distance from any such feature and thus no such impact is foreseen here.

If storm water runoff is not managed then erosion can occur along clean and dirty water drainage systems. 25 Eroded material can contribute to the pollution of surface waters. High Clean water diversion release points are particularly vulnerable.

Drainage lines in the area of the tailings dam will be affected and thus constitutes a Section 21 water use. 26 High Only real significance relates to loss of catchment, as discussed earlier.

Potential contaminants 27 Pollution only likely to arise from spills/leaks associated with poor housekeeping and incorrect management of pipeline Low bursts.

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No. Aspect affected Potential impact Significance Potential contaminants 28 Pollution only likely to arise from spills/leaks associated with poor housekeeping and incorrect management of pipeline Low bursts.

If storm water runoff is not managed then erosion can occur along linear infrastructure. 29 Low Eroded material can contribute to pollution of surface waters.

Pipeline crossing constitutes a Section 21 water use. 30 Low Inadequate design can lead to flooding of mine or other infrastructure.

Potential contaminants Acid Rock Drainage (ARD) tests indicate non-acid generating, low heavy metal mobilisation potential and low salt 31 concentrations. Low Rehabilitation of the dump will help minimise rainfall infiltration and assist in getting water off the dump as quickly as possible, with less chance of picking up contaminants.

Underlying aquifer is considered a non-aquifer, with low transmissitives and yields. 32 Rehabilitation of the dump will help minimise rainfall infiltration and assist in getting water of the dump as quickly as possible, High with less chance of picking up contaminants.

Leads to a loss in MAR. Rehabilitation of the dump post-closure could enable some runoff to be considered “clean” hence reducing the loss of 33 High catchment postclosure. This would need to be confirmed by adequate surface water monitoring.

If the storm water runoff is not managed then erosion can occur along clean and dirty water drainage systems. 34 Eroded material can contribute to pollution of surface waters. High Post closure maintenance will be required until the dump and associated storm water drains are considered stable and safe.

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11.3.3 Summary of the positive and negative implications and risks of the Millsell - Waterkloof EMPR, 2010

Table 83: Summary of implications and risks, post-mitigation.

No. Aspect affected Potential impact Significance

Altering of geology

1 Geology By the nature of mining projects the geology is exploited for the target minerals therefore the impact on the geology as a High whole is high and this cannot be mitigated. In this project the chrome ore in the middle group series is the target mineral. Any other minerals that occur in the exploited middle group series could be negatively affected.

Surface subsidence 2 Topography There will be no surface subsidence above the underground workings. Support will be provided in the underground workings Low to ensure this.

Progressive development of underground mine and extraction of ore

3 Groundwater During the operational phase and for a long time after closure the mine acts as a groundwater sink. Groundwater will thus Medium flow radially inwards towards the mine and the natural groundwater flow direction will be increased, decreased, altered or reversed, depending on the position in the depression cone.

Job creation plays a major role in increasing the economic well being of employees and their dependants. The mining of the 4 Positive additional mining area will result in increased job security. Socio-economic Both premature and planned closure of the project could have serious impacts on local communities reliant on the project 5 however; there are a number of other mines in the area that provide a source of income to the communities in the vicinity of Low - medium the project.

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12 Proposed impact management outcomes for inclusion into the EMPr

Based on the assessment and where applicable the recommendations from specialist reports, the table below summarises the impact management outcomes for the proposed project for inclusion in the EMPr as well as for inclusion as conditions of authorisation.

Table 84: Impact management objectives and the impact management outcomes

Environmental Summary of impact management Objective aspect outcome To minimise the destruction of the Monitoring of mineral resources and Geology geological strata and to prevent the reserves. unnecessary loss of geology.

Monitor the mining and related To minimise the extent of alteration of Topography activities in relation to the footprint localised topography. area of the mine.

To prevent the loss of soil and soil fertility Site inspection and monitoring Soil during the mining and mining activities. programs

To prevent the loss of soil and soil fertility Soil erosion during decommissioning and Rehabilitation monitoring programme. rehabilitation activities.

Returning the land use of the area to To restore the land use and land Land use and the specifics as agreed upon during capability to the agreed upon end land capability the discussions with the DMR and the use. municipalities.

Implementation of a declared weed Prevent the destruction of vegetation and and invader plant species subsequent impacts on species of Flora management programme. conservation concern and protected species. Site inspection and monitoring programme

Implementation of a declared weed and invader plant species management programme. Prevent the destruction of vegetation and Flora subsequent impacts on plant biodiversity. Site inspection and monitoring programme Implement rehabilitation plan

To minimise the destruction of faunal Implementation of access control Fauna habitat and prevent fragmentation as far measures and training programmes as possible.

Implementation and upgrading of To prevent quality deterioration of storm water management programme Surface water surface water quality and prevent impact and infrastructure. on catchment yield. Surface water monitoring programme.

To prevent quality deterioration of Groundwater Groundwater monitoring programme. groundwater resource.

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Environmental Summary of impact management Objective aspect outcome To prevent quantity and quality deterioration of groundwater resource.

To minimise the extent of disturbance of the aquifer

Control and mitigation measures will be Sensitive implemented to minimise the impact on Surface water monitoring programme. Landscapes the Hex River.

Prevent the deterioration of air quality Air quality and indirect effects on floral, faunal and Air quality monitoring programme. human health

Prevent and mitigate against the effects of noise on sensitive receptors (including Noise Noise monitoring programme. employees and surrounding communities and towns).

Prevent visual intrusions on sensitive Implementation of control measures to Visual aspects receptors mitigate against visual intrusions.

If any findings of archaeological Sites of importance are made, activities will be archaeological Prevent the destruction of National stopped immediately with such and cultural Heritage Resources findings reported to the South African importance Heritage Resources Agency (SAHRA)

Enhance the positive impact on the Sourcing of employees from the local socio-economic aspects. community and surrounding areas.

Sourcing of employees from the local Socio- To mitigate the effects of the influx of job community and surrounding areas. economic seekers to the area. aspects Implementation of measures indicated in the SLP.

To prevent and / or limit public exposure Implement control measures both on- to unacceptable health risks. site and off-site.

13 Final proposed alternatives

As described previously, Glencore: Waterval Mine is an existing operational mine and therefore no alternative sites could be considered. This EIAR / EMPr serves the purpose of containing consolidated information as per Waterval Mine’s various mining rights granted and previous EMPr’s compiled, and thus forms part of an amendment application.

14 Aspects for inclusion as conditions of the authorisation

Section 26 of the EIA Regulations GNR. 982, dated 04 December 2014 specifies the requirements and content of an environmental authorisation. The content requirements of the environmental authorisation

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is described in Table 85 below, and where applicable, a reference to the section as to where the requirement has been addressed as part of the EIR/:EMPr has been included.

Table 85: Content of environmental authorisation as per Section 26 of the EIA Regulation GNR.982, dated 04 December 2015.

Reference to Ref. No. Requirement as per Section 26 EIR/EMPr (where applicable) the name, address and contact details of the person to Refer to Section 1 of a whom the environmental authorisation is issued Part A for details.

Section 4 of Part A b a description of the activity that is authorised; for details.

c a description of the location of the activity, including

the 21 digit Surveyor General code of each cadastral land Section 2 of Part A (i) parcel, for details.

Section 2 of Part A (ii) where available, the physical address or farm name, for details.

where the required information in sub-regulation (i) and (iii) (ii) is not available, the coordinates of the boundary of the - property or properties,

Refer to Error! a plan which locates the proposed activity or activities Reference source (iv) authorised at an appropriate scale, or, if it is- not found. for the plan.

a linear activity, a description and coordinates of the (aa) - approved corridor of the activity or activities; or

on land where the property has not been defined, the (bb) coordinates of the area within which the activity is to be - undertaken;

the conditions subject to which the activity may be d - undertaken, including conditions determining-

the period within which commencement must occur, which period may not exceed 10 years and may not be As determined by the (i) extended beyond such 10 year period, unless the competent authority. process to amend the environmental authorisation contemplated in regulation 32 is followed;

the period for which the environmental authorisation is granted and the date on which the activity is deemed to As determined by the (ii) have been concluded, where the environmental competent authority. authorisation does not include operational aspects;

a distinction between the portions of the environmental authorisation that deal with operational and non- As determined by the (iii) operational aspects respectively and the respective competent authority. periods for which the distinct portions of the environmental authorisation is granted, where the

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Reference to Ref. No. Requirement as per Section 26 EIR/EMPr (where applicable) environmental authorisation contains operational and non- operational aspects;

requirements for the avoidance, management, mitigation, monitoring and reporting of the impacts of the As determined by the (iv) activity on the environment throughout the life of the competent authority. activity. additional to those contained in the approved EMPr, and where applicable the closure plan; and

the frequency of auditing of compliance with the conditions of the environmental authorisation and of compliance with the EMPr, and where applicable the closure plan, in order to determine whether such EMPr Refer to Section 1.8 and closure plan continuously meet mitigation and Section 1.11 of requirements and addresses environmental impacts, Part B for details and e taking into account processes for such auditing / or as determined by prescribed in terms of these Regulations: provided that the competent the frequency of the auditing of compliance with the authority. conditions of the environmental authorisation and of compliance with the EMPr may not exceed intervals of five years;

Refer to Section 1.11 the frequency of submission of an environmental audit of Part B details and / report to the competent authority, including the timeframe f or as determined by within which a final environmental audit report must be the competent submitted to the competent authority; authority.

the frequency of updating the EMPr, and where applicable the closure plan, and the manner in which the As determined by the g updated EMPr and closure plan will be approved, taking competent authority. into account processes for such amendments prescribed in terms of these Regulations;

a requirement that the environmental authorisation, EMPr, any independent assessments of financial provision for rehabilitation and environmental liability, h closure plans, where applicable, audit reports including - the environmental audit report contemplated by regulation 34, and all compliance monitoring reports be made available for inspection and copying-

(i) at the site of the authorised activity; -

(ii) to anyone on request; and -

where the holder of the environmental authorisation has (iii) - a website, on such publicly accessible website; and

any relevant conditions which the competent authority As determined by the i deems appropriate. competent authority.

Furthermore, should this EMPr be approved, the following conditions should be included and / or taken into account:

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• The mine should remain in full compliance with the requirements of the EMP and with all regulatory requirements. • The EMP should be implemented by qualified environmental personnel who have the competency and credibility to interpret the requirements of the EIA and the EMP. Such persons must be issued with a written mandate by Glencore Alloys management to provide guidance and instructions to employees and contractors. • Stakeholder engagement must be maintained during the phases of the mining operation.

15 Description of any assumptions, uncertainties and gaps in knowledge

In terms of Section 3(p) of Appendix 3 to the EIA Regulations GN 982, the Environmental Impact Assessment Practitioner (“EAP”) must provide a description of any assumptions, uncertainties and gaps in knowledge upon which the impact assessment has been based. The table below provides the assumptions and limitations applicable to the various specialist assessments.

Table 86: Specialist assumptions and limitations

Specialist Assumptions and limitations It is important to note that the absence of species on site does not conclude that the species is not present at the site. Reasons for not finding certain species during the field surveys may be due to:

• The small, fragmented nature of the site and disturbances from past and current mining Operations. • The short duration of fieldwork and lack of significant rainfall events during the fieldwork period. • The cryptic nature of certain species or simply lack of species Natural Scientific Services presence. Some animal species, which are uncommon, small, CC. June 2015. Biodiversity migratory, secretive or otherwise difficult to find may not have been Assessment Report. detected even though they were potentially present on site. • Safety and Security were an issue for Waterval North and therefore camera and live trapping was only performed in natural / semi-natural areas on Waterval West. • Some plant species, which are small, have short flowering times, rare or otherwise difficult to detect may not have been detected even though they were potentially present on site. • Anthropogenic influences such as the cattle grazing, have affected plant species identification (on emergences, a number of these

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Specialist Assumptions and limitations species are grazed) in a large portion of the northern Waterval study area. • Mapping the study area was based on Aerial Imagery and groundtruthing. NSS has extensive knowledge in mapping vegetation via aerial imagery, however, inaccuracies can occur due to:

o The scale at which the mapping was performed; o The date and season of the aerial imagery; and o The interpretation of habitat/communities by the capturer.

• As an alternative to other vegetation cover methods (such as the Domin method), the Braun-Blanquet cover-abundance scale was used to analyze vegetation. It is reported that the Braun-Blanquet method requires only one third to one fifth the field time required to other similar methods (Wikum & Shanholtzer, 1978). Furthermore, cover-abundance ratings are better suited than density values to elucidate graphically species-environment relationships. For extensive surveys this method provides sufficiently accurate baseline data to allow environmental impact assessment as required by regulatory agencies. However, there are a couple of problems that have been detected with such sampling methods (Hurford & Schneider, 2007). These are as follows:

o It can be seen as subjective and dependent upon the experience and knowledge of the vegetation type by the surveyor. The cover estimate may vary from observer to observer. o There also may be a problem when the cover estimate is very close to two different classes (on the border so to speak) and then it is for the observer to decide which class it should be allocated to. In Hurford & Schneider’s (2007) experience, in marginal situations, where the cover of a species is close to a boundary between two classes, the chance of two observers allocating the species to the same cover class is no better than 50:50. However, when comparing to other sampling methods such as Domin, Braun-Blanquet scale is better adapted for monitoring (less cover classes and fewer boundaries).

Agricultural Research Council. November 2007. No assumptions or limitations were specified for this study. Soil Investigation in Waterval Area.

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Specialist Assumptions and limitations Natural Scientific Services CC. April 2015. Land No assumptions or limitations were specified for this study. Function Analysis – Waterval.

Aquatico Scientific (Pty) Ltd. January 2015, February 2015 and March 2015. No assumptions or limitations were specified for this study. Waterval Mine - Monthly Water Quality Reports

Clean Stream Biological Services (Pty) Ltd. April 2015. Glencore Chrome No assumptions or limitations were specified for this study. RTB (Merafe) – Kroondal; Biomonitoring of the Hex River catchment.

Groundwater Complete. December 2014. Glencore Chrome, Rustenburg area - No assumptions or limitations were specified for this study. Annual report on groundwater monitoring results for 2014.

Clean Stream Groundwater Services. May 2009. Xstrata Alloys South Africa (Pty) Ltd: Report on Geohydrological No assumptions or limitations were specified for this study. Investigation as part of the EMPR Amendment for the proposed Waterval Chrome Opencast Mine and tailings facility.

National Occupational Health & Safety Consultants. January 2015 No assumptions or limitations were specified for this study. to June 2015. Fallout Dust Sample Reports.

Ashreq. July 2012. Report on Environmental Noise No assumptions or limitations were specified for this study. Monitoring Waterval West Mine.

J van Schalkwyk. 2009. Heritage Impact Assessment for the In some sections, the survey was affected by tall grass that limited Proposed Tailings Facility, archaeological visibility to some extent. Waterval Mine, Rustenburg Municipal District, North West Province.

The impact assessments have assumed that all specialist assessments are essentially correct.

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15.1 Further gaps in knowledge

The following additional knowledge gaps have been identified:

• A wetland delineation study is not available for the existing and proposed activities at Waterval Mine.

16 Reasoned opinion as to whether the proposed activity should or should not be authorised

An EMP Performance Assessment (EMP PA) was conducted in November 2013 by CHEMC Environmental on the approved EMPr, dated 2009. Subsequently, Glencore Operations SA (Pty) Ltd appointed Shangoni Management Services to undertake another Environmental Audit on compliance with and adequacy of the 2009 EMPr and the EMPr addendum for the proposed new tailings dam, dated 2011, (as per Regulation 34 of the Environmental Impact Assessment (EIA) Regulations, dated December 2014). The latest Environmental Audit report, dated July 2016, concluded that the approved EMPr, dated 2009, and the EMPr addendum provides sufficient detail on environmental risks and mitigation requirements pertaining to the activities being undertaken on the mine. However, it was identified that there are a limited number of EMPr commitments that are not applicable to the activities currently undertaken at Waterval Mine. The author’s opinion was that this EMPr amendment and consolidation continue.

Further to the above, the following additional reasons resulted in a decision to amend and consolidate the Waterval Mine EMPr:

• Consolidated all approved EMPr’s into one EMPr, including the following: o Environmental Management Programme report for the Xstrata Waterval Chrome Mine, dated July 2009 and compiled by CHEMC environmental; o Environmental Impact Assessment and Environmental Management Programme, Waterval PGM plant EMPr, dated 2011 and compiled by Environmental and Energy Services; and o Environmental Management Programme for the proposed new tailings dam for Waterval Chrome Mine, dated August 2011 and compiled by The MSA Group.

• Waterval Mine has recently obtain a new section of mining right (Section 11 consent, in terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002) (“MPRDA”) from the adjacent Samancor Chrome: WCM Millsell – Waterkloof operation • More up-to-date information is available on the various environmental aspects in the form of specialist studies and monitoring data for inclusion into the EMPr; • Various new environmental legislative publications have occurred since the previous EMPr and EMPr addendum, dated 2009 and 2011 were approved; and • Practical Management and Mitigation Measures, in compliance with the latest environmental legislation needed to be incorporated into the EMPr.

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16.1 Reasons why the activity should be authorised or not

An EMP Performance Assessment (“EMP PA”) was conducted in November 2013 by CHEMC Environmental on the approved EMPr, dated 2009. Subsequently, Glencore Operations SA (Pty) Ltd appointed Shangoni Management Services to undertake another Environmental Audit on compliance with and adequacy of the 2009 EMPr and the EMPr addendum for the proposed new tailings dam, dated 2011, (as per Regulation 34 of the Environmental Impact Assessment (“EIA”) Regulations, dated December 2014). The latest Environmental Audit report, dated July 2016, concluded that the approved EMPr, dated 2009, and the EMPr addendum provides sufficient detail on environmental risks and mitigation requirements pertaining to the activities being undertaken on the mine. However, it was identified that there are a limited number of EMPr commitments that are not applicable to the activities currently undertaken at Waterval Mine. The author’s opinion was that this EMPr amendment and consolidation continue.

Further to the above, the following additional reasons resulted in a decision to amend and consolidate the Waterval Mine EMPr:

• Consolidated all approved EMPr’s into one EMPr, including the following:

o Environmental Management Programme report for the Xstrata Waterval Chrome Mine, dated July 2009 and compiled by CHEMC environmental; o Environmental Impact Assessment and Environmental Management Programme, Waterval PGM plant EMPr, dated 2011 and compiled by Environmental and Energy Services; and o Environmental Management Programme for the proposed new tailings dam for Waterval Chrome Mine, dated August 2011 and compiled by The MSA Group.

• Waterval Mine has recently obtain a new section of mining right (Section 11 consent, in terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002) (“MPRDA”) from the adjacent Samancor Chrome: WCM Millsell – Waterkloof operation • More up-to-date information is available on the various environmental aspects in the form of specialist studies and monitoring data for inclusion into the EMPr; • Various new environmental legislative publications have occurred since the previous EMPr and EMPr addendum, dated 2009 and 2011 were approved; and • Practical Management and Mitigation Measures, in compliance with the latest environmental legislation needed to be incorporated into the EMPr. 16.2 Conditions that must be included in the authorisation

16.2.1 Specific conditions to be included into the compilation and approval of the EMPr

Should the Department of Mineral Resources grant authorisation for the proposed project, it should be subject to the following conditions:

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The project should remain in full compliance with the requirements of the EMPr and with all regulatory requirements; The EMPr should be implemented by qualified environmental personnel who have the competence and credibility to interpret the requirements of the EIAR and the EMPr. Such persons must be issued with a written mandate by mine management to provide guidance and instructions to employees and contractors; and Stakeholder engagement must be maintained during the operational and closure/rehabilitation phases of the project.

16.2.2 Rehabilitation requirements

The objective of the Rehabilitation Plan is to limit the adverse effects on the land capability of the disturbed area.

17 Period for which Environmental Authorisation is required

The total period for which authorisation is required, is equal to the remaining Life of Mine (LOM) for Waterval Mine, which is in excess of 30 years.

Table 87: Period for which authorisation is required

Stages of operation Timeframe (Years) Planning N/A

Construction (proposed infrastructure as described in this EIAR / 1 year EMPr)

Commissioning (proposed infrastructure as described in this EIAR / 1 year EMPr)

Operation (ongoing) > 30 years

Decommissioning and Closure ± 8 years

TOTAL Period > 30 years

18 Undertaking

The undertaking by the EAP is provided in Section 2 of Part B (Environmental Management Programme) below. This undertaking confirms: the correctness of the information provided in the reports, the inclusion of comments and inputs from stakeholders and I&APs, the inclusion of inputs and recommendations from the specialist reports where relevant and the acceptability of the project in relation to the finding of the assessment and level of mitigation proposed.

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19 Financial provisions

The information provided in this section was extracted from the following report: • Glencore Operations South Africa (Pty) Ltd – Waterval Mine Operations Financial Provisioning, dated November 2016 and compiled by Shangoni Management Services (Pty) Ltd. According to the closure cost assessment conducted in 2016, and in accordance with the DMR guidelines, the costs associated with the immediate closure of Waterval Mine was calculated as R 37,678,078.20 (including P&G, contingency and VAT). Per this quantum update, the financial provisioning available should increase by R 14,843,418.54 (including P&G, contingency and VAT). 19.1 Explain how the aforesaid amount was derived.

19.1.1 Process followed

Most of the information used for the quantum calculation was obtained from survey data provided by Glencore. The most recent Google earth and Bing imagery was used to identify and mark the entire related infrastructure, mining area and other associated areas of importance.

Once this was completed, a list of all the infrastructure was compiled. The infrastructure was classified in accordance with the tariffs list (Table 88) and the surface areas of the infrastructure were calculated to determine the volume or surface requiring rehabilitation or demolition.

Table 88 below provides the demolition and rehabilitation rates as obtained from the CES Group, which were used to calculate the closure costs.

Table 88: Tariffs used for quantum determination

Rehabilitation and Demolition List reference Unit Rates 800mm thick /deep Reinforced in situ concrete 800mm concrete structures: Demolition and removal to m³ R 502.27 structures demolition site

400mm thick /deep reinforced concrete 400mm concrete structure m³ R 447.27

250mm thick /deep reinforced concrete 250mm concrete structure m³ R 350.00

340mm concrete 340mm thick /deep concrete slabs m³ R 400.00 structures

220mm thick brick wall buildings (single storey) Face brick building, 14.8 x 10m x 4.4m high, consisting of 600 x 230mm strip footings laying 655mm deep, 150mm surface bed finished off Single storey double brick with ceramic floor tiles including 110mm m² R 447.27 internal walls, with 1000 x 100mm apron building around building and Roller shutter doors at service hatch 3000 x 1200mm. Ceilings at 2805mm high. Roof trusses 1600mm high at centre with 500mm overhang, pitching 15 degrees and 0.6mm IBR profiled colomet roof

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Rehabilitation and Demolition List reference Unit Rates sheeting, ridge capping, fascia boards, barge boards, gutters and downpipes.

Face brick building, 48 x 12.46m x 7.85m high, consisting of 750 x 300mm strip footings laying 755mm deep, 150mm surface bed finished off with ceramic floor tiles including 110mm internal walls, with 1000 x 100mm apron around building. Ceiling below hollow block slab at 2805mm high. 1st floor hollow block slab, 255mm thick finished off with ceramic Multi-level double brick floor tiles. Stairs to 1st floor 220mm threads x m³ R 435.00 building 150mm risers and slab to wall at 1400mm high in middle and to one side of building. Ceilings at 2890mm high. Prefabricated roof trusses 1900mm high at centre with 500mm overhang, pitching 15 degrees and 0.6mm colomet roof sheeting, ridge capping, fascia boards, barge boards, gutters and downpipes. Canopy at entrance to building 3m wide x 2.8m high

Light steel construction cladded with corrugated iron (car ports etc.) Carports 7.5m x 11m, consisting of 6 x 75 SHS Columns in 500mm deep concrete bases with Light steel m² R 53.13 colomet 6mm IBR roof sheeting on 75 x 75 SHS Curved purlins (one carport size 5.5 x 2.5m x 2.3m high)

Medium steel construction buildings (corrugated iron cladded workshops and Medium steel m² R 290.00 sheds with concrete floors)

Dismantle and remove Cattle Fencing not exceeding 1.2m high, including posts, gates, Dismantling fences 1.2m m R 12.00 foundations, etcetera

Dismantle and remove Security Fencing Dismantling fences 1.8m exceeding 1.8m high, including posts, gates, m R 13.50 Security foundations, etcetera

Wildlife fence 1.8m Erecting fences m R 140.00

Disconnect and remove 2 x MCC panels. Demolish and remove face brick building 6,5 x 9 x 5.05m high to roof truss, strip footings Infrastructure: Sub- laying 750mm deep, 6 x 2m high columns with no R 26 850.00 stations 300mm thick concrete slab on columns. Steel stairs and hand railing to 1st floor. Steel roof structure 1,6m high to pitch.

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Rehabilitation and Demolition List reference Unit Rates Disconnect and remove transformers, Infrastructure: demolish transformer room brick building, 3 x no R 10 850.00 Transformers 3 x 4m high.

Remove fuel pumps & tank Fuel pumps & tanks m³ R 850.00

Drain and fill French drain French drain no R 6 585.00

Remove water tank Water tanks m³ R 450.00

Permatank Underground fuel tanks m³ R 850.00

Office / park home Temporary office 6m no R 1 500.00

No cost incurred No cost incurred n/a R -

Ripping of dirt road Ripping m² R 14.89

Remove tarred surface areas not exceeding Tar removal m² R 33.73 50mm thick

Demolish reinforced concrete Weighbridges m³ R 550.00

Remove pumps and piping and demolish Pumps & pump rooms no R 1 805.75 pump room size 3,5 x 5,25 x 3m high.

20 Litre Bag Planting trees 20l no R 150.00

Traditional seeding Seeding m² R 3.36

The quantum was calculated using the demolition and rehabilitation rates obtained from the CES Group and has been calculated as R 37,678,078.20 (including P&G, contingency and VAT) for the premature closure of Waterval Mine. The table below contains the calculations made to obtain the physical closure costs.

The physical component of closure contributes R 19,228,260.56 towards the closure liability, with the greatest contribution coming from the demolition of concrete structures.

Table 89: Calculations made for the premature closure cost related to the physical components

Item Total Size Rate Final cost Waterval East 250mm concrete structure

Change House Slab Area 1675 R 350.00 R 586,250.00

Meeting Hall Area Slab 1450 R 350.00 R 507,500.00

Walk Ways Concrete Slabs 350 R 350.00 R 122,500.00

800mm concrete structures

Diesel Bay Area 208 R 502.27 R 104,472.16

Engineering Work Shop Slab 660 R 502.27 R 331,498.20

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Item Total Size Rate Final cost Heli Pad 30 R 502.27 R 15,068.10

Magazine Area 115 R 502.27 R 57,761.05

Oil Yard /Bay Area 125 R 502.27 R 62,783.75

Reservoir Dam 1 Plant 170 R 502.27 R 85,385.90

Reservoir Dam 2 Plant 170 R 502.27 R 85,385.90

Tar Parking Area 0 R 502.27 R 0.00

Reservoir Dam 1 150 R 502.27 R 75,340.50

Reservoir Dam 2 115 R 502.27 R 57,761.05

Dismantling fences 1.8m Mesh

Change house 155 R 12.00 R 1,860.00

Clinic Offices 235 R 12.00 R 2,820.00

Division Between Yard and Parking Area 60 R 12.00 R 720.00

Diesel Bay Area 80 R 12.00 R 960.00

Magazine Fence 290 R 12.00 R 3,480.00

Magazine Fence Mine Area 85 R 12.00 R 1,020.00

Perimeter Fence 1400 R 12.00 R 16,800.00

Perimeter Fence Mine Area 1545 R 12.00 R 18,540.00

Plant Fence 185 R 12.00 R 2,220.00

Precast Wall Fence Engineering Workshop 70 R 12.00 R 840.00

Security Fence Head office 290 R 12.00 R 3,480.00

Shaft portal Fence 380 R 12.00 R 4,560.00

Social Area 70 R 12.00 R 840.00

Store Yard Fence 212 R 12.00 R 2,544.00

Training Centre 254 R 12.00 R 3,048.00

Training Yard 37 R 12.00 R 444.00

Water Valve Fence 22 R 12.00 R 264.00

Infrastructure: Pipelines <400mm

Pipe Line 1 220 R 37.69 R 8,291.80

Pipe Line 2 240 R 37.69 R 9,045.60

Infrastructure: Powerlines

Mine Area 640 R 45.00 R 28,800.00

Telephone Line Clinic Area 600 R 45.00 R 27,000.00

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Item Total Size Rate Final cost Light steel

Carport 156 R 47.63 R 7,430.28

Lamp Room /Decline Area Walk Way 1025 R 47.63 R 48,820.75

Parking Area 867 R 47.63 R 41,295.21

Steel Roof /Social Area 170 R 47.63 R 8,097.10

Medium steel

Compressor House 240 R 250.00 R 60,000.00

Conveyor Belts with Transfer Towers 1885 R 250.00 R 471,250.00

Explosive Steel Shed 55 R 250.00 R 13,750.00

Plant Workshop 310 R 250.00 R 77,500.00

Security Head Office Steel Sheds 320 R 250.00 R 80,000.00

Steel Shading Sheds 222 R 250.00 R 55,500.00

Steel Sheds Parking Area 440 R 250.00 R 110,000.00

Store for Spares 625 R 250.00 R 156,250.00

Store Yard Sheds 150 R 250.00 R 37,500.00

Walk Way Shed 185 R 250.00 R 46,250.00

Weigh Bridges 288 R 250.00 R 72,000.00

Single storey double brick building

Change house 400 R 500.00 R 100,000.00

Clerk Office 100 R 250.00 R 25,000.00

Control Room Plant 75 R 250.00 R 18,750.00

Eng. Office 150 R 250.00 R 37,500.00

Hr Office 45 R 250.00 R 11,250.00

Managers Office 325 R 250.00 R 81,250.00

Meeting Hall Building Area 355 R 250.00 R 88,750.00

Mining Offices 150 R 250.00 R 37,500.00

Ruin 110 R 250.00 R 27,500.00

Security Building 35 R 250.00 R 8,750.00

Security Head office 365 R 250.00 R 91,250.00

Security Office 55 R 250.00 R 13,750.00

Sub Station 75 R 250.00 R 18,750.00

Weigh Bridge Offices 84 R 250.00 R 21,000.00

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Item Total Size Rate Final cost Workshop for Engineering 465 R 250.00 R 116,250.00

Waterval West

800mm concrete structures

Diesel Bay Slab 100 R 502.27 R 50,227.00

Helicopter Pad 108 R 502.27 R 54,245.16

Magazine 60 R 502.27 R 30,136.20

Plant Area Slab 13955 R 502.27 R 7,009,177.85

Plant Office 6875 R 502.27 R 3,453,106.25

Reservoir Dam 190 R 502.27 R 95,431.30

Small Water Dam 125 R 502.27 R 62,783.75

Sub Station Slab 120 R 502.27 R 60,272.40

Thickener Dam 215 R 502.27 R 107,988.05

Transformer Slab 140 R 502.27 R 70,317.80

Vent Fan Slab (Surface -underground) 155 R 502.27 R 77,851.85

Wash Bay 225 R 502.27 R 113,010.75

Conveyor belts

Conveyor Belts 1911 R 522.00 R 997,542.00

Dismantling fences 1.8m Security

Conveyor Belts Fences 164 R 13.50 R 2,214.00

Declines Shafts 180 R 13.50 R 2,430.00

Division Fence 433 R 13.50 R 5,845.50

Fence Magazine 155 R 13.50 R 2,092.50

Fence Stockpile Area 98 R 13.50 R 1,323.00

Hr Parking 120 R 13.50 R 1,620.00

Perimeter Fence Head Office 1765 R 13.50 R 23,827.50

Perimeter Fence Mine Area 1733 R 13.50 R 23,395.50

Plant Office 315 R 13.50 R 4,252.50

Precast Fence 65 R 13.50 R 877.50

Sampling Bay 310 R 13.50 R 4,185.00

Thickener Plant Dam 80 R 13.50 R 1,080.00

Infrastructure: Powerlines

Power Cable 550 R 45.00 R 24,750.00

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Item Total Size Rate Final cost Light steel

Decline shafts Roofs 310 R 47.63 R 14,765.30

Parking Sheds 2285 R 47.63 R 108,834.55

Medium steel

Oil Bay 40 R 250.00 R 10,000.00

Plant Office 220 R 250.00 R 55,000.00

Pump House 1 11 R 250.00 R 2,750.00

Sampling Bay 1242 R 250.00 R 310,500.00

Waste Bay 95 R 250.00 R 23,750.00

Weighbridge 167 R 250.00 R 41,750.00

Workshop at Plant 250 R 250.00 R 62,500.00

Single storey double brick building

Change houses 195 R 250.00 R 48,750.00

Compressor Building 325 R 250.00 R 81,250.00

Hr offices 965 R 250.00 R 241,250.00

Magazine Building Security 15 R 250.00 R 3,750.00

Mesh Offices 130 R 250.00 R 32,500.00

Office Buildings 5195 R 250.00 R 1,298,750.00

Plant Offices 550 R 250.00 R 137,500.00

Pump House 2 35 R 250.00 R 8,750.00

Security Wes Area 240 R 250.00 R 60,000.00

Sub Station Building 120 R 250.00 R 30,000.00

Workshop of Engineering 655 R 250.00 R 163,750.00

Grand Total R 19,228,260.56

The costs associated with the closure and rehabilitation of the bio-physical components result mostly from the rehabilitation of disturbed areas. The ripping of the stockpile area at Waterval West contributes more than R4 000 000.00 to the bio-physical closure costs. This is due to the immense size of the area disturbed. The table below contains the detailed calculations used to obtain the bio-physical closure costs.

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Table 90: Calculations made for the premature closure cost related to the bio-physical components

Item Total Size Rate Final cost Waterval East Adit sealing

Shaft Portal Area 1 R 1,200.00 R 1,200.00

Rehabilitation of processing waste deposits and evaporation ponds

Slimes Dam 5.2416 R 167,272.08 R 876,773.33

Ripping

Gravel Road 6390 R 14.89 R 95,147.10

Stockpiles Area 33465 R 14.89 R 498,293.85

Seeding

WvE & Clinic total disturbed 310000 R 3.36 R 1,041,600.00

Tar road ripping

Tar Road 3373 R 21.31 R 71,878.63

Waterval West

Paving removal: Concrete

Paved Roads 4400 R 22.73 R 100,012.00

Ripping

Gravel Roads 13955 R 14.89 R 207,789.95

Stockpile Area 280000 R 14.89 R 4,169,200.00

Seeding

Head Office +Shared Services 140400 R 3.36 R 471,744.00

Grand Total R 7,533,638.86

19.2 Confirm that this amount can be provided for from operating expenditure

As described above, according to the closure cost assessment conducted in 2016, and in accordance with the DMR guidelines, the costs associated with the immediate closure of Waterval Mine was calculated as R 37,678,078.20 (including P&G, contingency and VAT). Per this quantum update, the financial provisioning available should increase by R 14,843,418.54 (including P&G, contingency and VAT).This amount will be provided for in terms of a bank guarantee.

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20 Deviations from the approved scoping report and plan of study 20.1 Deviations from the Methodology used in determining the significance of potential environmental impacts and risks

The methodology applied in determining and ranking potential environmental impacts and the significance of potential impacts is described in detail in Section 7.6 of Part A above. No Scoping Report has been compiled for this EMPr Amendment, for the existing Waterval Mine. Therefore, no deviation from the methodology has occurred (is applicable). 20.2 Motive for the deviation

Refer to Section 20.1 of Part A, above. No deviation from the methodology used in determining the significance of potential environmental impacts and risks has occurred.

21 Other information required by the competent authority 21.1 Compliance with the provisions of section 24(4)(a) and (b) read with section 24(3)(a) and (7) of the National Environmental Management Act 107 of 1998

21.1.1 Impact on the socio-economic conditions of any directly affected person

Reference to where Results of investigation, assessment and evaluation of impact on any mitigation is directly affected person reflected Should this EMPr amendment be approved and the operations at Waterval Mine continue, mining of the available reserves can continue. This will ensure continued job security for the mine’s current employees and contractors, along with the continued and long-term benefits for the local community arising from the Social and Labour Plan (SLP). The SLP Annual Report for 2015 also provides more information regarding the progress made in terms of programmes forming part of the SLP and the overall benefit arising from the implementation of such. Refer to Annexure Refer to Part 9 above E. and Annexure E. Potential negative socio-economic impacts relate to: • An indirect impact on local communities in terms of the change in sense of place and visual aspects; and • Closure (downscaling and retrenchment).

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21.1.2 Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act 25 of 1999

Reference to where Results of investigation, assessment and evaluation of impact on any mitigation is national estate reflected • According to the Updated EMP, 2009, “there are no known sites of archaeological interest on the site, as the sites would have already been Refer to Part 9 above destroyed.” No heritage assessment for the mining area is however and Annexure G8. available and therefore the status of heritage resources at Waterval Mine cannot be assessed.

22 Other matters required in terms of section 24(4) (a) and (b) of the Act

Table 91: Information on other matters as required by section 24(4)(a) and (b) of the Act

24 (4) Procedures for the investigation, assessment and communication of the potential consequences or impacts of activities on the environment-

(a) must ensure, with respect to every application for an environmental authorisation-

Department of Mineral Resources is the only applicable authority for the evaluation of this EIAR / EMPr. However, the Local and District Municipalities, the Department of Human i. Coordination and cooperation between Settlements, Water and Sanitation (“DWS”), the organs of state in the consideration of South African Heritage Resource Agency assessments where an activity falls under (“SAHRA”), as well as the Department of the jurisdiction of more than one organ of Environmental Affairs have been registered as state; stakeholders (organs of state) and have received notification of the amendment of the EIAR / EMPr. Copies of the documentation will be made available to these organs of state upon request, for review.

ii. That the findings and recommendations flowing from an investigation, the general All the findings from investigations (including objectives of integrated environmental public participation) have been included in this management laid down in this Act and the EIAR and EMPr. principles of environmental management set out in section 2 are taken into account

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24 (4) Procedures for the investigation, assessment and communication of the potential consequences or impacts of activities on the environment-

in any decision made by an organ of state in relation to any proposed policy, programme, process, plan or project;

iii. That a description of the environment likely Environmental baseline information has been to be significantly affected by the proposed included in this EIAR / EMPr. Refer to Section activity is contained in such application; 7.4.1 (Part A) of this report.

iv. Investigation of the potential consequences for / or impacts on the Investigation of impact on the environment and environment of the activity and assessment of the significance of the potential assessment of the significance of those impacts have been done. See Section 9 (Part A). potential consequences or impacts; and

• Background information document (“BID”) and notification letters have been sent to v. Public information and participation interested and affected parties (“I&APs”), procedures which provide all interested organs of state and stakeholders. and affected parties, including all organs of • Notice boards have been placed in relevant state in all spheres of government that may places (onsite and in public places). have jurisdiction over any aspect of the • A newspaper advertisement has been placed activity, with a reasonable opportunity to in the local newspaper. participate in those information and • This EIAR / EMPr is made available to I&APs participation procedures; and and stakeholders for review for a period of 30 days.

(b) must include, with respect to every application for an environmental authorisation and where applicable-

i. Investigation of the potential consequences or impacts of the alternatives to the activity on the Investigation of the impacts on the environment environment and assessment of the and assessment of the significance of the significance of those potential impacts have been done. See Section 9 (Part A). consequences or impacts, including the option of not implementing the activity;

ii. Investigation of mitigation measures to Mitigation measures are outlined in Section 1.4.9 keep adverse consequences or impacts to (Part B) of this EIAR / EMPr. a minimum;

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24 (4) Procedures for the investigation, assessment and communication of the potential consequences or impacts of activities on the environment-

iii. Investigation, assessment and evaluation of the impact of any proposed listed or specified activity on any national estate Investigation of the impacts on the environment referred to in section 3(2) of the National and assessment of the significance of the Heritage Resources Act, 1999 (Act No. 25 impacts have been done. See Section 9 (Part A). of 1999), excluding the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act;

iv. Reporting on gaps in knowledge, the adequacy of predictive methods and underlying assumptions, and uncertainties Refer to Section 15 (Part A). encountered in compiling the required information;

v. Investigation and formulation of Waterval Mine has various monitoring arrangements for the monitoring and programmes in place. Such programmes will management of consequences for or continue to be implemented by the mine for the impacts on the environment, and the remainder of the Life of Mine. Refer to Section assessment of the effectiveness of such 1.8 (Part B). arrangements after their implementation;

vi. Consideration of environmental attributes Surrounding environmental attributes identified identified in the compilation of information were taken into consideration during the and maps contemplated in subsection (3); process. Refer to Section 7.4.1 (Part A) as well and as Section 9.

vii. Provision for the adherence to requirements that are prescribed in a specific environmental management Act Refer to Section 1.4.9 (Part B). relevant to the listed or specified activity in question.

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PART B

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

1 Draft environmental management programme 1.1 Details of the EAP

The requirements for the provision of the detail and expertise of the EAP are included in Part A, Section 1.2. 1.2 Description of the aspects of the activity

The requirement to describe the aspects of the activity that are covered by the draft environmental management programme is included in Part A, Section 7.5 1.3 Composite map

Refer to Figure 5 for a map that superimposes the activity, its associated structures and infrastructures on the environmental sensitivities of the preferred sites, also indicating any areas that should be avoided, including buffers. 1.4 Description of impact management objectives including management statements.

1.4.1 Determination of closure objectives

Refer to the Section 1.7.1 of Part B below for a description of the closure objectives for Waterval Mine.

1.4.2 The process for managing any environmental damage, pollution, pumping and treatment of extraneous water or ecological degradation as a result of undertaking a listed activity.

1.4.3 Potential risk of Acid Mine Drainage

The information contained below has been extracted from the report titled Waterval Chrome Mine: Mine Residue and Soil Classification, dated 19 May 2017, and compiled by Exigo.

As part of the hydrogeochemical leach tests, 3 samples (5 kg each) were taken from the tailings facilities and composited into one representative sample after which the following analyses were undertaken:

• XRD analysis for mineralogical composition; • Aqua-regia whole rock digest and ICP-MS analysis of the leachate to determine the metal and macro-chemical composition; and • A distilled water leach was done to simulate leaching potential from rainfall.

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1.4.3.1 XRD analysis

The XRD analysis indicated that the mineralogical chemical composition consists mainly of chromite, enstatite, plagioclase feldspar and smectite clay.

Table 92: Waterval Chrome mine residue XRD analysis results

Composition (%) GH 1053 (WTVL West Tailings) 14996 Amount Mineral (weight %) Chromite 35.93

Enstatite 2.46

Plagioclase 19.32

Talc 2.51

Diopside 6.65

Smectite 20.15

Actinolite 7.08

Kaolinite 5.56

Muscovite 0.34

Total 100

The mineral chemistry is dominated by Cr, Fe, Ca, Mg, SiO2, Na and Al. In the tailings and waste rock material, the whole rock total concentration (“TCT”) analyses indicated none of the samples exceeded the threshold values for TCT0. The leachable component (“LCT”) analyses indicated that none of the constituents exceeded the threshold values for LCT0.

Table 93: Waterval tailings and waste rock facilities mineral composition

Mineral Composition'

Actinolite Ca2(Mg,Fe)5Si8O22(OH)

Chromite FeCr2O4

Diopside CaMgSi2O6

Enstatite MgSiO3

Kaolinite Al4(OH )8(Si4O10 )

Muscovite K Al2 ((OH)2 Al Si3O10)

Plagioclase (Na,Ca)(Si,Al)4O8

Smectite (Na,Ca)0,3(Al,Mg)2Si4O10(OH)2•n(H2O)

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1.4.3.2 Macro-chemical leachate and distilled water leach The macro-chemical leachate (LCT) analysis indicated that the leachate is close to neutral with a pH of

6.9. Leachate of CaCO3 (560 ppm), is the only notable constituent. It is expected that the calcium originates from the plagioclase feldspar and the actinolite minerals, which occur naturally in the area. No leaching of metals is expected due to the combination of neutral pH values and high smectite mineral content. Smectite minerals have high adsorption potential for metals and metalloids. The pH is almost neutral and hence no significant leaching of metals is expected. There is no risk for acid rock drainage (“ARD”) as the sulphide mineral content is insignificantly low.

Table 94: Waterval mine residue facilities - chemical and distilled water leach test results – macro- parameters.

Analyses Sample Number 14991

TCLP / Acid Rain / Distilled Water / H2O2 Distilled Water Dry Mass Used (g) 50

Volume Used (mℓ) 1000

pH Value at 25˚C 6,9

Electrical Conductivity in mS/m at 25˚C 2,3

Inorganic Anions mg/ℓ

Total Dissolved Solids at 180 ˚C 188

Total Alkalinity as CaCO3 28

Bicarbonate Alkalinity as CaCO3 (calc) 28

Phenolphthalein Alkalinity as CaCO3 <5

Chloride as Cl <2

Sulphate as SO4 <2

Nitrate as N <0.1

Nitrite as N <0.05

Fluoride as F <0.2

Free & Saline Ammonia as N <0.1

Ortho-Phosphate as P <0.1

Hexavalent Chromium as Cr6+ <0.010

Total Cyanide as CN <0.01

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Table 95: Waterval chemical and distilled water leach test results – metals and micro-parameters

Glencore Waterval R635 Total Concentration R635 Leach Concentration Parameter West Tailings Threshold Values Threshold Values GH 1053 TCT0 TCT1 TCT2 LCT0 LCT1 LCT2 LCT3 TCT LCT

Sample no 14996 14996

Unit mg/kg mg/kg mg/kg mg/ℓ mg/ℓ mg/ℓ mg/ℓ mg/kg mg/ℓ

Al 11600.000 0.943

As 5.8 500 2,000 0.01 0.5 1 4 <0.400 <0.001

B 150 15,000 60,000 0.5 25 50 200 0.401 0.001

Ba 62.5 6,250 25,000 0.7 35 70 280 6.380 0.016

Ca 5200.00 1.00

Cd 7.5 260 1,040 0.003 0.15 0.3 1.2 <0.400 <0.001

Co 50 5,000 20,000 0.5 25 50 200 1.110 0.003

Cr 46,000 800,000 n.a 0.1 5 10 40 35.000 0.087

Cr(VI) 6.5 500 2,000 0.05 2.5 5 20

Cu 16.0 19,500 78,000 2.0 100 200 800 1.410 0.004

Fe 33200 3.150

Hg 0.93 160 640 0.006 0.3 0.6 2.4 <0.400 <0.001

K 454 0.5

Mg 33600 5

Mn 1,000 25,000 100,000 0.5 25 50 200 868 0.137

Mo 40 1,000 4,000 0.07 3.5 7 28 <0.400 <0.001

Na 1200 1

Ni 91 10,600 42,400 0.07 3.5 7 28 13 0.032

Pb 20 1,900 7,600 0.01 0.5 1 4 <0.400 <0.001

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Glencore Waterval R635 Total Concentration R635 Leach Concentration Parameter West Tailings Threshold Values Threshold Values GH 1053 Sb 10 75 300 0.02 1.0 2 8 <0.400 <0.001

Se 10 50 200 0.01 0.5 1 4 <0.400 <0.001

Si 108800 9.3

Te <0.400 <0.001

Th <0.400 <0.001

U <0.400 <0.001

V 150 2,680 10,720 0.2 10 20 80 2.48 0.006

Zn 240.0 160,000 640,000 5.0 250 500 2,000 2.45 0.006

The following conclusions can be drawn: • The tailings material consists mainly of chromite, enstatite, plagioclase feldspar, actinolite and smectite. • The macro-chemical leachate (LCT) analysis indicated that the leachate is close to neutral with a pH

of 6.9. Leachate of CaCO3 (28 mg/L), is the only potential parameter that could leach from the tailings material. It is expected that the calcium originates from the plagioclase feldspar and the actinolite minerals, which would occur naturally in the area. • No leaching of metals is expected due to the combination of neutral pH values and high smectite mineral content. Smectite minerals have high adsorption potential for metals and metalloids. The pH is almost neutral and hence no significant leaching of metals is expected. • There is no risk for acid rock drainage (ARD) as the sulphide mineral content is insignificantly low. • The whole rock analysis indicated that none of the constituents exceeds the regulatory value of Regulation 635 for TCT0. • The leachable concentration threshold (LCT) analyses indicated that none of the constituents exceeded the threshold values for LCT0. • The analysis indicated that the tailings material would classify as a Type 4 “waste” and is therefore inert according to R635.

1.4.4 Steps taken to investigate, assess, and evaluate the impact of acid mine drainage

As described above the report titled Waterval Chrome Mine: Mine Residue and Soil Classification, dated 19 My 2017, and compiled by Exigo, has been utilised to investigate the potential impact of acid mine drainage.

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Quarterly groundwater monitoring is undertaken at Waterval Mine and resultant reports generated and provided to the mine for implementation purposes. Results are interpreted by Aquatico Scientific on a quarterly basis and provided (against the relevant target water quality guidelines) in the mentioned reports. As mentioned above, there is currently no sign of impacts associated with acid mine drainage at Rietvly Mine, when reviewing the results as contained in the quarterly groundwater monitoring reports.

Furthermore, as per Groundwater Complete’s annual groundwater monitoring report for 2014, the water quality parameter (analyte) range depends mainly on the characteristics of the contamination source that is monitored and to a lesser extent on the natural hydrogeochemistry of the aquifers in the area. The sources are mostly inorganic and include ions like sulphate and nitrate. The focus with the monitoring program should thus be to determine the inorganic content of the water by firstly measuring analytes like macro element cations (Ca, Mg, Na, K) and anions (Cl, SO4, NO3, F) as well as pH, EC and alkalinity. Scans for metals (like iron, manganese and aluminum) are also important to show where mobilisation of metals occur due to acid mine drainage or related reactions. These parameters are analysed for at Glencore Rustenburg and this aspect is therefore considered to be adequate (Groundwater Complete, 2014).

1.4.5 Engineering or mine design solutions to be implemented to avoid or remedy acid mine drainage.

Refer to Section 1.4.3 and 1.4.4 above.

1.4.6 Measures that will be put in place to remedy any residual or cumulative impacts that may result from acid mine drainage.

The mitigation measures to be put in place to remedy and or minimize the effects of Acid Mine Drainage (“AMD”) should it occur are as follows: • A long-term goal may entail the establishment of a joint water management strategy with mines in the region and possible treatment capacity. • Reduce water inflow into shaft areas through efficient storm water management. • Water levels within the basins should be held at or below the relevant environmental critical levels (“ECLs”) through pumping of water. • Improved monitoring of mine water, groundwater, surface water,

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1.4.7 Volumes and rate of water use required for the mining, trenching or bulk sampling operation.

The water balance for Waterval Mine is presented in Figure 11

Figure 11: Waterval water flow diagram and shows the volumes of water sourced for operations at the mine and used within the mining process.

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1.4.8 Water Use Licence

Glencore Waterval Mine has an Integrated Water Use Licence (“IWUL”), dated January 2015 (Licence no 03/A22H/ABFGJ/2749). Refer to Annexure D.

1.4.9 Impacts to be mitigated in their respective phases

Refer to the full risk assessment and mitigation measures table provided in Section 7.5 (Part A) above. 1.5 Impact Management Outcomes

Refer to the full risk assessment and mitigation measures table provided in Section 7.5 (Part A) above. 1.6 Impact Management Actions

Refer to the full risk assessment and mitigation measures table provided in Section 7.5 (Part A) above. 1.7 Financial Provision.

1.7.1 Describe the closure objectives and the extent to which they have been aligned with the baseline environment described under Regulation 22(2)(d) as described in Section 7.4.1.

The following site-specific closure objectives have been developed:

Surface infrastructure Pre-closure engagement to determine buildings/infrastructure that can be utilised post closure. The plant area and associated workshops, conveyors and buildings will either be leased or sold. Should this not occur they will be broken down and their footprints will be returned to grazing potential land use. The following decommissioning and closure standards have been identified: • All infrastructure and concrete buildings to be dismantled and broken down to natural ground level; • All remaining building rubble must be taken to an approved municipal waste disposal site or be backfilled into the shaft; • Any hazardous substances removed from the building, must be disposed of at an appropriate hazardous waste site; • Septic tank areas to be rehabilitated to accepted standard; • Grading and final shaping of the disturbed footprint areas will be in line with final designs; • Storm water control measures, such as berms and trenches, must be installed where required to prevent erosion.

Underground shafts and ventilation shafts All shafts are to be sealed as per DMR requirements. All structures will be demolished and removed; shafts will be rehabilitated to an agreed upon end land use. Topsoil will be placed in line with final designs. • All infrastructure, headgear and concrete buildings to be dismantled and broken down to natural ground level.

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• Ventilation shafts to be sealed as per DMR requirements i.e. concrete plug 1m below ground level with a metal beacon attached. • Access shaft must also be sealed as per DMR requirements; this includes backfilling the shaft, placing a concrete plug over the entrance and then placing material over the plug to conceal it. • Grading and final shaping of the disturbed footprint areas will be in line with final designs. • Storm water control measures, such as berms and trenches, must be installed where required to prevent erosion.

Roads All roads not required for long term pollution monitoring must be rehabilitated to the agreed upon end land use. Engagement to identify roads to remain post closure. Topsoil will be placed as per final design, with a sustainable indigenous grassland vegetation cover. The following standards for decommissioning and closure will be applied: • All signage along the roads must be removed, unless the roads will be utilised post closure. • Roads surfaces will be rehabilitated as per designs if not used post closure. • Grading and final shaping of the disturbed footprint areas will be completed in line with the final designs. • Storm water management measures, such as berms and trenches, must be installed where required to prevent erosion. • The areas shall be rehabilitated with natural and indigenous vegetation where applicable.

Slimes Dams Slimes dumps will be rehabilitated to a landform that does not pose danger to public, or animal, health and safety. The slimes dams have a potential to be re-mined in future, as such rehabilitation must cater for future re-mining, unless otherwise agreed upon. • Footprints must be topsoiled as per design. • Area to be re-vegetated with indigenous vegetation. • Water management structures such as cut off trenches and surface run –off berms must be designed and implemented to control erosion. • Reshape the dumps as per design. • Shaping to ensure free draining landform.

Clean and dirty water dams Long-term strategic uses for the dams should be determined, as they can act as flood mitigating structures and water storage points for future farming activities. Should the dams not be required for storage, they must be broken down and the footprint returned to the agreed upon end land use. • Strategically assess each dam to determine viability of post-closure land use.

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1.7.2 Confirm specifically that the environmental objectives in relation to closure have been consulted with landowners and interested and affected parties.

This EIR and EMPr has been made available to the public for comment for a period thirty (30) days. The public is also encouraged to comment on this report (with specific reference to the closure objectives as presented in Section 1.7.1 above), any aspect of the project and raise any concerns and / or issues they may have. The comments, concerns and / or issues will be addressed and responded to and will be taken into consideration in finalising this EIR and EMPr.

1.7.3 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 rehabilitation plan has been compiled and contained as Annexure I.

1.7.4 Explain why it can be confirmed that the rehabilitation plan is compatible with the closure objectives.

Refer to Part A Section 16.2.2, Part B Section 1.7.1 above, as well as Annexure I for information in terms of the rehabilitation plan and closure plan.

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

A detailed description of the derivation and calculation of quantum is included in the document titled Glencore Waterval Chrome Mine Closure cost report, dated March 2020 and compiled by Environmental and Energy Services. The report is attached hereto as Annexure J. Refer to Section 19 of Part A, for the calculated quantum as well as for a description of the process followed in deriving and calculating the quantum.

1.7.6 Confirm that the financial provision will be provided as determined.

The financial provision as determined above is provided for in the form of a bank guarantee. 1.8 Mechanisms for monitoring compliance with and performance assessments against the environmental management programme.

Mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon, including

• Monitoring of Impact Management Actions • Monitoring and reporting frequency • Responsible persons • Time period for implementing impact management actions • Mechanism for monitoring compliance

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Table 96: Monitoring programmes and compliance thereto

MONITORING AND IMPACTS ROLES AND RESPONSIBILITIES REPORTING FREQUENCY SOURCE REQUIRING FUNCTIONAL REQUIREMENTS and TIME PERIODS FOR ACTIVITY MONITORING FOR MONITORING (FOR THE EXECUTION OF THE IMPLEMENTING IMPACT PROGRAMMES MONITORING PROGRAMMES) MANAGEMENT ACTIONS The pumping of Pumping of water, groundwater may found underground, result in the to the surface. development of a cone of depression.

Groundwater quality may be impacted The Environmental Department is to Groundwater quality and level upon as a result of Implementing the groundwater ensure that groundwater monitoring monitoring to be conducted on spillages, monitoring programme to determine is taking place. The resultant a quarterly basis. unauthorised if there are any impacts on groundwater monitoring reports need groundwater quantity and quality. to be submitted to the DWS and kept The reports will be submitted to Underground disposal of the DWS on a quarterly basis. mining activities at contaminated on record. Waterval Mine substances as well as seepage from mine residue deposits (TSF’s, Waste Rock Dumps and Product Stockpiles).

Surface water runoff may become Implement the surface water contaminated should monitoring programme to determine The Environmental Department is to Mining and mining it come into contact the quality of the water within the ensure that the surface water Surface water monitoring to be related activities at with pollutants dirty water containment facilities monitoring is taking place. The conducted on a monthly basis Waterval East and (chemicals, (sumps, cooling ponds) as well the resultant surface water monitoring and the reports submitted to Waterval West Shaft hydrocarbons, quality of the water within the reports need to be submitted to the the DWS on a monthly basis. and Plant areas. general waste, and adjacent surface water bodies, both DWS and kept on record. coal mining waste / upstream and downstream. product).

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MONITORING AND IMPACTS ROLES AND RESPONSIBILITIES REPORTING FREQUENCY SOURCE REQUIRING FUNCTIONAL REQUIREMENTS and TIME PERIODS FOR ACTIVITY MONITORING FOR MONITORING (FOR THE EXECUTION OF THE IMPLEMENTING IMPACT PROGRAMMES MONITORING PROGRAMMES) MANAGEMENT ACTIONS Surface water runoff from the TSF’s and Activities at the waste rock dumps TSF’s and waste may result in pollution rock dumps. of downstream water resources.

The Environmental Department is to Biomonitoring to be conducted Mining activities at Continue to implement the ensure that the biomonitoring is on a biannual basis (once in Mining and mining Waterval Mine may biomonitoring programme for taking place. The resultant the summer and once in the related activities at impact on the natural Waterval Mine to assess the impact biomonitoring reports need to be winter) and the reports Waterval Mine ecosystem of the Hex on the Hex River ecosystem. submitted to the DWS and kept on submitted to the DWS on a River. record. biannual basis.

A waste monitoring programme is to be developed and implemented as Waste will be per Regulation GNR 634 of 23 generated at the August 2013 under the NEM:WA various areas on the (2008). mine (offices, The Environmental Department is to ablutions, workshops, Sub-regulation 10 of GNR 634 Annual internal and external ensure that all departments at the stores) which may requires the following: audits will be conducted on the Activities that may Mine are keeping accurate and up to result in the commitments as stipulated in result in the Waste generators must keep date records of the waste generated. contamination of the IWWMP and the Water Use generation of waste. accurate and up to date records of The Environmental Department will surface water runoff, Licence and will be submitted the management of the waste they ensure that all waste reports are groundwater to the DWS. generate, which records must combined and kept on record. resources, and soil reflect-the classification of the and may impact on wastes. fauna, flora and visual aspects. The quantity of each waste generated, expressed in tons or cubic metres per month.

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MONITORING AND IMPACTS ROLES AND RESPONSIBILITIES REPORTING FREQUENCY SOURCE REQUIRING FUNCTIONAL REQUIREMENTS and TIME PERIODS FOR ACTIVITY MONITORING FOR MONITORING (FOR THE EXECUTION OF THE IMPLEMENTING IMPACT PROGRAMMES MONITORING PROGRAMMES) MANAGEMENT ACTIONS the quantities of each waste that has either been re-used, recycled, recovered, treated or disposed of. by whom the waste was managed. The records contemplated above must be retained for a period of at least five (5) years. made available to the Department upon request.

Environmental legal compliance The Environmental Department is to audits, including GN704 audits, are ensure that the Environmental Legal The Environmental Legal to be conducted to ensure Compliance audit is to be conducted Compliance audit is to be compliance against all applicable by an independent and suitably conducted on a biennial basis. environmental legislation and qualified individual. policies. Potential The Environmental audit is to Mining and Mining environmental Environmental Audits on the EMPr The Environmental Department is to be conducted on a biennial related activities at impacts resulting from compliance (as per the EIA ensure that the Environmental audits basis (unless otherwise Waterval Mine. the non-compliance Regulations, 2014 (or amendments are conducted by an independent instructed by the DMR), kept with legislation. thereto) are to be conducted. and suitably qualified individual. on record and submitted to the DMR.

The Environmental Department is to The internal and external WUL Internal and external WUL audits ensure that the Environmental audits audits are to be conducted on are to be undertaken as required by are conducted by an independent an annual basis and submitted the Waterval Mine WUL. and suitably qualified individual. to the DWS.

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MONITORING AND IMPACTS ROLES AND RESPONSIBILITIES REPORTING FREQUENCY SOURCE REQUIRING FUNCTIONAL REQUIREMENTS and TIME PERIODS FOR ACTIVITY MONITORING FOR MONITORING (FOR THE EXECUTION OF THE IMPLEMENTING IMPACT PROGRAMMES MONITORING PROGRAMMES) MANAGEMENT ACTIONS The internal WML audit is to be conducted on an annual basis The Environmental Department is to Internal and external WML audits and submitted to the ensure that the Environmental audits are to be undertaken as required by department. The external audit are conducted by an independent the license. is to be conducted on an and suitably qualified individual. biennial basis and submitted to the department.

The Environmental Department is to Mining related The dust fallout and air quality ensure that the dust fallout and air activities including Dust may be The dust fallout and air quality monitoring reports (monthly) quality monitoring is conducted by a the conveyance of generated as a result monitoring plan will be continued are to be submitted annually to suitably qualified individual. The dust ore and the disposal of mining related throughout the Life of Mine in order the DMR and the North West fallout monitoring programme must of mining waste on activities conducted to determine potential impacts and Department of Economic establish a network of monitoring the TSF’s and waste on the surface. sources of dust. Development, Environment, points using method AST D1739 rock dumps. Conservation and Tourism. (1970) or equivalent.

The noise monitoring reports are to be submitted annually to Mining and related The Environmental Department is to the DMR and the North West activities such as the Mining and related The mine will continue to implement ensure that noise monitoring is Department of Economic use of vehicles on activities environmental noise monitoring. conducted by a suitably qualified Development, Environment, roads, crushing etc. individual. Conservation and Tourism generate noise. (along with the dust monitoring reports)

Impacts such as soil The rehabilitation monitoring The Environmental Department will Monitoring of the rehabilitation erosion, deterioration programme will be implemented to ensure that the rehabilitation success will take place for at Decommissioning of vegetation and dust ensure that the rehabilitation monitoring programme is being least 3 years and will include and rehabilitation may result in the techniques that were implemented implemented, the monitoring corrective follow-up action. activities. techniques were implemented event that the are sufficient for the rehabilitation of The rehabilitation monitoring correctly and that no impacts rehabilitation Waterval Mine and that no reports will be submitted to the occurring on the rehabilitated areas. techniques were significant impact (soil erosion, DMR on an annual basis during

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MONITORING AND IMPACTS ROLES AND RESPONSIBILITIES REPORTING FREQUENCY SOURCE REQUIRING FUNCTIONAL REQUIREMENTS and TIME PERIODS FOR ACTIVITY MONITORING FOR MONITORING (FOR THE EXECUTION OF THE IMPLEMENTING IMPACT PROGRAMMES MONITORING PROGRAMMES) MANAGEMENT ACTIONS incorrectly dust, weed and invasive plant the Decommissioning / Closure implemented species establishment) are Phase. occurring on the rehabilitated areas.

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1.9 Programme for reporting on compliance

Unless otherwise instructed by the DMR or as a condition to the authorisation, the Environmental Management Programme Performance assessments (Environmental Audits) will be undertaken on a biennial basis (every two years), and the resultant audit reports will be submitted to the DMR. 1.10 Environmental awareness plan

1.10.1 Manner in which the applicant intends to inform his or her employees of any environmental risk which may result from their work

Formal training will be provided to all employees regarding the hazards of the duties to be performed to both their health as well as the surrounding environment. It is the responsibility of the Mine Manager and the Health and safety officer to ensure that adequate training is provided to all employees. It is also the responsibility of the relevant Head of Departments to identify the need for further training. As part of the mandatory training provided to all employees and contractors, environmental awareness training will be provided, as described in Section 1.10.2 below.

1.10.2 Manner in which risks will be dealt with in order to avoid pollution or the degradation of the environment

The following Environmental Awareness Training will be implemented by Waterval Mine in order to inform employees and contractors of the environmental risk that may result from their work, or the risk of their interaction with the sensitive environment. The training will be conducted as part of the induction process for all new employees (including contractors) that will perform work in terms of the proposed activities. Proof of all training provided must be kept on-site.

The Environmental Awareness Training will, as a minimum cover the following topics: • Air Quality o Activities that may result or mitigate impact on air quality; speeding on roads, covering of haul trucks etc; and o Negative impacts on the receiving environment if mitigation measures are not implemented.

• Surface and groundwater o Risks to surface and groundwater, e.g. fuel and chemical handling and further risks of erosion or damage to riparian vegetation; o How incidents should be reported, and emergency requirements; o The importance of storm water control, maintenance of pollution control infrastructure; and o The importance to reuse water and to prevent spillages.

• Cultural Heritage o To respect all cultures and believes; o To remain within working areas and not to enter or interfere with any cultural heritage; and o How to report any sightings as identified during operation activities (e.g. fossils).

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• Fauna o Overview of the fauna found on site and the uniqueness thereof; o Mitigation measures that all contractors and employees need to abide by; and o No contractor or personnel allowed to catch or kill any species, and how any sightings should be reported if further actions are required (e.g. to catch and release).

• Flora o Overview of the flora diversity on site, and the rare and endangered nature thereof; o Measures taken by the mine to protect species; and o No contractor or personnel allowed to remove, harvest or destroy any flora species unless clearly instructed based on the construction and operational plans.

• Waste management o The correct segregation of general and hazardous waste; o Do’s and don’ts with respect to waste disposal; and o Measures to avoid waste generation and to participate in waste minimisation/reduction strategies.

• Traffic o Abide by traffic rules, no speeding allowed; o To stay on designated roads (and not to drive on areas that are not fit and designed for this purpose); and o To be aware of the fauna species and to be on the lookout and avoid collisions.

• Natural Resource Consumption o Minimise unnecessary use of energy by making use of energy saving devices, switching off non-essential appliances etc.; and o Optimise utilisation of mining and plant equipment, travelling routes etc.

• Emergency Preparedness and Response o Designated smoking areas; o How to report any emergency or incident; and o How to respond when emergency alarm goes off.

• General rules and conduct o Respect for the sensitive environment; o Do not litter; o HIV/AIDS awareness; o Respect for each other and for different cultures; and o Safety and health requirements. 1.11 Specific information required by the Competent Authority

The information, as presented in the table below, will be required by the competent authority.

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Table 97: Monitoring information required by the competent authority

Information Frequency of submission Quantum of Financial Provision Annually

Annual rehabilitation plan Annually

Biennially (every second year) or as Environmental Audit Report on approved EIAR / EMPr and per auditing timeframe indicated in other environmental autthorisations authorisation(s)

Legal compliance audit report, including GN704 audit. Biennially (every second year)

Surface water monitoring Monthly

Biomonitoring Biannually

Groundwater quality monitoring Quarterly

Groundwater level monitoring Quarterly

Fall-out Dust Monitoring and Noise Monitoring Annually

Annually (during Decommissioning Rehabilitation Monitoring Report / Closure Phase)

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2 Undertaking

The EAP herewith confirms • the correctness of the information provided in the reports

• the inclusion of comments and inputs from stakeholders and I&APs ;

• the inclusion of inputs and recommendations from the specialist reports where relevant; and • the acceptability of the project in relation to the finding of the assessment and level of mitigation proposed;

______Signature of EAP Date

3 Declaration of independence

Shangoni hereby declares that it is an independent auditor in that it has no business, financial, personal or other interest in this project in respect of which Shangoni is appointed. Furthermore, no circumstances exist that may compromise the objectivity of Shangoni, excluding fair remuneration for work performed in connection with this project.

Report compiled DRAFT FOR REVIEW Report reviewed by: DRAFT FOR REVIEW by:

Ashley Miller Brian Hayes (Pr Eng)