Integrated Water and Waste Management Plan

REGISTRATION NUMBER: 2018/110720/07

INTEGRATED WATER AND WASTE MANAGEMENT PLAN

APPLICATION FOR A WATER USE LICENCE IN TERMS OF SECTION 40 FOR A WATER USE IN TERMS OF SECTION 21(G) OF THE NATIONAL WATER ACT, 1998 (ACT NO. 36 OF 1998): THE REHABILITATION OF THE HISTORICALLY MINED PIT ON PORTION 15 OF THE FARM JAGERSFONTEIN 14 IS IN THE FREE STATE THROUGH BACKFILLING

OCTOBER 2019

Report prepared by:

REGISTRATION NUMBER: 2018/110720/07

Environmental Assessment Practitioner (EAP) : Louis De Villiers Assistant : Morné van Wyk : Suite 221 Private Bag X01 Postal Address Brandhof 9324 : 21 Dromedaris Street Dan Pienaar Physical Address Bloemfontein 9301 Tel : 072 967 7962 : [email protected] E-mail [email protected]

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Applicant:

Applicant Contact Person : Mr. P. N. Meyer Postal Address : P.O. Box 24 Jagersfontein 9974 Physical Address : Jagersfontein Tailings Operation Jagersfontein Tel : 073 463 1747 E-mail : [email protected]

Site Information:

Property (i.e. farm) name : Jagersfontein Farm Number : 14 Farm Portion : 15 21 Digit Surveyors Code(s) : F01100000000001400015 Magisterial District : Fauresmith District Municipality : Xhariep District Municipality Local Municipality : Kopanong Local Municipality : Lat: -29.771783° Site coordinates (Centre of site) : Long: 25.418445°

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TABLE OF CONTENTS

TABLE OF CONTENTS iii 1. INTRODUCTION 27 1.1 Activity Background ...... 27

1.2 Contact Details ...... 27

1.2.1 Contact details of the Applicant ...... 27 1.2.2 Contact details of the Environmental Consultant ...... 28

1.3 Location of project ...... 28

1.3.1 Regional locality ...... 28 1.3.2 Water management area...... 28

1.4 Property description ...... 29

1.4.1 Landowner ...... 29 1.4.2 Land tenure and use of immediately adjacent land ...... 29 1.4.3 Surface infrastructure and presence of servitudes ...... 30

1.5 Purpose of the IWWMP ...... 31

2. CONTEXTUALISATION OF ACTIVITY 33 2.1 Description of Activity ...... 33

2.2 Extent of activity ...... 35

2.3 Key activity related processes and products ...... 35

2.4 Activity life description ...... 35

2.5 Activity infrastructure description ...... 36

2.6 Key water uses and waste streams ...... 36

2.6.1 Water use activities ...... 36 2.6.2 Key waste streams ...... 36

2.7 Organisational structure of activity/organisation ...... 36

2.8 Jagersfontein Developments (Pty) Ltd Environmental Policy ...... 39

3. REGULATORY WATER AND WASTE MANAGEMENT FRAMEWORK 40 3.1 Summary of all water uses ...... 40

3.2 Existing lawful water uses ...... 40

3.3 Relevant exemptions ...... 40

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3.4 Generally authorised water uses ...... 41

3.5 New water uses to be licensed ...... 41

3.6 Waste management activities (NEMWAA) ...... 42

3.7 Other authorisations and regulations (EIAs, EMPs RoDs) ...... 42

4. PRESENT ENVIRONMENTAL SITUATION 44 4.1 Climate ...... 44

4.1.1 Regional Climate ...... 44 4.1.2 Rainfall ...... 44 4.1.3 Evaporation ...... 45

4.2 Surface water...... 46

4.2.1 Water Management Area ...... 46 4.2.2 Surface water hydrology ...... 47 4.2.3 Surface water quality ...... 49 4.2.4 Mean Annual Runoff (MAR) ...... 49 4.2.5 Resource class and river health ...... 50 4.2.6 Receiving water quality objectives and the reserve ...... 50 4.2.7 Surface water user survey ...... 50 4.2.8 Sensitive areas survey ...... 50

4.3 Groundwater ...... 51

4.3.1 Aquifer characterisation ...... 51 4.3.2 Groundwater quality ...... 51 4.3.3 Hydrocensus ...... 55 4.3.4 Potential pollution source identification ...... 55 4.3.5 Groundwater Model ...... 55

4.4 Socio-economic Environment ...... 55

4.4.1 Population density, growth and location ...... 56 4.4.2 Employment data in Kopanong Local Municipality ...... 57 4.4.3 Income per individual in the Kopanong Local Municipality ...... 57

5. ANALYSES AND CHARACTERISATION OF ACTIVITY 59 5.1 Site delineation for characterisation ...... 59

5.2 Water and Waste Management ...... 59

5.2.1 Process water ...... 59

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5.3 Stormwater (clean and dirty water management) ...... 60

5.4 Operational Management ...... 60

5.4.1 Organisational structure ...... 60 5.4.2 Resources and competencies ...... 60 5.4.3 Education and training ...... 60 5.4.4 Awareness raising ...... 61

5.5 Monitoring and control ...... 61

5.5.1 Surface water monitoring ...... 61 5.5.2 Groundwater monitoring ...... 61 5.5.3 Bio-monitoring ...... 62 5.5.4 Waste monitoring ...... 62

5.6 Risk Assessment / Best Practice assessment ...... 62

5.6.1 Methodology followed ...... 62 5.6.2 Determination of Consequence ...... 62

Rating 63

5.6.3 Determination of Overall Consequence ...... 65 5.6.4 Determination of Likelihood ...... 65 5.6.5 Determination of Overall Environmental Significance...... 67 5.6.6 Aspects which may result in impacts assessed as identified by specialists ...... 68

5.7 Issues and responses from the public consultation process ...... 78

5.8 Matters requiring attention / problem statement ...... 78

5.9 Assessment of level and confidence of information ...... 78

6. WATER AND WASTE MANAGEMENT 79 6.1 Water and Waste Management Philosophy ...... 79

6.1.1 Surface water philosophy ...... 79 6.1.2 Groundwater philosophy ...... 79 6.1.3 Stormwater ...... 79 6.1.4 Waste ...... 79

6.2 Strategies ...... 79

6.2.1 Surface water...... 79 6.2.2 Groundwater ...... 80 6.2.3 Stormwater ...... 80

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6.2.4 Waste ...... 80

6.3 Performance objectives / goals ...... 80

6.4 Measures to achieve and sustain performance objectives ...... 81

6.5 Options analyses...... 81

6.6 IWWMP Action Plan ...... 81

6.6.1 Short term actions:...... 84 6.6.2 Medium term actions: ...... 84 6.6.3 Long term actions: ...... 84

6.7 Control and monitoring ...... 84

6.7.1 Monitoring of change in baseline information ...... 85 6.7.2 Audit and report on performance of measures ...... 85 6.7.3 Audit and report on relevance of action plan ...... 85

7. CONCLUSION 86 7.1 Regulatory status of the activity ...... 86

7.2 Statement on water uses requiring authorisation, dispensing with the requirement for a license and possible exemption from Regulations ...... 86

7.3 Section 27(1) motivation ...... 86

7.3.1 Section 27(1)(a): Existing Lawful Water Uses ...... 86 7.3.2 Section 27(1)(b): The need to redress the results of past racial and gender discrimination...... 87 7.3.3 Section 27(1)(c): Efficient and beneficial use of water in the public interest ...... 87 7.3.4 Section 27(1)(d): The socio-economic impact – ...... 87 7.3.5 Section 27(1)(e): Any catchment management strategy applicable to the relevant water resources 88 7.3.6 Section 27(1)(f): The likely effect of the Water Use to be authorised on the water resource and on other Water Users ...... 88 7.3.7 Section 27(1)(g): The class and the resource quality objectives of the water resource ...... 88 7.3.8 Section 27(1)(h): Investments already made and to be made by the Water User in respect of the Water Use in question ...... 88 7.3.9 Section 27(1)(i): The strategic importance of the Water Use to be authorised ...... 89 7.3.10 Section 27(1)(j): The quality of water in the water resource which may be required for the Reserve and for meeting international obligations ...... 89 7.3.11 Section 27(1)(k): The probable duration of any undertaking for which a Water Use is to be authorised 89

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7.4 Key commitments ...... 89

8. REFERENCES AND SPECIALIST STUDIES 90

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LIST OF TABLES

Table 1: Licensed water uses by applicant ...... 22 Table 2: Property details ...... 29 Table 3: Adjacent landowners and related land use ...... 29 Table 4: Summary of all water uses ...... 40 Table 5: Average monthly rainfall ...... 44 Table 6: Net evaporation ...... 45 Table 7: Catchment runoff calculation ...... 50 Table 8: Surface areas and estimated population density for the Free State Province, the Xhariep District- and Kopanong Local Municipalities (Statistics SA, Census 2007) ...... 56 Table 9: Percentage of the population of Kopanong Local Municipality by age and gender (Statistics SA, Census 2011) ...... 56 Table 10: Income in Kopanong Local Municipality ...... 57 Table 11: Rating of Severity ...... 63 Table 12: Rating of Duration ...... 64 Table 13: Rating of Extent ...... 65 Table 14: Example of calculating Overall Consequence...... 65 Table 15: Rating of Frequency ...... 66 Table 16: Rating of Probability ...... 66 Table 17: Example of calculating the Overall Likelihood...... 66 Table 18: Determination of Overall Environmental Significance...... 67 Table 19: Description of the Environmental Significance and the related action required...... 67 Table 20: Performance objectives for Jagersfontein Developments ...... 80 Table 21: IWWMP Action Plan ...... 81

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LIST OF FIGURES

Figure 1: Historical annual rainfall data (SRK, 2019) ...... 18 Figure 2: Average monthly rainfall data (SRK, 2019) ...... 18 Figure 3: MAR of the study area marked with red circle ...... 19 Figure 4: MAE map of the Study Area marked with red circle ...... 20 Figure 5: NW-SE geological section through the Pit ...... 21 Figure 6: Jagersfontein Developments (PTY) Ltd company structure ...... 37 Figure 7: Jagersfontein Developments (PTY) Ltd board of directors ...... 37 Figure 8: Jagersfontein Developments (PTY) Ltd company management team ...... 38 Figure 9: Climate in Jagersfontein ...... 44 Figure 10: Jagersfontein quaternary region C51H ...... 47 Figure 11: Indication of catchment areas of the Operational Area (O.J. Gericke, 2013) ...... 48 Figure 12: 2011 and 2012 Water sampling boreholes (Bijengsi, 2013) ...... 52 Figure 13: Distribution of boreholes in Jagersfontein during 2011 and 2012 (Bijengsi, 2013) ...... 52

LIST OF APPENDICES

Appendix A: Maps

Appendix B: Specialist Reports

Appendix C: Public Participation

Appendix D: Environmental Management Programme reports and Monitoring Plans

Appendix E: CVs

Appendix F: Water Balance and Quality Results

Appendix G: Other Information

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EXECUTIVE SUMMARY

Jagersfontein Developments (Pty) Ltd (“JD”) proposes to rehabilitate the historically mined pit (the "Pit" or "Site") on Portion 15 of the Farm Jagersfontein 14 IS, Fauriesmith District, Free State ("Farm Jagersfontein") as part of an initiative to restore the Pit's safety and to rehabilitate the surrounding environment, which will be done by removing the surface tailings dumps from the surface and backfilling the material into the Pit to create more space for agricultural activities. Portion 15 of the Farm Jagersfontein ("Portion 15") is owned by JD.

The rehabilitation initiative will involve infilling the Pit with fine and coarse tailings ("Backfill Material") generated from JD's existing diamond extraction Plant (the "Plant") to make the bottom of the Pit shallower (the "Project").

The Project will require a water use licence from the Department of Human Settlements, Water and Sanitation (“DHSWS”), in terms of section 40 of the National Water Act, 1998 (Act No. 36 of 1998) (“NWA”), for the undertaking of a water use in terms of Section 21(g) of the NWA.

This report is developed in support of the Water Use Licence Application (“WULA”). According to a Geochemical Analyses conducted on the tailings and paste, it was concluded that the paste is potentially a Type 3 waste, which will require a liner consistent with a Category C liner. However, it was also found that the Backfill Material is sterile and immobile in this environment. A Geohydrological Study compiled by GHT Consulting ("GHT") in 2017 ("GHT 2017 Geohydrological Study") indicated that it is more beneficial to backfill the Pit than to develop additional surface storage facilities.

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The Pit was formed in the 1870s when the Farm Jagersfontein was proclaimed a public digging. It is the biggest hand-excavated hole in the world and, given its historical value, is a heritage resource under section 3 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) (“NHRA”). The Pit has, however, not been given any formal protection by the South African Heritage Resources Agency (“SAHRA”) or the Free State Heritage Resource Authority (“FSHRA”) under the NHRA.

It has an extent of 19.635ha and is a near-vertical sided hole, with some of the faces being more than 200m in height. The Pit is unstable, breaking back and poses vibration risks. The Pit's instability presents a very serious safety risk, potentially placing local residents at risk in the long term. Due to the safety risks, it cannot be accessed by the public and is therefore closed for public viewing.

JD appointed a geotechnical and structural engineering specialist, Dr. Graham Howell (Professional Civil Engineer, Corporate Consultant and ex-Chairman of SRK Consulting (SA) Pty Ltd ("SRK")), who has undertaken extensive and on-going assessments. Dr. Graham Howell has confirmed that using tailings for the Pit's rehabilitation is the only viable and practical way to ensure its stability and eliminate associated risks. Please refer to the Jagersfontein Pit Backfill Design Report by Dr. G. Howell1 attached in Appendix B.

The Farm Jagersfontein is scarred from mining operations that have been conducted for over 100 years and is in a state of environmental degradation. Processing of the tailings dumps and backfilling them into the Pit is an environmentally sound project, which will lead to land rehabilitation. A calculation by Dr. Howell indicated that, with the volume of tailings available to be processed, the Pit will be backfilled to a depth of approximately 30m from the top. This is however dependent on when the Backfilling will commence, and the volume of surface tailings available for reprocessing at that stage. If the Backfilling is authorized early, it is expected that this void will be smaller, as there will be more tailings available for backfilling of the Pit. The opposite is true should the project commence very late.

JD's surface tailings processing operations (“Tailings Operation”) and the Plant are situated in the Xhariep District Municipality of the Free State Province. The Tailings Operation entails reprocessing eleven tailings dumps, where coarse tailings from historic diamond mining operations have been discarded (the "Tailings Dumps") at the Plant. JD purchased the Tailings Dumps from De Beers Consolidated Mines Ltd ("De Beers") in 2010.

The operational area of the Tailings Operation extends over Portion 16 and the Remaining Extent of the Farm Jagersfontein (the “Operational Site”), with a combined area of 5, 945ha. Portion 15 does not form part of the Operational Site.

Currently the Tailings Operation utilises the existing Fine Tailings Storage Facilities ("FTSF") for storage of the fine tailings from the Plant. Coarse tailings are returned to the existing footprints from where they were

1 Jagersfontein Pit Backfill Design report, compiled by Dr. Howell of SRK, Report Number 445072/3, dated July 2019 ("SRK 2019 Report").

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removed and used to stabilise the FTSF's walls. The FTSF's footprint is currently approximately 110 ha. Although the FTSF's capacity can be increased, it currently has the capacity to store material for approximately 1 more year. The continued storage of the tailings in aboveground facilities will require an additional FTSF to be constructed at a different location to the existing one. "This new facility would further sterilise another 100 Ha of surface area to a height of some 33m and, in addition, act as a potential pollution source for the upper aquifer (up to 20m below surface), from which water is currently abstracted in the area".2

However, it was determined by Dr. Howell that the coarse and fine tailings can be utilised for infilling to rehabilitate the Pit. Other than assisting in the rehabilitation of the surface area, this will restore the Pit's stability. It will also remove all current tailings from the Operational Site, ensuring more effective rehabilitation of this Site and creating opportunities for agricultural development. The Pit's rehabilitation will also lessen the groundwater impacts on the shallow aquifer, currently caused by the presence of tailings on the Operational Site.

The total volume of tailings still to be processed on the surface of the Tailings Operation is approximately 36 Million tons (“Mt”), of which 25.6 Million cubic metres (“Mm3”) will be tailings backfilled into the Pit. The ‘usable’ volume of air space in the Pit (to level 1400mamsl) is 31Mm3. Accordingly, the remaining Backfill Material will only fill to Pit to a level some 30m below the rim (1371mamsl). From a historical and tourism viewpoint, therefore, the Pit's unique geology will still be observable once the Operations cease. In addition, the current potentially unstable Pit slopes will be buttressed by the Backfill Material and further break-back (towards the Jagersfontein Town and surrounding) will be mitigated. Since the Backfill Material will only reach to a level of 1371mamsl, which is below the upper aquifer depth, no effect on the regional usable aquifer will result.

Processes undertaken at the Tailings Operation include the ploughing and / or ripping of the Tailings Dumps to loosen tailings before they are loaded onto conveyors, which transports the tailings to the Plant. The Plant consists of 4 X 75 tons/hour Dense Medium Separator Plants, which are used to separate the mineral particles in a sink-float process. A suspension of dense powder in water is used, which forms a heavier liquid, for the separation. This causes the heavier material, containing diamonds, to sink and the lighter material to float. The material is further separated into coarse tailings and fine tailings suspended in water. The fine tailings are then further dewatered to a ‘paste’ before being deposited. These products will be used to rehabilitate the Pit. The Plant has a minimum processing target of 300 tons of tailings per hour. JD has also introduced a pan plant in early 2019, which increased run of mine) production to 700tons per hour.

Alternatives

The following alternatives were considered:

2 SRK 2019 Report

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1. Location alternatives:

Given that the existing Pit needs to be rehabilitated at its current location on Portion 15, there are no location alternatives.

2. Alternative methods to backfilling the Pit

2.1. Fencing

The only feasible alternative to backfilling the Pit with Backfill Material is through maintaining the fence around it on the surface, to prevent people and larger animals from entering the area. The fence, however, provides no absolute barrier against trespassing. Furthermore, the Pit's instability will persist, with the potential risk that vibrations and break-back of the Pit's walls might cause injuries to trespassers or damage to surrounding property and the fence itself. Break-back episodes are intermittent and unpredictable. Regular survey and drone surveys are performed. Current activity is only a minor erosional process, but large block-break back can always be expected and has occurred in the form of boulders falling into the Pit during heavy rain events.

2.2. Civil Engineering Stabilisation Mechanisms

Dr. Howell investigated whether there are any civil engineering mechanisms that could be used to stabilise the Pit. He concluded that it is impractical to carry out any stabilisation work due to the geological circumstances present at the Pit. If it were possible, it would be a world first; the most challenging endeavour of its kind in the world and extremely expensive. This is discussed further in section 5 below; however, given that stabilisation work is not feasible, it is not assessed as an alternative in this report.

3. Technological alternative (i.e. infilling of material):

3.1. Method of transportation of material into the Pit

The preferred method of transportation and infilling of the Backfill Material is via a conveyor and pipe. A conveyor will be used to transport coarse tailings, whilst the paste will be transported via a pipe.

An alternative mode of transportation of the Backfill Material to the Pit will be the use of trucks. However, due to fuel consumption, it will be very costly and have a larger carbon footprint (due to burning of fossil fuels) and physical footprint (as a result of the roads). Travelling on dirt roads by truck will also create higher emissions of dust. Due to safety reasons, the trucks will also not be permitted to enter the area close to the Pit and use of a shorter conveyor and pipe will be required near the Pit.

3.2. Method of infilling

The proposed method of infilling will involve the constant change of the tailings discharge point into the Pit, and also the type of tailings discharged into it, to ensure a balance between coarse tailings and the paste. Coarse tailings will be discharged into the Pit from the southern rim adjacent to the main shaft,

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while the Paste will be piped into the Pit on the eastern side. Coarse tailings will be used to “line” the Pit's base and form a base layer or “filter blanket” on the southern side of the Pit. This “filter blanket” will have an initial thickness of 10m, which will increase as deposition continues. The Paste will only be introduced to the Pit's eastern flank in the fourth month after commencement of the coarse tailings’ deposition. Due to the density of the paste being lower than that of the coarse tailings, it will remain above the coarse tailings. “The continued deposition of tailings from the south rim, will displace the slimes slurry laterally and upwards (sink to the bottom as has been the case at DeBeers pit in Kimberley and as observed from the Jagersfontein surface tailings/slimes dam)” (SRK 2019 Report). Deposition of tailings and paste will take approximately 6 years at current production rates.

An alternative method to infilling the Pit is to establish one point from where coarse tailings and the paste are discharged into the Pit. This will entail the co-disposal of coarse tailings and paste. This method will result in unpredictable movement of the paste, as the mixture will be dominated by the mobility of the paste. Thus, there will be no base layer.

3.3. Lining

It was determined that the tailings are classified as a Type 3 waste which, in terms of the National Norms and Standards for Disposal of Waste to Landfill, published under NEMWA in GN R636 of GG 36784 of 23 August 2013 (Landfill Norms and Standards), requires a liner consistent with a Class C barrier system.

Due to the Pit’s size, depth, inaccessibility and the significant health and safety risks associated with lining it, a liner of this type is unpractical, if not impossible. Even if it was possible, the costs of such a lining would make it unfeasible. Furthermore, groundwater modelling indicated, through simulations, that the migration of the pollution plume from the filled Pit will be limited, due to the:

• fact that the Pit would not be filled to the surface, and therefore the filling would not reach the base of the exploitable aquifer; and

• geohydrological properties of the paste (as discussed in Section 3.2).

(Please refer to Chapter 9 of the GHT 2017 Geohydrological Study attached in Appendix B).

The need to backfill the Pit due to the safety risk it poses clearly outweighs any need to line it due to low pollution risks.

3.4. No Go: The Pit will not be rehabilitated by infilling

Should the no-go option be chosen, the Pit will not be backfilled with tailings and be left dormant. The coarse tailings and paste will then be disposed of into a FTSF. Due to the limited capacity of the existing FTSF, a new facility will have to be constructed for the storage of material. However, due to the elevated costs associated with this option, it is not regarded as economically feasible. The Pit would remain fenced and access-controlled to render it safe. Furthermore, the construction and use of an additional surface FTSF will result in impacts on the exploitable upper aquifer and create a further loss of land due to the

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FTSF's footprint. A new FTSF will also likely have a negative impact on hydrology and surface water quality. The quantity of natural runoff will also be reduced, as it (i.e. rainfall) will be retained in the FTSF.

PROCESS DESCRIPTION

JD exploits the old Tailings Dumps purchased from De Beers in 2010. Methods undertaken at the Tailing Operation include the ploughing and/or ripping of Tailings Dumps to loosen tailings before they are loaded onto conveyors and/or trucks, which transport it to the Plant. The Plant consists of 4 X 75 T/hour DMS plants, which are used to separate the mineral particles in a sink-float process. A suspension of dense powder in water is used, which forms a heavier liquid, for the separation. The heavier material containing diamonds will thus sink and the lighter material will float.

A pan plant was also introduced in 2019 to further separate material into concentrate (which carries the diamonds) and excess material (used for the stabilization of the FTSF walls). The concentrate still passes through the x-ray machine and sorting house used at the DMS plant.

From the Plant the material is separated into the coarse tailings and paste, which is transported to the existing FTSF located on the Remainer of the Farm Jagersfontein 14 IS. While the coarse tailings are used for the stabilisation of the walls of the FSTF, the paste is stored inside it. However, the FSTF is near capacity and has a lifetime of approximately 1 more year until capacity is reached, based on the existing design of the plant and facility. JD therefore proposed to rehabilitate the Pit, using the coarse tailings and paste, by backfilling the Pit to a depth of approximately 30 mbgl. This option was chosen to prevent the construction of another surface FTSF at a different location, which is not economically feasible. The construction of another surface FTSF will also have additional environmental impacts, and it will result in a loss of land to the extent of more than 100 ha and airspace of approximately 33 m.

The proposed process for the backfilling of the Pit will entail the following as per the SRK 2019 Report of 2019:

“Since access to the pit, either from surface or from underground, is not possible, the only practical way to fill the pit is from the rim. The proposed filling process of the tailings is from the south rim adjacent to the Main Shaft via conveyor from the plant, while the slimes will be piped from the plant to a discharge point on the eastern side of the pit.

The main constraint considered in this procedure is the ‘protection’ of the main shaft area and the floor of the pit using tailings which will be deposited from the south rim for a period of three months prior to commencement of slimes deposition. The following aspects are integral components/constraints for the backfilling procedure:

• The main shaft currently houses water pumps at the 450m level. These pumps provided process water for the plant only. The pumps have been installed (remotely) down the Main Shaft to the

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extraction level even though physical access is not possible (as confirmed by C&A Mining exploration Consultants).

• The water in the Main shaft is derived mainly from stormwater run-off into the pit from the western and north-western catchment areas together with some minor seepage from the deep aquifer via the (abandoned) underground workings.

• Physical inspection of the pit and the shaft have deduced that there are no open adits or tunnels from the pit walls into the shaft area. Seepage of water is therefore concluded to be through the erosion sediments at the base of the pit and via the block cave material below that level (±275m below surface). The water pumped is clean and devoid of sediments thus indicating that there is no piping or sediment transport into the shaft area.

• In order to protect the base of the pit and the southern (main shaft) wall, tailings will be deposited first in this area to form a “filter blanket” of a minimum thickness of 10m initially and increasing in thickness as deposition continues.

• The slime slurry will be introduced by pipeline for the eastern flank of the pit in month four after commencement of tailings deposition.

• Since the slimes slurry is less dense than the tailings, the slurry will remain above the tailings (Section 6.2.3 of the SRK Report). The continued deposition of tailings from the south rim, will displace the slimes slurry laterally and upwards (sink to the bottom as has been the case at DeBeers pit in Kimberley and as observed from the Jagersfontein surface tailings/slimes dam).

• The tailings will act as a water filter (see the assessment of filter characteristics in Section 6.2.2 of the SRK Report) and progressively enhance/prevent piping/internal erosion into the main shaft area, thus ensuring the continued availability of water to the pumps.

• Continued deposition of the tailings and slimes slurry will progressively buttress the southern flank with tailings and develop a pool of slimes slurry towards the north, west and eastern side of the pit. The deposition of the tailings has been assessed (calculated) to remain proud of the slurry surface until late in the backfilling process (at the end of the 6th year of deposition of 6 years).

• Deposition is programmed to take about 6 years (72 months) at the current production levels. Recently a new pan plant has been installed that will increase the ROM production to 700tph (tons per hour) – or 504 000tpm (tons per month). Tailings production is 396 000tpm and Slime slurry is 153 000m3/m (cubic metres per month) including makeup water. The total ROM still to be processed is estimated to the 36Mt (million tons). Further assessment of the volumes and rates of rise are contained in Section 7 of the SRK Report.

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the stormwater close to the tailings deposition point and facilitate water seepage into the main shaft area. This has been considered in Section 6.5 of the SRK Report.

• The two main catchment areas (Section 6.5 of the SRK Report) that report to the Open Pit are from the west and northwest, with a minor catchment for the northeast (town) area. Currently the western catchment (Loskop dam) discharges into the pit via the southern culvert. The North Catchment discharges via the North Dam (north of the Fauresmith road) into the northwestern area of the pit. It is proposed that consideration be given, during the detailed design phase, to upgrading the North, Loskop and Moon dams and channeling the stormwater toward the southern culvert entry point in order to optimise the use of run-off into the pit. Alternatively, it must be recognised, that the stormwater from the Northern catchment will naturally (following the current contours and flow paths) enter the pit directly into the slurry area during the latter part of the deposition cycle.”

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ENVIRONMENTAL DESCRIPTION

The Pit is situated in the Upper Orange Water Management Area in the Riet-Modder Catchment, and in quaternary catchment C51H. There are no major rivers that extends through the Site on which the Tailings Operation or the Pit is located.

The Pit is situated in a semi-arid region with an average annual rainfall of 420mm (Refer to the SRK 2019 Report attached as Appendix B). Jagersfontein is within a summer rainfall area, with peak rainfall occurring in February and March. Winter frost is very common in the region for about 50 days annually on average (Mucina & Rutherfort, 2006).

Figure 1: Historical annual rainfall data (SRK, 2019)

Figure 2: Average monthly rainfall data (SRK, 2019)

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The Site is within Rain Zone C5B and receives a Mean Annual Rainfall (“MAR”) of between 400 and 500mm, according to the Water Resource Commission in 2005 (“WRC”). The Mean Annual Evaporation (“MAE”) of the Site is between 1 800 to 2 000mm and the Site is in Evaporation Zone 19A, according to the WRC.

Figure 3: MAR of the study area marked with red circle

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Figure 4: MAE map of the Study Area marked with red circle

The geology of the area consists of Karoo shales of the Karoo Supergroup intruded by dolerite sills. This can be observed through the cross section of the geology of the Pit in Figure 5 below. The Kimberlite pipe intruded through the Karoo Supergroup sediments and the dolerite intrusive sill complexes.3

3 SRK Consulting (2012) Review of Jagersfontein Pit Stability and Backfilling Options

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Figure 5: NW-SE geological section through the Pit

The Pit itself has vertical walls comprised of a succession of alternating dolerite and sandstone, which also forms the barrier between the upper and lower aquifer. The bottom of the Pit is filled with break-back material, continually falling into the Pit as a result of erosion and structural failures, which also poses a safety hazard. There are very little fauna present in the Pit apart from “a pair of Verreaux’s (Black) Eagles (Aquila verreauxii) inhabiting the cliffs of the Pit. The species is widespread and not regarded as endangered. The species is therefore not considered of significant concern” (Van Rensburg, 2013). Scattered vegetation is visible on the collapsed banks of the Pit's side walls.

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WATER SYSTEM CHARACTERISATION

Jagersfontein is situated in the Upper Orange Water Management Area (“WMA”). The Quaternary Catchment of the Operational Site is C51H.

No major rivers or streams are located on the Operational Site. There is a non-perennial stream located on the Operational Site, to the south of the Main Tailing Dump (“MTD”) and Plant. Stormwater from the Tailings Dumps drains into the non-perennial stream, which drains into Dam 10 located on the Remainder of the Farm Jagersfontein 14 IS. The catchment outside the Dam 10 catchment drains into the Proses Spruit, a perennial stream located outside the Operational Site, flows north into the Kromellenboogspruit which in return flows north into the Riet River. The Riet River is a perennial River that flows westwards until it is dammed by the Kalkfontein Dam, which is situated approximately 34 km north west of the operational area (Van Rensburg, 2013).

The Jagersfontein area consists of a shallow upper aquifer and deep-seated aquifer, which are separated from one another through the presence of large dolerite sills. The shallow aquifer is classified as being a low yielding aquifer of relatively good water quality, consisting of sandstone and shale, with the shale and weathered dolerite acting as water barriers. This shallow aquifer is found between 5 – 70 mbgl. The deep- seated aquifer, consisting of sandstones, is around 200 mbgl and is situated between layers of massive dolerite sills, which create the contact zones for water to accumulate. The water abstracted from this aquifer is done so through the old mine shaft. Refer to the Impact Assessment of the Diamond Recovery Operation at Jagersfontein on Surface and Groundwater Resources (2013) by Mr. G. J. Hoon (Eko Environmental) in Appendix B.

The Tailings Operation make use of various water resources located on farms adjacent to Pit. This water is mainly abstracted from the shallow aquifer from boreholes and surface water resources (i.e. Dam 10 and Loskop Dam). The shaft used to access the underground workings in the Pit is located on Portion 15 and is used for the abstraction of water from the deep aquifer for use in the process plant. Table 1 indicates all the water uses authorised and the water use applied for with this WULA.

Table 1: Licensed water uses by applicant

Water use in terms of Jagersfontein Jagersfontein Jagersfontein Vlakfontein Rietkuil 21/RE Section 21 of 14/RE 14/16 14/15 1173/1 the NWA

• Abstraction of • Abstraction of Abstraction of Abstraction of Abstraction of 21(a): Taking groundwater groundwater water from the water from a water from a water from a from Borehole 4 from Borehole shaft borehole on the borehole on the water resource. (Domestic use). 7 for use at the farm for use in farm for use in Plant. the Plant. the Plant.

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Water use in terms of Jagersfontein Jagersfontein Jagersfontein Vlakfontein Rietkuil 21/RE Section 21 of 14/RE 14/16 14/15 1173/1 the NWA

• Abstraction of • Abstraction of water from water from Dam 10. Loskop Dam.

• Process water • Loskop Dam 21(b): Storage dam; of water • Dam 10.

21(c): Impeding • Construction of the flow of a crossing in a water in a watercourse watercourse

21(i): Altering • Construction of the bed and a crossing in a banks of a watercourse watercourse

21(g): • Storage of Disposal of fine tailings in waste or water the FTSF. containing waste in a manner which may have a detrimental impact on a water resource

MANAGEMENT PROGRAMMES

Waste minimisation, disposal and recycling

Waste generation at the Tailings Operation is minimised as far practicable possible. JD manages solid waste generated in accordance with its Environmental Management Plan (“EMP”) on waste (attached hereto in Appendix D). The main objectives of the waste management implemented at the Operation is to prevent and / or limit any potential impacts from waste generation, storage and management through the implementation of appropriate waste management measures, in accordance with the applicable legislative requirements. This includes the following:

• Characterisation of the waste;

• Separation of waste into the different waste streams;

• Re-use of waste where possible; and

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• Recycling of recyclable waste (e.g. scrap metal, old oil, etc.).

This IWWMP is a supplementary report to a WULA in terms of Section 21(g) for the disposing of waste in a manner which may detrimentally impact on a water resource. The rehabilitation of the Pit is a rehabilitation project, whereby the Pit will be backfilled with coarse and fine tailings.

Water Use Efficiency

Water is abstracted from Borehole 4 (BH 4) for potable water for domestic use at the site offices, the Plant and staff houses.

To ensure the efficient use of water, JD makes use of Purified Sewage Effluent (“PSE”) abstracted from the final maturation pond of the STP. This water is used in the Plant to limit the use of water abstracted from natural water resources.

Water used in the Plant is recycled continuously and the necessary measures have been implemented to optimally recover water from it.

Seepage from the FTSF is collected in a trench and sump at the lowest wall and pumped from the sump and reused at the Plant.

During the Pit rehabilitation project these measures will still be implemented to use water efficiently. Other measures will also be investigated throughout the project lifetime and implemented where necessary.

Water containing waste

Process Water Dams ("PWDs") The plant has one lined PWD, which stores recycled water from the Plant and water abstracted from the shaft.

A control dam is also used to collect all water abstracted from various sources from where it is pumped to the process.

Return Water Dams Seepage from the FTSF collects in a sump; from where it will be reused in the Plant. These are Seepage 1, located between the FTSF and Dam 10, and Seepage 2 which is located east of the FTSF at the foot of the FTSF wall.

FTSF Tailings produced by historical diamond mining activities are being reprocessed. Coarse tailings produced by the current processing operations are used to stabilize the fine FTSF's walls and is stored on the previously disturbed footprints.

The paste from the operation are stored in the FTSF on the Operational Site, which was constructed and used by De Beers during historic mining activities.

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Pit The paste to be discharged into the Pit contains approximately 58% water and 42% fine tailings and can therefore be regarded as water containing waste. Furthermore, the Backfill Material was classified as a Type 3 waste by SRK in the 2016 Waste Classification Report.

Stormwater management

Stormwater management measures, such as diversion berms and trenches, are implemented on all operational areas, in order to separate clean- and dirty storm water.

Due to Dam 10's location, stormwater from the Dam 10 catchment area (Catchment A in the "Surface Water Resource Assessment by O. J. Gericke in 2013) will drain to Dam 10. Water from Dam 10 will not drain to the Process Spruit, or any other sources located downstream from it as the water from Dam 10 will be used at the processing plant. Any run-off from the Tailings Dumps and FTSF's walls will be captured by trenches and channels around these facilities and re-used in the Plant.

During the backfilling of the Pit, berms will be built around it, on the north-eastern to the north-western side, to stop the natural flow off clean surface runoff entering the pit and effectively to divert the stormwater around it. This water originates from the North Dam catchment area, near the Fauresmith road tailings area, and flows naturally towards the Pit. Before any backfilling occurs, the North Dam’s walls need to be upgraded to contain this water and create an overflow away from the Pit, which will subsequently have to drain into the Loskop Dam.

Groundwater management

The main objectives of groundwater management during the operational phase at the Tailings Operations and the Pit's rehabilitation are as follow:

• Contain pollution as far as is practicably possible;

• Do not abstract water exceeding the safe yield of groundwater resources;

• Implement the SRK design during the Pit's backfilling and follow the requirements and guidelines of the method proposed;

• Conduct regular monitoring of the groundwater in both the shallow and deep aquifer;

• Reduce groundwater contamination caused by the seepage of water from FTSF;

• Minimize the spillages of water in the Plant during the processing of tailings; and

• Implement continued groundwater monitoring in accordance with the operations water monitoring program (attached hereto in Appendix D).

The main operational objective is to limit residual impacts related with groundwater pollution and ensure sustainable use of groundwater.

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As part of the proposed backfilling of the Pit the shaft will be monitored for water quality, to determine if the backfilling of the Pit causes contamination of the lower aquifer through the deposition of fine tailings. The shaft is already part of the Surface and Groundwater Monitoring Program (“SGMP”), which is monitored quarterly.

Remediation and rehabilitation

JD plans to rehabilitate the Pit and the surrounding area by depositing the tailings into the Pit. This proposed rehabilitation aims to limit further break-back in the Pit and to clean the environment of pollution sources (i.e. Tailings Dumps). The removal and rehabilitation of the surrounding land will improve the land use in the area and the land can again be used for other purposes.

Water monitoring

Surface water There are two surface water resources being used on the Jagersfontein properties. Dam 10 is located directly south of the FTSF and all the surrounding water drains into it. Loskop Dam is located upstream and north-west of the Plant. Dam 10 water is used in the Plant as process water. Very little water from the Loskop Dam has been used to date. Both these sources are monitored quarterly, through water sampling, and results are sent to DHSWS.

Samples of all the surface water resources are taken on a quarterly basis, analysed in a laboratory for the chemical and micro biological elements and then compiled into a report, which is sent to DHSWS.

Groundwater A groundwater monitoring network was established, whereby 6 boreholes are used to monitor the quality of groundwater in the shallow aquifer and the water in the deep aquifer is monitored from the Shaft.

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1. INTRODUCTION

1.1 Activity Background

JD proposes to rehabilitate the historically mined pit on Portion 15 as part of an initiative to restore its safety and rehabilitate the surrounding environment, which will be done by removing the surface Tailings Dumps from the surface and backfilling the material into the Pit to create more space for agricultural activities.

JD's Tailings Operation and the Plant are situated in the Xhariep District Municipality of the Free State Province. The Tailings Operation entails reprocessing the eleven Tailings Dumps, where coarse tailings from historic diamond mining operations have been discarded at the Plant. JD purchased the Tailings Dumps from De Beers in 2010, where after the reprocessing commenced.

The Pit was formed in the 1870s when the Farm Jagersfontein was proclaimed a public digging. It is the biggest hand-excavated hole in the world and, given its historical value, is a heritage resource under section 3 of the NHRA. The Pit has, however, not been given any formal protection by the SAHRA or the FSHRA under the NHRA.

It has an extent of 19.635ha and is a near-vertical sided hole, with some of the faces being more than 200m in height. It is unstable, breaking back and poses vibration risks. The Pit's instability presents a very serious safety risk, potentially placing local residents at risk in the long term. Due to the safety risks, it cannot be accessed by the public and is therefore closed for public viewing. The rehabilitation initiative will involve infilling the Pit with Backfill Material generated from JD's existing diamond extraction Plant to make the bottom of the Pit shallower.

The Farm Jagersfontein is scarred from mining operations that have been conducted for over 100 years and is in a state of environmental degradation. Processing of the Tailings Dumps and backfilling them into the Pit is an environmentally sound project, which will lead to land rehabilitation. A calculation by Dr. Howell indicated that, with the tailings volume available to be processed, the Pit will be backfilled to a depth of approximately 30m from the top. This is however dependent on when the backfilling will commence, and the volume of surface tailings available for reprocessing at that stage. If the backfilling is authorized early, it is expected that this void will be smaller, as there will be more tailings available for the Pit's backfilling. The opposite is true should the project commence very late.

1.2 Contact Details

1.2.1 Contact details of the Applicant

Applicant: Jagersfontein Development (Pty) Limited

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Registration No.: 2010/025335/07

Postal address: Jagersfontein Developments (Pty) Ltd

P.O. Box 24

Jagersfontein

9974

Contact person: Mr. Pieter Nicolas Meyer

Tel. No.: 073 463 1747

E-mail: [email protected]

1.2.2 Contact details of the Environmental Consultant Name: Turn 180 Environmental Consultants

Postal address: Suite 221

Private Bag X01

BRANDHOF

9324

Contact person: Mr. Louis De Villiers

Tel. No.: 072 967 7962

E-mail: [email protected]

1.3 Location of project

1.3.1 Regional locality Province: Free State Province

Magisterial Districts: Jagersfontein

District Municipality: Xhariep District Municipality

Local Municipality: Kopanong Local Municipalities

The nearest town to the operations: Jagersfontein

1.3.2 Water management area Jagersfontein is situated in the Upper Orange Water Management Area. The Quaternary Catchment of the operational area is C51H.

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No major rivers or streams are located on the the Operational Site. There is a non-perennial stream located on the operational area to the south of the Main Tailing Dump (“MTD”) and the Plant. Storm water from the Tailings Dumps drains into the non-perennial stream, which drains into Dam 10. The catchment outside the Dam 10 catchment drains into the Proses Spruit, a perennial stream located outside the the Operational Site, flows north into the Kromellenboogspruit, which in return flows north into the Riet River. The Riet River is a perennial River that flows westwards until it is dammed by the Kalkfontein Dam, which is situated approximately 34 km north west of the the Operational Site (Van Rensburg, 2013).

1.4 Property description

1.4.1 Landowner The Farm name and landowner of the Farm on which the proposed water uses will be conducted are listed in Table 3 for ease of reference. Also refer to the Locality map indicating the locality of the different farms in Appendix A for reference.

Table 2: Property details

Farm name Portion Title deed number Surface owner

Jagersfontein Developments (Pty) Jagersfontein 14 15 T1157/2011 Ltd

1.4.2 Land tenure and use of immediately adjacent land The main land uses of land adjacent to the land used for the Tailings Operations are agriculture (mainly grazing) and urban settlement (town of Jagersfontein). Refer to Error! Reference source not found.Table 3 for a list of adjacent landowners and the related land use of each farm. Also refer to the Neighbours Map in Appendix A attached hereto for reference.

Table 3: Adjacent landowners and related land use

Name Farm name Land use

Jagersfontein Developments Surface Tailings Dumps and Jagersfontein 14/16 (Pty)Ltd agriculture

Kopanong Local Municipality Jagersfontein 14/RE Town and tailings operation

Mr. Lucas Dreyer Nebo 313 Agriculture

Rietkuil 21/RE Agriculture Mr. P. Louw Commissiepoort 174

Mr. D. Louw Vlakfontein 1173/1 Agriculture

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Name Farm name Land use

Preezfontein North 927 Agriculture Mr. Nelius Booysen Preezfontein 19/RE

Mr. Marius Eksteen Vogelfontein 15 Agriculture

Kopanong Local Municipality Annex Preezfontein North 1063 Agriculture

Mr. K. Greeff Welgelegen Agriculture

Mrs. M. M. Hamman Mara 205 Agriculture

Prospect Boerdery Trust (Lessee: Agriculture Prospect 487 Mr. P. Snyman)

Mr. K. Botha Thomas 678/RE Agriculture

Rust en Vrede 393/1 Agriculture Mrs. E. K. Snyman Thomas 678/1

Mr. J. C. Du Toit Slangfontein 631 Agriculture

Mr. G. F. Jacobs Gleniffer 764 Agriculture

Mr. P. G. De Lange Waterval 329 Agriculture

Gamma 492 Agriculture Mr. J. R. Kolver Paardeplaat A 964

1.4.3 Surface infrastructure and presence of servitudes

• Power lines The electricity at the Plant, workshops and the staff houses, are supplied by Eskom. The Tailings Operation has an electrical network of overhead cables in various areas for power supply to pumps, conveyors and plant.

• Water use The Kopanong Local Municipality pipeline, for the supply of potable water from the Kalkfontein Dam to Jagersfontein, is located on the Remainder and Portion 16 of the Farm Jagersfontein 14 and extends from the north-west of Portion 16 to the town of Jagersfontein in the east.

Potable water at the Tailings Operations is abstracted from the Loskop Borehole on the Remainder of the Farm Jagersfontein 14.

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The Shaft from which water is abstracted for use in the Plant is located on Portion 15 of the Farm Jagersfontein 14.

• Roads Access to all the Tailings Operation's offices and infrastructure (e.g. Plant, workshop, etc.) is obtained by an internal gravel road system extending from Jagersfontein town. An internal network of sand- and gravel roads are used to gain access to areas such as boreholes, monitoring points, tailings facilities, etc. The roads used are existing roads developed during historic mining activities. These roads were upgraded and are maintained. This road network will be used during the backfilling of the Pit.

• Conveyors and pipes A conveyor network was established on the Tailings Operation to transport tailings from the Tailings Dumps to the Plant and back to the FTSF, where it is used for the stabilisation of its walls. It was proposed by Dr. Howell that a conveyor be used for the deposition of coarse tailings into the Pit. The coarse tailings will therefore be transported to the Pit via a conveyor, which will be approximately 750m long.

The Tailings Operation has a network of pipes used for the transfer of water to the PWDs, from various resources. A pipe is also used for the deposition of the paste into the FTSF. This pipe will be rerouted and extended to approximately 1 100m for the deposition of the paste into the Pit.

1.5 Purpose of the IWWMP

The IWWMP will be used as supporting documentation to inform the WULA and the decision making authorities regarding the Project. The IWWMP will also specify management and monitoring measures and design methods developed specialists, which JD must commit to implement to prevent and/or limit the impacts which may occur on the water resources as a result of the Project's commencement.

The purpose of the IWWMP is to describe the Water and Waste Management System currently implemented by the Tailings Operation and measures to be implemented during the Pit's rehabilitation. The report's main objectives are as follows:

• The writing of a management plan to be implemented to address all aspects relating to water;

• Provide detailed background to the environmental conditions and water resources;

• Develop mitigation and control measures and strategies to limit or prevent potential impacts;

• Limit potential significant environmental risks by considering site-specific aspects;

• Limit potential surface- and groundwater pollution through the implementation of appropriate management and / or mitigation measures;

• Manage identified possible long-term residual groundwater impacts after closure of the Tailings Operations; and

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• Apply the “Cradle to grave” principle.

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2. CONTEXTUALISATION OF ACTIVITY

2.1 Description of Activity

JD exploits the old Tailings Dumps, purchased from De Beers in 2010. Methods undertaken at the Tailings Operation include the ploughing and/or ripping of the 11 Tailings Dumps to loosen tailings before they are loaded onto conveyors and/or trucks, which transport the tailings to the Plant. The Plant consists of 4 X 75 T/hour DMS plants, which are used to separate the mineral particles in a sink-float process. A suspension of dense powder in water is used, which forms a heavier liquid, for the separation. The heavier material containing diamonds will thus sink and the lighter material will float.

A pan plant was also introduced in 2019, to further separate material into concentrate (which carries the diamonds) and excess material used for the stabilization of the FTSF's walls. The concentrate still passes the x-ray machine and sorting house used at the DMS plant.

From the Plant the material is separated into the coarse tailings and paste, which is transported to the existing FTSF located on the Remainer of the Farm Jagersfontein 14 IS. While the coarse tailings are used for the stabilisation of the FSTF's walls, the paste is stored inside it. However, this FSTF is near capacity and has a lifetime of approximately 1 more year until capacity is reached based on the existing design of the Plant and FSTF. JD thus proposed to rehabilitate the Pit using the coarse tailings and paste to backfill the Pit to a depth of approximately 30 mbgl. This option was decided on to prevent the construction of another surface FTSF at a different location, as it: is not economically feasible to do this; and will have additional environmental impacts, resulting in a loss of land to the extent of more than 100 ha and airspace of approximately 33 m.

The proposed process for the Pit's backfilling will entail the following as per the SRK 2019 Report of 2019:

• The main shaft currently houses water pumps at the 450m level. These pumps provided process water for the plant only. The pumps have been installed (remotely) down the Main Shaft to the extraction level even though physical access is not possible (as confirmed by C&A Mining exploration Consultants).

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• The slime slurry will be introduced by pipeline for the eastern flank of the pit in month four after commencement of tailings deposition.

• Since the slimes slurry is less dense than the tailings, the slurry will remain above the tailings (section 6.2.3 of the SRK 2019 Report). The continued deposition of tailings from the south rim will displace the slimes slurry laterally and upwards (sink to the bottom as has been the case at DeBeers pit in Kimberley and as observed from the Jagersfontein surface tailings/slimes dam).

• The tailings will act as a water filter (see the assessment of filter characteristics in Section 6.2.2 of the SRK 2019 Report) and progressively enhance/prevent piping/internal erosion into the main shaft area, thus ensuring the continued availability of water to the pumps.

• Deposition is programmed to take about 6 years (72 months) at the current production levels. Recently a new pan plant has been installed that will increase the ROM production to 700tph (tons per hour) – or 504 000tpm (tons per month). Tailings production is 396 000tpm and slime slurry is 153 000m3/m (cubic metres per month) including makeup water. The total ROM still to be processed is estimated to the 36Mt (million tons). Further assessment of the volumes and rates of rise are contained in Section 7 of the SRK 2019 Report.

• It is proposed that the stormwater entry into the pit (which currently enters at the southern culvert and western depression area) is rerouted to the southern culvert entry point. This will concentrate the stormwater close to the tailings deposition point and facilitate water seepage into the main shaft area. This has been considered in Section 6.5 of the SRK 2019 Report.

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• The two main catchment areas (Section 6.5 of the SRK 2019 Report) that report to the Open Pit are from the west and northwest, with a minor catchment for the northeast (town) area. Currently the western catchment (Loskop dam) discharges into the pit via the southern culvert. The North Catchment discharges via the North Dam (north of the Fauresmith road) into the north-western area of the pit. It is proposed that consideration be given, during the detailed design phase, to upgrading the North, Loskop and Moon dams and channelling the stormwater toward the southern culvert entry point in order to optimise the use of run-off into the pit. Alternatively, it must be recognised, that the stormwater from the Northern catchment will naturally (following the current contours and flow paths) enter the pit directly into the slurry area during the latter part of the deposition cycle.”

2.2 Extent of activity

As indicated above, the Pit is located on Portion 15 of the Farm Jagersfontein 14 IS in the Fauresmith District. The property is located directly adjacent to the Jagersfontein Town. The Pit has a surface area / footprint of approximately 19.635ha and it is proposed that it will be filled to approximately 30m below ground level.

2.3 Key activity related processes and products

Tailings are transported from the Tailings Dumps on the surface to the Plant, via conveyors and/or trucks. At the Plant, the material (i.e. tailings) is washed and separated into a fine and course fraction. From the washing plant the tailings will go through a DMS plant, to separate them into a dense and a light fraction, from where the light fraction (i.e. paste) will go to the FTSF. The more dense, heavier tailings will then be processed further by means of an x-ray machine and grease tables, where the diamonds will be separated from the tailings. It is the paste and coarse tailings that will be transported and deposited into the Pit for rehabilitation. No other materials apart from the Backfill Materials will be used for the Pit's rehabilitation.

The production rate of the existing Tailings Operation (i.e. DMS plant and pan plant) is 504 000tpm. The coarse tailings production is 396 000tpm and paste is 153 000m3/m. The paste volume is accurate, as the average paste produced per month currently is 138 619m3/m. This average was calculated from paste volumes measured since April 2016.

It is expected that the Project will occur over a period of 6 years, until all surface Tailings Dumps have been removed. However, this depends on when the activity commences.

2.4 Activity life description

It is estimated that the estimated life of the Tailings Operation will be between another 6 to 8 years after commencement with the project and was based on the production rates and available material to be backfilled. However, this is dependent on when the activity will start, as the lifetime of the Operation and project is based on the available volume of surface tailings at the time of this report.

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2.5 Activity infrastructure description

The infrastructure directly related to the project will be: a conveyor, with a length of 750m, to transport coarse tailings from the existing Process to the Pit for deposition; and a pipe with a length of 1 100m, which will transport paste to the Pit for deposition. The conveyor will extend from the Plant towards the Pit’s southern rim, passing the shaft's eastern side. The pipe will also be located on this footprint, but deposition points will vary. Paste will be discharged on the eastern side of the Pit mainly. Reference is made to the SRK 2019 Report.

Other infrastructure on the operational site includes the road network and water pipes supplying water to the Plant and houses.

No additional buildings will be constructed for the project.

2.6 Key water uses and waste streams

2.6.1 Water use activities

Water is abstracted from various sources for use in the Plant. These sources are described in more detail above.

A key water use associated with the Pit's rehabilitation is the deposition of paste and coarse tailings into it.

2.6.2 Key waste streams

The waste streams at the Tailings Operation during the different operational stages include the following:

• Coarse and fine tailings used to rehabilitate the Pit. Backfilling Material was classified as a Type 3 waste to be deposited into the Pit for rehabilitation;

• General/ domestic waste generated at the Plant, workshop and site offices;

• Hazardous waste in the form of oil, oil filters, oil rags, paint, grease and other hydrocarbons from the Plant and workshop; and

• Sewage from the staff houses and offices.

2.7 Organisational structure of activity/organisation

The company structure of JD is indicated in the figure below:

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Figure 6: Jagersfontein Developments (PTY) Ltd company structure

The following figure indicates the board of directors of JD:

Figure 7: Jagersfontein Developments (PTY) Ltd board of directors

The following figure indicates the company management team of JD:

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Figure 8: Jagersfontein Developments (PTY) Ltd company management team

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2.8 Jagersfontein Developments (Pty) Ltd Environmental Policy

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3. REGULATORY WATER AND WASTE MANAGEMENT FRAMEWORK

3.1 Summary of all water uses

The following table indicate a summary of the proposed water uses by JD and the property on which it will occur.

Table 4: Summary of all water uses

Water use in terms of Coordinates of centre of Pit Activity Section 21 of the Property description Latitude Longitude NWA, 1998

21(g): Disposing of Backfilling of coarse Portion 15 of -29.763906° 25.419023° waste or water and fine tailings into Jagersfontein 14 IS containing waste in a the Pit to manner which may rehabilitate it. have a detrimental impact on a water resource

3.2 Existing lawful water uses

According to Section 32 of the NWA, 1998, an Existing Lawful Water Use is defined as:

(1) An existing lawful water use means a water use -

(a) which has taken place at any time during a period of two years immediately before the date of commencement of this Act; or

(b) which has been declared an existing lawful water use under section 33, and which -

(i) was authorised by or under any law which was in force immediately before the date of commencement of this Act;

(ii) is identified as a stream flow reduction activity in section 36(1); or

(iii) is identified as a controlled activity in section 37(1).

There are no water uses relating to the Project which will be regarded as Existing Water Use.

3.3 Relevant exemptions

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A motivation for exemption in terms of Regulation 3 of GN. 704 (4 June 1999) was submitted to the DHSWS as part of the WULA in terms of Section 21(g) of the NWA. The Regulations which requires exemptions are the following:

• Regulation 4: Restrictions on locality. ➢ Regulation 4(c): “No person in control of a mine or activity may place or dispose of any residue or substance which causes or is likely to cause pollution of a water resource, in the workings of any underground or opencast mine excavation, prospecting diggings, pit or any other excavation”. • Regulation 5: Restrictions on use of material ➢ “No person in control of a mine or activity may use any residue or substance which causes or is likely to cause pollution of a water resource for the construction of any dam or other impoundment or any embankment, road or railway, or for any other purpose which is likely to cause pollution of a water resource.” • Regulation 7: Protection of water resources. ➢ Regulation 7(a): “prevent water containing waste or any substance which causes or is likely to cause pollution of a water resource from entering any water resource, either by natural flow or by seepage, and must retain or collect such substance or water containing waste for use, reuse, evaporation or for purification and disposal in terms of the Act;”.

3.4 Generally authorised water uses

The water use applied for is not generally authorised.

3.5 New water uses to be licensed

Section 21(g) of the NWA: Disposing of waste in a manner which may detrimentally impact on a water resource

JD proposes to rehabilitate the Pit on Portion 15 of the Farm Jagersfontein 14 IS, as part of an initiative to restore its safety and rehabilitate the surrounding environment, which will be done by removing the surface Tailings Dumps from the surface and backfilling the material into the Pit to create more space for agricultural activities.

The rehabilitation initiative will involve infilling the Pit with Backfill Material generated from JD's existing Plant to make the bottom of the Pit shallower.

The total volume of tailings still to be processed on the surface of the Tailings Operation is approximately 36 Million tons (“Mt”), of which 25.6 Million cubic metres (“Mm3”) will be tailings backfilled into the Pit. “The ‘usable’ volume of air space in the Pit (to level 1400mamsl) is 31Mm3. Accordingly, the remaining Backfill Material will only fill the Pit to a level some 30m below the rim (1371mamsl). From a historical and tourism viewpoint, therefore, the Pit's unique geology will still be observable. In addition, the current potentially unstable Pit slopes will be buttressed by the Backfill Material and further break-back (towards the Jagersfontein Town and surrounds) will

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be mitigated. Since the Backfill Material will only reach to a level of 1371mamsl, which is below the upper aquifer depth, no effect on the regional usable aquifer will result.

The Project above will require a WUL as it is neither generally authorised and will require exemptions in terms of Regulations 4(c), 5 and &(a) of GN. 704 of 4 June 1999.

3.6 Waste management activities (NEMWAA)

A WML is not required under the National Environmental Management: Waste Amendment Act, 2014 (Act No. 26 of 2014 ("NEM:WA"), as the Backfill Material is not unwanted or rejected by JD.4 In order to determine whether the tailings that will be used for the Backfilling constitute waste, one would need to assess the primary purpose of its disposal into the Pit. JD has a duty of care under the National Environmental Management Act, 1997 (Act No. 107 of 1998), to take reasonable measures to prevent pollution and environmental degradation. JD intends to utilize the Backfill Material from the Plant for the backfilling to fulfil its duty of care. It would have positive environmental impacts and be beneficial for JD to utilize the Tailings for Backfilling, as it will:

• stabilize the Pit;

• result in a new FSTF not being required, which would further sterilise another 100 Ha of surface area to a height of some 33m and, in addition, act as a potential pollution source for the upper aquifer (up to 20m below surface), from which water is currently abstracted in the area; and

• allow the Operational Site to be used for other sustainable land uses, such as agriculture.

JD is, therefore, of the view that the Backfill Material does not constitute waste as it is not "unwanted" but required for JD to fulfil its duties of care and the backfilling constitutes rehabilitation and not a waste management acitivity.

3.7 Other authorisations and regulations (EIAs, EMPs RoDs)

According to the High Court of South Africa’s judgment in the matter between De Beers Consolidated Mines and Atequa Mining (Pty) Ltd. the Tailings Operation do not require a mining right, as the Operation is not regarded as mining and compliance with the MPRDA is not required.

A closure application is not required under the Minerals and Petroleum Resources Act, 2008 (Act No. 28 of 2008) ("MPRDA"). This is only required to be submitted by the holder of a prospecting right, mining right, retention

4 Section 1 of NEMWA defines "waste" as: "any substance, material or object, that is unwanted, rejected, abandoned, discarded or disposed of, or that is intended or required to be discarded or disposed of, by the holder of that substance, material or object, whether or not such substance, material or object can be re-used, recycled or recovered and includes all wastes as defined in Schedule 3 to this Act…". (own emphasis added)

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permit, mining permit, or previous holder of an old order right ("Mineral Rights") or previous owner of works that has ceased to exist, or a person to whom liability in section 43(2) has been transferred to. JD nor De Beers have ever held a mining right in respect of the Pit. Mining of the Pit ceased in 1913 and De Beers never conducted opencast mining of the Pit or held any Mineral Rights in respect of it. Neither are the owner of "works".5

None of the activities associated with the Pit's backfilling require an environmental authorisation under the National Environmental Management Act, 1998 (Act No. 107 of 1998).

JD therefore seeks to obtain the required WUL and SAHRA permit for the Pit's.

5 The MPRDA refers to the definition of works in the Mine Health and Safety Act 1996 (Act No. 29 of 1996), which defines “works” as any place, excluding a mine, where any person carries out - (a) the transmitting and distributing to another consumer of any form of power from a mine, by the employer thereof, to the terminal point of bulk supply or where the supply is not in bulk, to the power supply meter on any such other consumer’s premises; or (b) training at any central rescue station; or (c) the making, repairing, re-opening or closing of any subterranean tunnel; or (d) any operations necessary or in connection with any of the operations listed in this paragraph.

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4. PRESENT ENVIRONMENTAL SITUATION

4.1 Climate

4.1.1 Regional Climate

Jagersfontein is located within the Jagersfontein Magisterial District, which is situated in a summer (i.e. October - March) rainfall region in a semi-arid region with a Mean Annual Precipitation (MAP) of 400 mm. The Mean Annual Temperature (MAT) in the region is around 15°C (Mucina and Rutherford, 2006). The occurrence of frost in the area generally occurs during winter, i.e. June - August.

Figure 9: Climate in Jagersfontein

4.1.2 Rainfall

The MAP of the Operational Site is based on a weather station located at Kalkfontein Dam, which was obtained from the DHSWS and indicates the rainfall from 1942 - April 2013. The average monthly rainfall over the 71 year period is indicated in the following table:

Table 5: Average monthly rainfall

Month Average rainfall (mm)

January 58.01

February 71.28

March 68.85

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April 48.01

May 19.05

June 12.22

July 7.9

August 13.06

September 14.65

October 34.93

November 45.90

December 49.09

Total/Average 437.6

Data provided by DWS

4.1.3 Evaporation

The Mean Annual Evaporation (MAE) in Evaporation Zone 19A, wherein the Tailings Operation is located, is 1 800 mm (Symons pan evaporation). The MAE of the 2 closest evaporation stations (i.e. at Tierpoort- and Kalkfontein Dams) are 1 715 mm and 1 871 mm respectively. The evaporation data for Zone 19A are indicated in the following Table:

Table 6: Net evaporation

Month Distribution S-Pan Pan factors Net evaporation (%) evaporation (mm) (mm)

October 10.6 191 0.81 132

November 11.9 214 0.82 146

December 13.5 243 0.83 171

January 12.8 230 0.84 154

February 10.1 182 0.88 109

March 8.9 160 0.88 89

April 6.2 112 0.88 70

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May 4.5 81 0.87 57

June 3.5 63 0.85 47

July 4 72 0.83 53

August 5.8 104 0.81 76

September 8.2 148 0.81 108

Total/Average 100 1 800 - 1 212

The data was obtained from the Surface Water Resource Assessment by Mr. O. J. Gericke attached in Appendix B

4.2 Surface water

4.2.1 Water Management Area

The Tailings Operation is within the Quaternary Drainage Region C51H, which covers an area of 1 782 km², in the Upper Orange WMA in the Modder - Riet Catchment Management Area.

Jagersfontein is within the Riet River Government Water Control Area.

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Figure 10: Jagersfontein quaternary region C51H

4.2.2 Surface water hydrology

The study area consists of 3 distinctive sub-catchment areas (Figure 11). Surface water from all 3 Sub- Catchments will naturally drain into Dam 10, located at the catchment outlet. The total catchment area of Dam 10 (i.e. Catchments A, B and C collectively) is an area of approximately 24 km². Structures (i.e. the Pit, FTSF, Tailings Dumps, the Plant, buildings, roads, etc.) will have an impact on the quality and/or quantity of the surface water within the Operational Site, as natural drainage patterns are changed by these structures. The sub-catchment located towards the north west of the Plant will drain into Loskop Dam. Runoff in the most northern sub-catchment will drain into a dam constructed during historic mining activities to the north of the R704 (Jagersfontein - Fauresmith road).

Water from the northern parts of Catchment A, bordering Catchment B, will drain into the Pit. This is however a very small catchment on its own. Measures will be implemented to divert this surface water from the eastern most culvert under the R704 to drain towards the south of the Pit, passing its western rim. Water from the artificial

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impoundment (i.e. North Dam) in Catchment B will drain through the western most culvert into Loskop Dam if the North Dam overflows. It is assumed that the North Dam and the overflow was constructed to drain water away from the Pit during historic underground mining operations.

Figure 11: Indication of catchment areas of the Operational Area (O.J. Gericke, 2013)

Refer to the Surface water resources assessment by Mr. O. J. Gericke attached in Appendix B.

There are several seasonal streams located within the study area with their origins in the surrounding hills. The catchments of the seasonal streams are largely confined to the Operational Site, with only small portions of the catchment occurring outside the mining area to the north and south of the Site.

The catchment outside the Dam 10 catchment drains into the Prosesspruit, a perennial stream located outside the Operational Site that flows north into the Kromellenboogspruit, which in return flows north into the Riet River. The Riet River is a perennial river that flows westwards until it is dammed by the Kalkfontein Dam, which is situated approximately 34 km north-west of the Operational Site. (Refer to the Biodiversity Management Plan by Mr. Darius Van Rensburg attached in Appendix B).

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4.2.3 Surface water quality

The water quality in Dam 10 and Loskop Dam is monitored, as stipulated in JD's surface water monitoring program (refer to Ground- and Surface water Monitoring Program in Appendix D). During monitoring, the pH, total dissolved solids and electrical conductivity, amongst other, of the water in Dam 10 and Loskop Dam are measured.

The surface water of the Operational Site is contaminated due to the mobilisation of unwanted salts or elements from the Tailings Dumps and FTSFs into the small tributaries on the Site. Due to the low rainfall and high evaporation in the area, the rate at which the unwanted elements are transported into the tributaries is low. Dam 10 has been impacted on noticeably, as it is the catchment for all tributaries on the Operational Site collectively and because of the kimberlite mining activities that occurred over the past 100 years.

The erosion of the residue is usually high, due to the dispersive quality of residue from kimberlite mines. As a result of the higher potential for erosion of kimberlite mine residue, the Tailings Dumps' footprints have enlarged since the tailings have eroded from the Dumps into the tributaries and Dam 10. The suspended particles (silt) and the salts entering Dam 10 are trapped as the water fraction evaporates, leaving the silt and salt behind. Any impact on surface water quality from the historic and current Jagersfontein operations is therefore confined to the study area because of Dam 10's buffer capacity.

Dam 10's water level will determine the water quality, as low water levels will have higher concentrations of salt, which will result in poor water quality. The water quality in Dam 10 will improve as the water level rises, as a result of the dilution effect.

Measures will be constructed and implemented to divert all stormwater around the Pit to prevent any water from entering the Pit from the surface. No water entering the Pit during rain events will be able to drain out of the Pit on the surface.

4.2.4 Mean Annual Runoff (MAR)

According to the SRK 2019 Report the runoff in the area ranges between 5 – 15% of the annual rainfall. This depends on the location, soil type and land use. It is known that runoff will be much higher on compacted surfaces due to the lack of infiltration. The runoff was calculated as follows:

Table 7 shows that the runoff to the Pit is estimated at 300 000 m3/annum. This volume is the total runoff for the entire runoff. If none of the catchments with dams contribute the volume will be 40 000 m3/annum.

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Table 7: Catchment runoff calculation

4.2.5 Resource class and river health

Not applicable

4.2.6 Receiving water quality objectives and the reserve

The classification of each water resource, setting of the resource quality objectives and reserve determination aims to protect South Africa's water resources in terms of the NWA (DWAF, 2002). This has not been completed for all catchments yet, but the current ecological status of the water resources is determined, to estimate the volume of water required to maintain the ecological reserve of the catchment. This is to be determined by DHSWS for this application.

4.2.7 Surface water user survey

Watercourses in the area are seasonal and long periods of low to no flow are experienced along the most parts of the river reaches and are thus not feasible for irrigation purposes. Due to this, certain conditions in the WUL granted to JD for the water use noted above (including monitoring of upstream, downstream and instream hydrology) can only be performed during the wet seasons or high rainfall events.

The Operational Site is within the Riet River Government Water Control Area.

The Woolwash Dam is located approximately 7 km east of the Tailings Operation. No major surface water users are present in the immediate area. It is not expected that the Project will have an impact on surface water recourse users in the area.

4.2.8 Sensitive areas survey

Due to historic mining activities on the same Operational Site that is used by JD currently, natural sensitive areas have been disturbed.

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The drainage lines on the Operational Site can only contain a base flow for short periods and are therefore not capable of sustaining a large degree of riparian wetland species. According to Van Rensburg (Biodiversity Management Plan, 2013), the drainage lines provide a vital service (Ecological) and must be regarded as sensitive. However, the Pit is not regarded as a sensitive ecological area, as it does not contain diverse plant species. A pair of Verreaux’s Eagles established a nest on the side of the Pit. However, this species is listed as being of Least Concern as they are not uncommon.

4.3 Groundwater

4.3.1 Aquifer characterisation

Based on water levels gathered for this area over the years and around the Pit, it is evident that the area contains two separate aquifers that are not hydrologically connected to each other. The geological profile also indicates that a shallow (5 -70 mbgl) aquifer is present followed by a much deeper-seated aquifer (around 200 mbgl), separated by massive dolerite sills (which is also evident in the wall of the Pit). The upper aquifer consists of horizontal layered lithologies, consisting of sandstone, mudstone/shales and weathered dolerite, where the sandstones are the water bearing units. The deeper aquifer also consists of layer lithologies but consists of much large and thicker units of sandstone in between fresh impermeable massive dolerite sills. The massive dolerite sills act as a barrier between the surface hydrology and the deeper workings of the lower aquifer, essentially separating the two systems from each other.

The shallow aquifer is recharged by recent rainwater, where it either directly follows to the aquifer through infiltration or flows into weathered and fractured dolerite into the aquifer. The deeper quifer also receives recharge but this happens over 100’s of year, as water move slowly and under high pressure.

Farmers in the area make use of the shallow aquifer, as it is not feasible to drill to a depth at which the deep aquifer is located and due to the extremely high cost of installing equipment to abstract water from such depths. Abstraction from the deeper aquifer will not have an impact on the quantity of water available in the shallow aquifer, as the shallow aquifer is not affected by the draw-down created by the deep aquifer.

4.3.2 Groundwater quality

• Water quality in the deep aquifer The quality of the water from the deep aquifer falls within the parameters of the SANS for Drinking Water, except for the Arsenic ("As") levels. (Refer to the results of the water analysis in Appendix F).

• Arsenic The boreholes in Jagersfontein Town were not sampled during this assessment and the interpretation of the groundwater quality data is based on the report and water quality data by Bijengsi, 2013. The following boreholes at localities, as indicated in Figure 3 and 4 (Bijengsi, 2013), were sampled during 2011 and 2012.

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Figure 12: 2011 and 2012 Water sampling boreholes (Bijengsi, 2013)

Figure 13: Distribution of boreholes in Jagersfontein during 2011 and 2012 (Bijengsi, 2013)

As is a metalloid (natural element whose properties are intermediate between those of metals and solid non metals) and it can be found in groundwater in an organic or inorganic form. It is an element that naturally occurs in many minerals and its presence in groundwater may be as a result of natural or artificial processes.

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The presence of As in groundwater is a fairly common problem that is experienced in many places globally and the World Health Organization limit for As is 0.01 mg/l.

The average concentration for As in the groundwater in the shaft is 0.101 mg/l, based on the 3 analyses considered since October 2011. It was concluded in a recent study: “A Geohydrological Assessment of Arsenic as a Contaminant in the Jagersfontein Area and Remediation Options”, that was done as a thesis for the degree Magister Scientea at the Institute for Groundwater Studies, University of the Free State by Bijengsi, that As naturally occurs in the groundwater and is not caused by previous kimberlite mining operations on the Site or any reprocessing of tailings.

From studies undertaken in the area it appears that the As levels in the deep aquifer system are not attributed to the Tailings Operation, or any previous mining operation on the Site. Studies have shown that its presence in the groundwater in the lower aquifer system may be as a result of natural processes or artificial processes, such as the use of pesticides and herbicides containing As.

As was present in the lower aquifer system before JD commenced its operations. As stated above, groundwater from the lower aquifer system in the Shaft was previously abstracted by the Municipality during 1980 to 2012 for water supply to the Jagersfontein residents. Due to the presence of As that was already detected in the groundwater at that time, a purification plant was built to treat the groundwater before being supplied to the Jagersfontein Residents.

As is not present in the upper aquifer system.

It is reiterated that, due to the underlying geological formations, the upper and lower aquifer systems are independent and not connected. Therefore, As present in the lower aquifer system will not migrate to the upper aquifer system.

Even if As was present in the upper aquifer system, due to the topography of the area, the groundwater in this system flows away from the Jagersfontein Town.

The fact that As is not present in the upper aquifer system is supported by studies commissioned by the Municipality in 2011 and 2012 on the groundwater quality in the upper aquifer system in the Jagersfontein Town. The As levels from borehole samples taken were within acceptable limits; save for two sample. It is unclear what the reason for the high levels of As in these samples might be, but it is most unlikely that the As levels in these boreholes were caused by previous mining operations as: a) the borehole is situated upstream of the Operational Site; and b) other boreholes in the same area had no As levels, or below detection limits.

Please refer to the Impact Assessment of the Diamond Recovery Operation at Jagersfontein on Surface and Groundwater Resources by Mr. G. Hoon in Appendix B.

• Water quality in the shallow aquifer

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The water quality in the shallow aquifer is likely to be the most vulnerable against any activity that may cause elevations of undesirable chemical elements. Groundwater movement in the shallow aquifer will flow along preferential pathways, which will most likely be in the weathered contact zone between the dolerite sill and the upper Karoo sedimentary formations.

Considering that the general direction of groundwater movement in the study area is in a south-east direction, potential contamination or plume is likely to manifest in a south-east direction of the FTSF, which is away from the Jagersfontein Town.

The borehole at Itumeleng that is located downstream from the Tailings Operation is not impacted on by the Tailings Operation, as the water quality is very similar to groundwater from the background boreholes in the Jagersfontein Town.

Groundwater is also not extensively used in the area surrounding the Site, except for a few private boreholes in the Jagersfontein Town.

The extent of groundwater contamination is limited and is very likely to be contained to the study area, as no boreholes outside the study area downstream (Itumeleng) appear to be affected.

The storage of fine tailings in the FTSF is a wet process and therefore bears the highest risk from all the facilities on the Operational Site to contaminate groundwater. The water in the FTSF creates a piezometric or hydraulic head in the FTSF (i.e. the water in the FSTF is higher than the surrounding area) that can increase the potential of seepage into the upper aquifer system. A trench and sump were made at the lowest wall of the FTSF, to intercept any drainage from the FTSF and reuse the water in the Plant. This prevents seepage from the FTSF to enter into the natural drainage pattern.

Although not as significant as a FTSF, there is also a risk of elements leaching from the Tailings Dumps, due to water contained in the tailings during the time of storage and aggravated by rain. There will however be much less water in the material contained in the tailings at the time of storage on the dump than in the FTSF.

• Sampling on Site The boreholes downstream and directly east of the FTSF (BH 9, BH 1 and BH 11) show relatively good water chemistry. On the other hand, the water’s micro-biological constituents show that the water is highly contaminated with sewage and not up to standard. BH 10, which is situated directly South and adjacent to the FTSF, show elevated concentrations of salts and As. Also, the water samples indicated that this water is slightly contaminated with sewage.

Ca, Mg and SO4 also occur naturally in groundwater. Elevated levels will affect the taste of the water and increase the hardness of the water. Hard drinking water is generally not harmful to one's health but it can pose serious scaling problems to household products like geysers and kettles.

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4.3.3 Hydrocensus

Since the start of the Tailings Operation by JD, numerous new boreholes were established for the abstraction of water. There is a total of 11 boreholes on the Operational Site, including the 5 monitoring boreholes. It should be noted that only 3 of the 11 (Rietkuil, Vlakfontein and Shaft) boreholes are equipped and used. Refer to Part 7 of this report for detail of the monitoring program implemented.

4.3.4 Potential pollution source identification

The potential pollution sources are the following:

• FTSF,

• PWDs,

• Tailings Dumps,

• Spills from: Maintenance materials, operational areas, processing plant, septic tanks.

Refer to the Impact Assessment of the Diamond Recovery Operation at Jagersfontein on Surface and Groundwater Resources report dated 16 July 2013 attached in Appendix B.

If the proposed backfilling of the Pit is authorised, the tailings currently stored in the FTSF can become a possible pollution source. However, numerous studies concerning the waste classification and backfilling of the Pit indicates that little to no pollution will occur from the tailings if it is deposited into the Pit.

4.3.5 Groundwater Model

An impact assessment on the surface and groundwater resources was compiled by Mr. Gys Hoon in July 2013 and contains all details regarding the groundwater. The report indicates that there is a deep (i.e. 338 meters below surface) and a shallow (i.e. 5 meters below surface) aquifer in the study area. The two aquifers are separated by an impermeable dolerite sill.

Refer to the Impact Assessment of the Diamond Recovery Operation at Jagersfontein on Surface and Groundwater Resources report dated 16 July 2013 attached in Appendix B.

A model was compiled by GHT in 2017 (Refer to Appendix B) to indicate the impact of the backfilling of the Pit with Backfill Material on the groundwater and the environment. The results of the model showed that it will be more beneficial on the groundwater resource over time to remove the surface tailings (i.e. pollution sources) and use them to backfill the Pit. The model showed that the pollution plume will remain for a very long time if tailings are not backfilled into the Pit, compared to when they are.

4.4 Socio-economic Environment

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The information in this section will be based on the data for Jagersfontein and the surrounding environment, as well as a brief overview of the entire Free State. The data will be based on the 2007 and 2011 census.

4.4.1 Population density, growth and location

The Operational Site is situated in the Free State Province and falls within the Kopanong Local Municipality that includes Jagersfontein, Fauresmith, Trompsburg, Meloding, Theunissen, Philippolis, Springfontein, Edenburg, Reddersburg, Bethulie and Gariep Dam Towns.

Table 8: Surface areas and estimated population density for the Free State Province, the Xhariep District- and Kopanong Local Municipalities (Statistics SA, Census 2007)

Surface area (km2) Estimated population density

Free State Province 129 825 2 745 590

Xhariep District Municipality 37 673.74 146 259

Kopanong Local Municipality 15 190 49 171

The Xhariep District has an average decrease in annual population of 1.1% between 2001 and 2011, with a negative growth rate of 1.31% in Kopanong local municipality. The population by age and gender of Kopanong Local Municipality is presented in Table 9 below.

Table 9: Percentage of the population of Kopanong Local Municipality by age and gender (Statistics SA, Census 2011)

Male Female Age % Number % Number

0 – 4 5.4 2 654 5.4 2 643

5 - 9 5.1 2 513 5.1 2 529

10 - 14 4.3 2 130 4.3 2 130

15 - 19 4.5 2 181 4.4 4 389

20 - 24 4.7 2 323 4.5 2 211

25 - 29 4.6 2 255 4.1 2 018

30 - 34 3.6 1 779 3.3 1 641

35 - 39 3.1 1 509 3.3 1 609

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Male Female Age % Number % Number

40 - 44 3 1 451 3.1 1 528

45 - 49 2.5 1 209 2.5 1 386

50 - 54 2.1 1 039 2.4 1 167

55 - 59 1.9 934 2.2 1 072

60 - 64 1.5 746 2 967

65 - 69 1 509 1.3 656

70 - 74 0.8 372 1.1 549

75 - 79 0.5 228 0.7 354

80 - 84 0.3 124 0.4 221

85+ 0.2 93 0.5 224

4.4.2 Employment data in Kopanong Local Municipality

Kopanong has an unemployment rate of 27%. The number of individuals with employment in Kopanong is 11336 with the number of unemployed individuals in the Municipality at 4 193 individuals. The number of discouraged work seekers and individuals not economically active in the Municipality is 2 078 and 13 625 respectively (Statistics SA, 2011).

4.4.3 Income per individual in the Kopanong Local Municipality

Table 10: Income in Kopanong Local Municipality

Income %

No income 11.3

R1 - R4 800 4.8

R4 801 - R9 600 6.8

R9 601 - R19 600 26.2

R19 601 - R38 200 22.5

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R38 201 - R76 400 13

R76 401 - R153 800 7.6

R153 801 - R307 600 4.6

R307 601 - R614 400 1.9

R614 001 - R1 228 800 0.7

R1 228 801 - R2 457 600 0.3

R2 457 601+ 0.2

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5. ANALYSES AND CHARACTERISATION OF ACTIVITY

5.1 Site delineation for characterisation

The larger activities on the operational area are delineated into the following smaller facilities:

• S Tailings Dumps,

• FTSF,

• Process Water Storage Facilities,

• Workshop,

• Stores,

• Site offices,

• Staff housing area,

• Dam 10,

• Loskop Dam,

• Shaft and other groundwater resources (i.e. boreholes),

• Pit (No activities currently undertaken at the pit but backfilling with tailings is proposed),

• Processing Plant

5.2 Water and Waste Management

5.2.1 Process water

• Water Supply Process water for the Plant is obtained from the following sources:

− Boreholes (i.e., Borehole 4, Vlakfontein Borehole, Rietkuil Borehole),

− Shaft,

− Dam 10,

− Loskop Dam,

− Jagersfontein Sewerage Treatment Plant ("STP"), and

− Recovered water (Seepage 1 and Seepage 2)

• Water conservation and demand management

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JD abstracts the PSE from the final maturation pond of the STP in Jagersfontein, which is then used at the Plant. The PSE is used to supplement the water abstracted from the other natural sources, to alleviate the pressure on them.

PWDs are lined to reduce seepage.

The safe yields of all the water sources were determined and abstracted accordingly.

• Sewage management The site offices and staff houses make use of septic tanks to manage their sewage.

5.3 Stormwater (clean and dirty water management)

Stormwater will be managed by diverting all surface water from the northern catchments around the Pit via berms and trenches. The area north of the R704 has an artificial impoundment, which was constructed to contain water and prevent water from draining into the Pit during historical underground mining operations.

5.4 Operational Management

5.4.1 Organisational structure

Refer to the company structure in Section 2.7 of this report.

5.4.2 Resources and competencies

JD strives to be compliant with all relevant legislation. The following companies have been contracted to assist and advise management of JD with environmental issues:

• De Villiers Inc De Villiers Inc was appointed by JD to monitor compliance with all legal aspects of the Tailings Operation, including compliance to environmental legislation. Monthly meetings are held during which JD’s legal standings in terms of environmental compliance at the time are reported. Subsequently, areas of possible non- compliance are identified, and assistance is provided by De Villiers Inc on legal issues and to implement measures to ensure compliance. • Turn 180 Environmental Consultants Turn 180 was contracted by JD to conduct monthly Environmental Compliance Monitoring, to ensure that JD complies with environmental reports, legislation and regulations and assist in the application process of projects that need to be authorised by relevant authorities in order to legalise activities undertaken at the Operation.

Turn 180 is also responsible for the sampling of water and dust fallout from bucket systems.

5.4.3 Education and training

The following training is provided to employees:

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• Formal job specific training

Employees conducting specific skilled jobs undergo formal training in their respective fields.

• Induction

All employees are given induction on both safety and environmental aspects. During the induction employees are trained on waste management and water use and conservation, including pollution prevention methods among other aspects.

• Toolbox talks

Short toolbox talks and meetings are held before commencement of shifts to address and discuss health, safety and environmental aspects which requires attention.

5.4.4 Awareness raising

Employees at the Tailings Operation are made aware of environmental issues during induction at their appointment and during toolbox talks during employment. Furthermore, notices on site raise awareness of environmental, health and safety issues. These notices will raise awareness of water conservation.

5.5 Monitoring and control

5.5.1 Surface water monitoring

Surface water monitoring is conducted on a quarterly basis. During the surface water monitoring process, samples are taken from Loskop Dam, Dam 10, Swanepoel Dam (SPD), Seepage 1, Seepage 2, watercourse upstream and watercourse downstream and are submitted to Aquatico Labratories in Johannesburg.

Note that the watercourse upstream and downstream will be sampled monthly during the wet season, as there is no available water present for sampling during the dry months.

5.5.2 Groundwater monitoring

Groundwater monitoring is conducted on a quarterly basis. During the water monitoring process, samples are taken from the following groundwater sources:

• Shaft

• Borehole 4

• Borehole 10 (Monitoring borehole), and

• Borehole 11 (Monitoring borehole)

• Borehole 1

• Borehole 9

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Water samples are submitted to Aquatico Laboratories

5.5.3 Bio-monitoring

No bio-monitoring is currently undertaken at the Tailings Operation. A Biodiversity Management Plan was compiled by Mr. Darius Van Rensburg at the initiation of the project.

Mr. Darius van Rensburg was contacted in 2019 in terms of conducting a new Invertebrate Habitat Assessment System (Aquatic Assessment) alongside a Biodiversity Report. A quote was given to JD and a decision is pending.

5.5.4 Waste monitoring

There is no waste monitoring program for the Tailings Operation, as the chemical composition of the tailings does not pose a major risk (i.e. acid mine drainage, etc.), although the volumes of waste stored in the FTSF are recorded

Used oil and oil filters are stored in a separate container and collected by a contractor to be recycled. Records of the volumes of waste are kept.

5.6 Risk Assessment / Best Practice assessment

5.6.1 Methodology followed

The main objective of the impact assessment process will be to assess and quantify the potential impacts that were identified by the specialists during their investigations.

The concept of "significance" is at the core of impact identification, evaluation and decision-making, and can be differentiated into impact magnitude and impact significance. Impact magnitude is the measurable change (i.e. intensity, duration and likelihood), while impact significance is the value placed on the change by different affected parties (i.e. level of acceptability) (DEAT, 2002).

The environmental significance assessment methodology is based on the following determination:

Environmental Significance = Overall Consequence x Overall Likelihood

5.6.2 Determination of Consequence

Consequence analysis is a mixture of quantitative and qualitative information and the outcome can be positive or negative. Several factors can be used to determine consequence. For the purpose of determining the environmental significance in terms of consequence, the following factors were chosen: Severity/Intensity, Duration and Extent/Spatial Scale. Each factor is assigned a rating of 1 to 5, as described below.

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5.6.2.1 Determination of Severity

Severity relates to the nature of the event, aspect or impact to the environment and describes how severe the aspects will impact on the biophysical and socio-economic environment.

Table 11: Rating of Severity

Type of Rating criteria 1 2 3 4 5

Quantitative 0-20% 21-40% 41-60% 61-80% 81-100%

Small / Disastrous Insignificant / Significant / Great / Very Qualitative Potentially Extremely Non-harmful Harmful harmful harmful harmful

Slightly Totally Social / Intolerable / Unacceptable Acceptable / tolerable / unacceptable Community Sporadic / Widespread I&AP satisfied Possible / Possible legal response complaints complaints objections action

Very low cost Substantial to mitigate / Prohibitive cost to cost to High mitigate / mitigate / Little potential to Potential to or no mitigate Low cost to High cost to Irreversibility mitigate mechanism to impacts to mitigate mitigate impacts / mitigate level of Potential to impact insignificance reverse / Easily Irreversible impact reversible

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Type of Rating criteria 1 2 3 4 5

Biophysical

(Air quality, water Insignificant Moderate Significant Very significant Disastrous quantity change / change / change / change / change / and quality, deterioration deterioration deterioration deterioration or deterioration waste or or or disturbance or disturbance production, disturbance disturbance disturbance fauna and flora)

5.6.2.2 Determination of Duration

Duration refers to the amount of time that the environment will be affected by the event, risk or impact, if no intervention.

Table 12: Rating of Duration

Rating Description

1: Low One month

2: Low-Moderate Between 1 and 3 months (Quarter)

3: Moderate 3 months to 1 year

4: Moderate-High 1 to 10 years

5: High More than 10 years

5.6.2.3 Determination of Extent/Spatial Scale

Extent refers to the spatial influence of an impact. It will be: a) limited to the site and its immediate surroundings; b) extending to the surrounding local area; c) regional (will have an impact on the region) d) national (will have an impact on a national scale); or e) or international (impact across international borders).

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Table 13: Rating of Extent

Rating Description

1: Low Immediate, fully contained area

2: Low-Moderate Surrounding area

3: Moderate Regional

4: Moderate-High National

5: High International

5.6.3 Determination of Overall Consequence

Overall consequence is determined by adding the factors determined above and summarised below, and then dividing the sum by 3.

Table 14: Example of calculating Overall Consequence.

Consequence Rating

Severity Example 4

Duration Example 2

Extent Example 4

SUBTOTAL 10

TOTAL CONSEQUENCE:(Subtotal divided by 3.3 3)

5.6.4 Determination of Likelihood

The determination of likelihood is a combination of Frequency and Probability. Each factor is assigned a rating of 1 to 5, as described below.

5.6.4.1 Determination of Frequency

Frequency refers to how often the specific activity, related to the event, aspect or impact, is undertaken.

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Table 15: Rating of Frequency

Rating Description

1: Low Once a year or once during operation

2: Low-Moderate Once / more in 6 Months

3: Moderate Once / more a Month

4: Moderate-High Once / more a Week

5: High Daily

5.6.4.2 Determination of Probability

Probability refers to how often the activity/event or aspect has an impact on the environment.

Table 16: Rating of Probability

Rating Description

1: Low Almost never / almost impossible

2: Low-Moderate Very seldom / highly unlikely

3: Moderate Infrequent / unlikely / seldom

4: Moderate-High Often / regularly / likely / possible

5: High Daily / highly likely / definitely

5.6.4.3 Determination of Overall Likelihood

Overall likelihood is calculated by adding the factors determined above and summarised below, and then dividing the sum by 2.

Table 17: Example of calculating the Overall Likelihood.

Likelihood Rating

Frequency Example 4

Probability Example 2

SUBTOTAL 6

TOTAL LIKELIHOOD (Subtotal divided by 2) 3

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5.6.5 Determination of Overall Environmental Significance

5.6.5.1 Quantitative description or magnitude of Environmental Significance

The multiplication of overall consequence with overall likelihood will provide the environmental significance, which is a number that will then fall into a range of LOW, LOW-MEDIUM, MEDIUM, MEDIUM, MEDIUM-HIGH or HIGH, as shown in the table below.

Table 18: Determination of Overall Environmental Significance.

Significance or Risk Low- Moderate- Low Moderate High Moderate High

Overall Consequence 1 - 4.9 5 - 9.9 10 - 14.9 15 – 19.9 20 - 25 X

Overall Likelihood

5.6.5.2 Qualitative description or magnitude of Environmental Significance

This description is qualitative and is an indication of the nature or magnitude of the Environmental Significance. It also guides the prioritisations and decision-making process associated with this event, aspect or impact.

Table 19: Description of the Environmental Significance and the related action required.

Low Low-Moderate Moderate Moderate-High High Significance

Impact is of Impact is real, Impact is real Impact is of low very low order and potentially and substantial Impact is of the order and and therefore substantial in in relation to highest order Impact therefore likely to likely to have relation to other impacts. possible. Magnitude have little real very little real other impacts. Poses a risk to effect. Unacceptable. effect. Can pose a risk the I&AP. Acceptable. Fatal flaw. Acceptable. to I&AP. Unacceptable.

Implement Maintain Improve Implement Maintain current monitoring. Action current management significant management Investigate Required management measures to mitigation measures. mitigation measures. reduce risk. measures or measures and

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Low Low-Moderate Moderate Moderate-High High Significance

Where possible Implement improve implement improve. monitoring and management alternatives. evaluate to measures to determine reduce risk, potential where possible. increase in risk.

Where possible improve.

5.6.6 Aspects which may result in impacts assessed as identified by specialists

Note that the impact assessment in this report only relates to aspects which may have an impact on water quality and/or quantity.

5.6.6.1 Groundwater

The geology of the Jagersfontein area consists mainly of sediments from the Karoo Supergroup. These are predominantly sandstone, shale and mudstones formations of the Dwyka-, Ecca- and Beuafort group, with intrusion of post Karoo dolerite sills and dykes along weak contact zones between different formations or faults zones.

The Karoo sediments are characterized by low permeability and groundwater movement mainly occurring along jointed and fractured zones caused by faults, or on the contact zones with dolerite intrusions.

Based on the water levels around the Pit and the differences in water qualities, it is evident that there are two aquifer systems in the study area. At the top is a shallow aquifer, with a rest water level (water table level) of approximately 5 metres below ground level (mbgl). At the bottom is a deeper aquifer, with a current drawdown water level at 338 mbgl and a rest water level at approximately 160 mbgl. The two aquifer systems are separated by an impermeable dolerite sill. This is based on early geological maps that indicated a dolerite sill from surface to depth of approximately 300 m. In the two monitoring boreholes drilled about 2 000 m south east of the Pit, dolerite was intersected from about 5 m to a depth of 70 m. It is most likely that the dolerite sill that was intersected in the two monitoring boreholes correlates with the sill at the Pit, as indicated in the geological section by Woodford et al, 2002.

It is very likely that the dolerite sill is a major geological feature because of its thickness, that it is likely to cover a large area over the Site, which plays an important role in groundwater movement in the study area.

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The shallow aquifer will most probably be very recent water (i.e. recently recharged from rainwater) and will move along the weathered zone of the dolerite sill and/or rainwater along the contact with the Karoo sediments that can be associated with the dolerite sill intrusion.

The aquifer systems are to a large extent independent of each other because of the impermeable sill that separates them. There may, however, be some isolated zones of connectivity between the two aquifer systems.

The surrounding groundwater users in the Jagersfontein Town abstract from the shallow aquifer, as it is not feasible to drill boreholes to the depths required to abstract from the deeper aquifer. The shallow aquifer is not affected by the drawdown created in the deep aquifer. Abstraction from the deeper aquifer has therefore an insignificant impact on the water levels in the shallow aquifer.

Because of the restricted movement of groundwater between the two aquifer systems, this will also be applicable to the movement of any undesirable chemical elements that may naturally occur in the deeper aquifer, or from previous mining operations” (Hoon, 2013 in the SRK 2019 report, attached as Appendix B).

Potential impacts identified by specialists which are assessed are the following:

• Impact on water quality in the shaft (i.e. lower aquifer) through seepage of water from the Pit; • Impact on water quality in upper aquifer; • Impact on quantity of water in the deeper aquifer; and • Impact on quantity of water in the upper aquifer.

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1. Impact on water quality in the deeper aquifer Jagersfontein 14/15

Potential Impact There is a potential that water seeping from the slimes during deposition into the Pit can enter the lower Description: aquifer and contaminate the source.

Duration of Impact: Permanent Preferred Alternative Backfilling as per SRKs’ design (Barrier system) Severity Duration Extent Consequence Probability Frequency Likelihood Significance Without Mitigation (No barrier) 5 5 3 4,3 5 5 5 21,7 With Mitigation (Barrier on southern Pit wall) 2 5 2 3 2 5 3,5 10,5 Stringent steps will be taken to ensure that the barrier system as per SRK’s design are deposited correctly. Mitigation Measures Also, monitoring of water quality will be done by sampling the lower aquifer through the shaft, as per SRK’s report. Construction of a new tailings facility on the surface Severity Duration Extent Consequence Probability Frequency Likelihood Significance Without Mitigation

With Mitigation No Impacts expected

Mitigation Measures

Barrier System: Should the impacts occur on groundwater in the deeper aquifer, the impact will not be Can the Impact be reversable, as the Backfill Material will not be able to be removed from the Pit. The impacts may be reduced Reversed by dilution over time. This will entail the cessation of the Project. Pollution will therefore remain and will dilute

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over time. The impact will be Moderate if the Pit is backfilled with a coarse tailings barrier and mitigation measures proposed by the SRK and GHT are carried out. New tailings facility: Deposition without implementing a barrier will cause an irreversible effect on water quality through seepage and the impact significance will be High. It is not expected that the construction of a new FSTF on the surface will affect the deeper aquifer. Barrier System: No loss of water quality is expected to the deeper aquifer when backfilling with a barrier and Will impact cause constructing a surface FSTF. Deposition of Backfill Material into the Pit without mitigation will cause an irreplaceable loss to irreplaceable loss to water quality in the lower aquifer. resource New tailings facility: Yes, loss of water quality is expected in the long term with the FSTF polluting water in the lower aquifer as long it stands on the surface. If the water quality is not monitored regularly for all alternatives, a pollution plume may start to develop and Cumulative Impacts spread systematically. There are no other sources of potential pollution to the deeper aquifer.

The impact assessment above shows that the significance of the impacts on groundwater quality in the deep aquifer, (which will occur with the rehabilitation of the Pit using a barrier of coarse tailings, as per the SRK 2019 Report) will be Moderate. However, it should be considered that the Frequency and Duration were calculated on a “daily” basis and “More than 10 years”. Although the activity associated with the groundwater pollution will occur daily, the activity will be temporary and cease once reprocessing of the tailings at the Tailings Operation ceases. No further backfilling will occur after cessation of the Tailings Operation. It is expected that the operation will last until 2029. After this time, the significance of the impacts will be Low. It is, however, unlikely that the impact on groundwater quality in the deep aquifer will occur with the proper mitigation measures and design as per the SRK 2019 Report attached as Appendix B.

It was determined that the impacts will be High if the mitigation measures and design by the SRK area not implemented and followed and Backfill Material is deposited into the Pit in no set manner and without a barrier. There will be no protection on the water in the deep aquifer.

2. Impact on water quality in the upper aquifer Jagersfontein 14/15

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Potential Impact Description: The pollution of water in the upper aquifer due to seepage of water into the aquifer from the Pit. Duration of Impact: Permanent Preferred Alternative Backfilling as per engineers’ design (Barrier system) and Geohydrological model Severity Duration Extent Consequence Probability Frequency Likelihood Significance Without Mitigation (Filling Pit to rim) 3 5 2 3,3 3 5 4 13,3 With Mitigation (Filling Pit to below 60m) No impacts expected If deposition of the tailings is done correctly, it is not foreseen that seepage water will have an impact on the water quality in the upper aquifer. Furthermore, due to the consistency of the slurry (low permeability and high water retention), it is highly probable that the water in the surrounding area will rather flow around the slurry, and that the water from the slurry itself will be contained within the Backfill Material inside the Pit. Monitoring of water quality in the upper aquifer will be undertaken by borehole sampling. As per the geohydrological model in the GHT 2017 Geohydrological Study, it is not expected that there will be an impact on the shallow / upper aquifer if the Pit is filled to a depth that is below the base of the shallow aquifer, which lies at 60m. It is therefore advised that the Pit should not be filled to Mitigation Measures a level higher than 60m without conducting additional studies. Other Alternatives Co-disposal without a liner Severity Duration Extent Consequence Probability Frequency Likelihood Significance Without Mitigation With Mitigation Impacts will not differ from implementing the liner, if the level to which the Pit is filled remains below the base of the shallow / upper aquifer.

Mitigation Measures

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Construction of a new tailings facility on the surface Severity Duration Extent Consequence Probability Frequency Likelihood Significance Without Mitigation 3 5 3 3,7 4 5 4.5 16.5 With Mitigation 2 5 2 3 2 5 3,5 10.5 A new FTSF can be lined with HDPE liners, but the cost implications would be too high. Trenches and Mitigation Measures berms can be built to stop runoff and seepage from the FTSF's walls. Constant pumping of the upper aquifer will be necessary to stop the pollution plume's progression.

Barrier System: All the alternatives are permanent in nature. The degree of contamination in the upper aquifer will vary greatly between the alternatives. If the Pit is backfilled correctly, changes to the water

Can the Impact be Reversed quality in the upper aquifer are not foreseen. New tailings facility: The building of a new FTSF on the surface will have a moderate impact on the water quality in the upper aquifer, and the impact would not be reversible.

Barrier System: No reduction of water quality is expected for the upper aquifer when backfilling the

Will impact cause irreplaceable loss Pit, if it is filled to a point below the base of the upper aquifer. to resource New tailings facility: The construction of a new FTSF will cause an irreplaceable loss to water quality in the upper aquifer.

The backfilling of the Pit will not have a cumulative impact on the upper aquifer. However, the Cumulative Impacts construction of a new FTSF will contribute to the pollution of water in the upper aquifer and have a cumulative impact, as there is a FTSF on the Operational Site already.

As confirmed by GHT, if the Pit is filled to a level below 60m there will be no impact on the upper aquifer. “Evaporation from the open pit area exceeds the combined influence of precipitation and groundwater influx. The groundwater level within the Pit would therefore not rise to above the base of the shallow aquifer. There is currently no visible influx of groundwater from the shallow aquifer into the Pit. There is therefore no known interconnectivity between the shallow and deeper aquifer” (GHT 2017 Geohydrological Study).

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“The slimes paste has very little ‘free’ water that can be released as seepage due to the very low permeability of the material. No access to the open Pit is possible. The slimes slurry (that contains water) has a very low permeability and coefficient of consolidation, therefore the release of water will be very slow – of the order of decades. No liner or drainage is contemplated”. (SRK 2019 Report)

The impact assessment indicates that there will not be an impact on the groundwater in the upper / shallow aquifer if the Pit is filled to a level below that of the base of the upper aquifer. The GHT 2017 Geohydrological Study established this level at 60m. Should this measure not be implemented, the significance of the impact on water in the upper aquifer will be Moderate.

The construction of a new FTSF will have a Moderate impact on the groundwater in the exploitable upper aquifer. The impact's significance will be Moderate with mitigation. The impact's significance without mitigation (i.e. liners, monitoring, abstraction of pollutants, etc.) will be Moderate – High.

3. Impact on quantity of water in the deeper aquifer Jagersfontein 14/15 It is not foreseen that the deposition of tailings into the Pit will have an effect on the water quantity in the deeper Potential Impact aquifer, but piping can occur where slimes flow into cracks within the Pit's walls and further beyond, essentially Description: causing blockages for water to flow naturally and sterilizing the groundwater in the shaft. Duration of Impact: Permanent Preferred Alternative Backfilling the Pit Severity Duration Extent Consequence Probability Frequency Likelihood Significance Without Mitigation (No barrier) 5 5 3 43 5 5 5 21,7 With Mitigation (Barrier on the southern Pit wall) 1 5 2 2,7 1 5 3 8 Mitigation Measures Implementing a base layer as per the SRK engineers report. Construction of a new FTSF on the surface

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Severity Duration Extent Consequence Probability Frequency Likelihood Significance Without Mitigation With Mitigation No Impact Mitigation Measures

Barrier System: No. This is an activity that will be permanent and once the blockage of openings occur the impact cannot be reversed. Can the Impact be Reversed New tailings facility: Will have no impact

Will impact cause Barrier System: Yes, if piping occurs. irreplaceable loss to resource New tailings facility: Will have no impact

There are no other activities which has impacts on the deep aquifer. Cumulative Impacts

"If there are not any open shafts or haulages by which the slimes can directly flow to the main abstraction shaft, it is unlikely that the main shaft will become silted”. (GHT 2017 Geohydrological Study).

The impact assessment above indicates that the impact's significance on groundwater in the lower aquifer will be High without the implementation of the barrier on the Pit's southern wall, as per the SRK 2019 Report. The implementation of the barrier will reduce the impacts to Low – Moderate. However, it was confirmed by both the SRK 2019 Report and GHT 2017 Geohydrological Study that it cannot be confirmed that there are no cracks, adits or open shafts on Pit's walls, which may lead to siltation and sterilisation of the groundwater in the lower aquifer, although none of these could be observed.

5.6.6.2 Surface water

Please refer to Section 6 of the SRK 2019 Report for an in-depth discussion on the surface water around the Pit.

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Note that there are no significant surface water bodies near the Pit which may be impacted on by the Project. Only stormwater and surface runoff will be affected by the Pit and are as follows:

• Loss of surface water (stormwater flowing into the Pit); and • Contamination of stormwater. 1. Stormwater flowing into the pit Jagersfontein 14/15 Potential Impact If site-specific stormwater controls are not implemented, most of the stormwater will drain towards the Pit and be Description: lost. Duration of Impact: Permanent

Backfilling of the Pit Severity Duration Extent Consequence Probability Frequency Likelihood Significance Without Mitigation (No Stormwater management measures) 4 5 2 3,7 3 2 2,5 9,2 With Mitigation (Stormwater management measures) 2 2 1 1,7 2 2 2 3,3 Proper site-specific stormwater controls and management plans will be introduced. This includes the diversion of any Mitigation Measures stormwater that flows towards the Pit into nearby dams or drainage lines, to prevent water from entering the Pit.

Can the Impact be Yes Reversed

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Will impact cause irreplaceable loss to No resource With the proper mitigation techniques, the stormwater drainage can be improved for the area around the Pit to Cumulative Impacts prevent stormwater draining into the Pit.

“Surface water catchment areas are mainly to the west and northwest of the Jagersfontein Pit. In order to assess the likely flow into the pit from storm events, a high level hydrological and surface water flow analysis has been carried out. Since the stormwater flow will interact with the tailings and slime deposition process, the volume and flow rates under the various likely storm events have been assessed”. (SRK 2019 Report.)

“It is proposed that the stormwater entry into the Pit (which currently enters at the southern culvert and western depression area) is rerouted to the southern culvert entry point. This will concentrate the stormwater close to the tailings deposition point and facilitate water seepage into the main shaft area”. (SRK 2019 Report)

The implementation of stormwater management measures will be important to ensure a Low impact on the stormwater in the area around the Pit. Stormwater must be diverted around the Pit and water must be prevented from entering the Pit on the northern side of the rim.

Conclusion of impact assessment

The impact assessments above indicate that the impacts will be lowest when the historically mined Pit is rehabilitated through backfilling with Backfill Materials. However, this will only be achieved with the implementation of the coarse tailings barrier, as designed by SRK (SRK 2019 Report). Furthermore, it is not advised that the Pit is filled to a level exceeding the base of the upper / shallow aquifer, as groundwater in this aquifer is exploitable by other users in the area and must therefore not be polluted by the Project.

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5.7 Issues and responses from the public consultation process

The following measures will be implemented to notify the public of the WULA and to consult them:

• Placing an advertisement in national and local newspapers;

• Sending notification letters to all neighbouring landowners and relevant authorities and municipalities;

• A meeting will be arranged with the applicant, local and district municipalities, Ward Councillors, planning and environmental departments;

• Arranging a public community meeting to discuss the project with the community;

• Placement of site notices at the entrance to the Tailings Operation and Pit and along the outer fence of the Tailings Operation;

• Placement of notices in town areas (i.e. library, hospital, police station, shops, etc.); and

• Doing a mail drop with leaflets in the community to raise awareness.

Comments will be logged in a comments and response report. All comments and concerns will be addressed. Adjacent landowners, stakeholders and authorities will be registered as Interested and Affected Parties ("I&APs") and the IWWMP and other reports will be provided to them for commenting. Comments will be sent to the Competent Authority with a Final Report containing all comments.

5.8 Matters requiring attention / problem statement

A Public Consultation Process must be initiated and completed to allow the public to comment on this report.

5.9 Assessment of level and confidence of information

Information was gathered from specialist studies conducted on the operational- and the surrounding area. The level of confidence is high with the uncertainties mentioned in the various specialist reports. Specialist investigation were undertaken, and reports written based on the information and data available at the time. Although this data is accurate it is expected that the information will be verified before commencement with the project as certain variables may change. This relates to a full survey of Backfill Material available, classification of the characteristics of the Backfill Material, final stormwater management investigations, etc.

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6. WATER AND WASTE MANAGEMENT

6.1 Water and Waste Management Philosophy

JD's water and waste management philosophy is derived from the company’s Environmental Policy, which aims to "conserve renewable and non-renewable natural resources and reduce all forms of environmental pollution and degradation". Therefore, JD aims to enhance positive aspects and minimise negative aspects.

6.1.1 Surface water philosophy

It will always be ensured that water from surface water resources are not abstracted at rates exceeding the safe yield of the resources, as this may affect the availability of water in the resources.

Stormwater measures will be implemented and maintained, to divert clean storm water around the operational area and prevent contamination of the 'off-site' area. Stormwater from the operational area collects in the return water dam to be re-used at the Plant.

6.1.2 Groundwater philosophy

A groundwater monitoring and measuring system was developed, implemented and will be maintained to ensure ongoing data collection to ensure compliance and to assist in the decision-making process when needed.

Groundwater is used in such a manner to ensure preservation of the sources.

6.1.3 Stormwater

Stormwater management measures, such as trenches and berms, have been implemented, not only to ensure that clean water is diverted around the Operational Site, but also in such a manner to prevent and/or minimise the potential for erosion to occur on the site.

Stormwater will be diverted around the Pit to prevent it from entering the Pit. Stormwater will drain from the north to Loskop Dam.

6.1.4 Waste

Waste is disposed of according to key waste streams and the collection and disposal of the waste is done according to the Operational Procedures for the different waste streams developed by JD.

The reuse, reduction and recycling of waste, as well as the support by JD for recycling projects in the town of Jagersfontein (i.e. Glaas Studio), will continue for the duration of the existence of the operation and beyond.

6.2 Strategies

6.2.1 Surface water

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The management strategy for the surface water resources includes the following:

− The safe yield of surface water resources will not be exceeded in order to preserve water;

− Surface water monitoring will be conducted quarterly over the lifespan of the Tailings Operation;

− Pollution sources will be contained to prevent surface water resources from being contaminated.

6.2.2 Groundwater

The management strategy for the groundwater resources includes the following:

− Abstraction volumes will be recorded to ensure that the safe yield of the resources is not exceeded when water is abstracted;

− Quarterly quality monitoring will be conducted in order to identify potential pollution plumes and/or source to implement management measures if necessary.

6.2.3 Stormwater

The management strategy for the stormwater includes the following:

− Contaminated storm water will be collected and contained;

− Seepage from the FTSF will drain into the trenches and sump, from where it will be abstracted to be used in the Plant;

− Clean and dirty stormwater will be separated by means of trenches and berms around operational areas.

6.2.4 Waste

The strategy for the management of waste is the following:

− Waste will be disposed of according to the JD operational procedures for waste;

− Waste will be separated into different key waste streams;

− The reuse, reduction and recycling of waste on site will be promoted throughout the lifetime of the project.

6.3 Performance objectives / goals

An environmental policy was developed for the operation, wherein JD commits to environmental management and provides a broad framework for environmental activities at the operation.

Table 20: Performance objectives for Jagersfontein Developments

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Theme Performance objective / goal

Surface water • Abstraction of water does not exceed the safe yield of the surface water resources,

• Maintaining good water quality,

• No surface water flow into the Pit during backfilling.

Groundwater • Abstraction of water does not exceed the safe yield of the surface water resources,

• Maintaining good groundwater quality,

• Identify and manage any pollution source that might contaminate the groundwater.

• Removal of Tailings Dumps from the surface and deposition into Pit, as a measure to remove the pollution source and prevent further contamination of contaminated seepage into the upper aquifer.

• Constant monitoring and implementation of preventative and reactive measures

Waste • Waste is separated into different key waste streams,

• Waste is stored and disposed of according to the operational procedures for waste compiled by JD,

• The operational area is kept clean and tidy.

6.4 Measures to achieve and sustain performance objectives

The measures to achieve and sustain the performance objectives will be implemented as indicated in the EMP, operational procedures and monitoring programmes in Appendix D.

6.5 Options analyses

This section is not applicable, as there are no other preferred options for water and waste management measures to be implemented.

6.6 IWWMP Action Plan

The priority actions and other short, medium and long-term actions are as follow:

Table 21: IWWMP Action Plan

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Theme Performance objective Actions / Measures Responsible person implemented

Abstraction of water • Weekly recording of • Plant Manager from sources within safe abstraction volumes

yield from sources,

• No increase in the volume of water • Plant Manager needed by the Plant,

• Optimal reuse and

recycling of water from the Plant. • Plant Manager

• Maintain the reuse of

the PSE from the STP in Jagersfontein • Environmental officer / Plant manager

Surface water No contamination of • Quarterly monitoring • Environmental officer surface water resources of surface water

quality, • Environmental officer • Identify and manage pollution sources to reduce

contamination risks,

• Contain seepage from FTSF in sump and • Environmental officer reuse in Process Plant.

Free drainage of • Ensure that there are • Environmental officer watercourses no obstructions within watercourses

No storm water in the Pit • Prevent storm water • Environmental Officer from entering the Pit

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Theme Performance objective Actions / Measures Responsible person implemented

by means of berms and trenches.

Abstraction of water • Weekly recording of • Environmental officer from sources within safe water abstraction

yield volumes from sources,

• No increase in the • Plant manager volume of water

needed by the Plant,

• Optimal reuse and recycling of water • Plant manager from the Plant.

Groundwater Maintain good • Quarterly monitoring groundwater quality of groundwater quality,

• Identify and manage pollution sources to reduce risk of Environmental officer contamination,

• Monitoring of water in the Shaft for contamination to deeper aquifer.

Separation of clean and • Delineate • Environmental officer dirty storm water operational areas to

identify areas with Storm water potential dirty storm water,

• Implement and • Environmental officer maintain berms and

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Theme Performance objective Actions / Measures Responsible person implemented

trenches around operational areas

Classification and • Provide marked • Environmental officer separation of waste into disposal areas / bins / Section foreman key waste streams for the disposal of different waste streams (i.e. hazardous-, general waste, etc.)

Legal compliance • Waste is stored and • Environmental officer Waste disposed of according to the operational procedures

Reuse, reduce and • Maintain support of • Plant manager recycling of waste the recycling

programme in the town of Jagersfontein (i.e. Glass studio),

6.6.1 Short term actions:

Ensure compliance with all relevant legislation by obtaining authorisation for all applications as included in the WULA.

6.6.2 Medium term actions:

Ongoing investigation, development and implementation of additional measures for the reduction, reuse and recycling of process water to ensure optimal water use.

6.6.3 Long term actions:

The long-term actions of the operation include the ongoing monitoring of all water resources and investigating, developing and implementing management measures to reduce any environmental impacts.

6.7 Control and monitoring

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6.7.1 Monitoring of change in baseline information

The information on the baseline environment has been established by the various reports (i.e. biodiversity plan, groundwater- and surface water reports, etc.) compiled at the initiation of the operation.

Baseline conditions will be monitored when monitoring is done on water resources and other features and changes in the baseline environmental conditions will be investigated and reported.

6.7.2 Audit and report on performance of measures

Turn 180 Environmental Consultants was appointed to conduct monthly environmental compliance audits on site and compile a report including all findings of the audit. This report will also include the results of the sampling after every quarter. The audit entails the monitoring of the implementation of management measures.

De Villiers Inc was appointed to ensure legal compliance to all aspects of the operation. Monthly compliance meetings or feedback and advice sessions are conducted between the various parties (i.e. JD, Turn 180, De Villiers Inc).

6.7.3 Audit and report on relevance of action plan

To ensure compliance with the requirements of DHSWS and best practices and continued relevancy of the IWWMP, JD will conduct the following audits and reports as required:

• Compile an IWWMP performance assessment report based on verification of compliance of this IWWMP to be implemented once every year, and update the IWWMP where necessary;

• Surface- and ground water monitoring results will be submitted to DHSWS annually;

• A water and waste report will be compiled annually, reporting on surface- and groundwater qualities, water quantities used and disposed, waste generated and disposed and water balances;

• Compliance to set targets will be evaluated and reported.

• Involve identified I&APs and stakeholders during the IWULA process of this registration process and any potential new water uses in future. Any complaints received during the consultation process or during the Operational Phase will be recorded in the complaints register and addressed where possible.

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7. CONCLUSION

7.1 Regulatory status of the activity

The IWULA submitted to the DHSWS includes applications for new water uses to be authorised before the commencement of the activities. Activities commenced with in terms of water uses under the National Water Act (Act 36 of 1998) as indicated in Table 1:

7.2 Statement on water uses requiring authorisation, dispensing with the requirement for a license and possible exemption from Regulations

This IWWMP was compiled as supporting documentation for the backfilling of the Pit. This IWWMP contains applications as discussed in detail in Section 3.5. No authorisations have been obtained for any of the water uses as applied for at the time of compilation of this IWWMP.

A GN 704 was compiled by the time of submission of this IWWMP for exemption, by the Provincial Head, on the following regulations:

• Regulation 4: Restrictions on locality.

➢ Regulation 4(c): “No person in control of a mine or activity may place or dispose of any residue or substance which causes or is likely to cause pollution of a water resource, in the workings of any underground or opencast mine excavation, prospecting diggings, pit or any other excavation”.

• Regulation 5: Restrictions on use of material

➢ “No person in control of a mine or activity may use any residue or substance which causes or is likely to cause pollution of a water resource for the construction of any dam or other impoundment or any embankment, road or railway, or for any other purpose which is likely to cause pollution of a water resource.”

• Regulation 7: Protection of water resources.

➢ Regulation 7(a): “prevent water containing waste or any substance which causes or is likely to cause pollution of a water resource from entering any water resource, either by natural flow or by seepage, and must retain or collect such substance or water containing waste for use, re-use, evaporation or for purification and disposal in terms of the Act;”.

7.3 Section 27(1) motivation

7.3.1 Section 27(1)(a): Existing Lawful Water Uses

There are no existing Lawful Water Uses applied for.

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7.3.2 Section 27(1)(b): The need to redress the results of past racial and gender discrimination

JD is a BBBEE compliant company and employs 190 people of which the majority is locally sourced.

The table above indicates that 147 employees are African, 4 people are coloured and 39 White. This indicates that most of the workforce employed by JD consist of previously disadvantaged individuals.

7.3.3 Section 27(1)(c): Efficient and beneficial use of water in the public interest

The use of water at the Tailings Operation is of upmost importance to ensure the continuation of the Tailings Operation and provide employment to the 190 people employed there. Without water the diamonds cannot be extracted from the tailings. The Tailings Operation also contributes to the economy of Jagersfontein, as the main industry in the area, by supporting local businesses and assisting in town infrastructure repairs.

The Pit's rehabilitation will furthermore clean the surrounding environment of the Tailings Dumps and thereby improve the land use by creating more efficient land which can be used for communal agriculture.

7.3.4 Section 27(1)(d): The socio-economic impact –

(i) of the Water Use or Uses if authorised; or

(ii) of the failure to authorise the Water Use or Uses

(i) The authorization of the water use will secure employment opportunities that include 154 people of previous disadvantaged group, mostly from the local community for a longer period.

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(ii) Failure to licence the backfilling of the Pit may result in the construction of an additional surface FTSF for the storage of paste. This will result in the pollution of groundwater in the upper aquifer and the loss of land.

7.3.5 Section 27(1)(e): Any catchment management strategy applicable to the relevant water resources

Jagersfontein is situated in the Upper Orange Water Management Area in the Modder-Riet Catchment and therefore forms part of the Modder-Riet Catchment Management Agency. The Quaternary Catchment of the Operational Site is C51H.

The Operational Site is located within the Riet River Government Water Control Area, therefore, general authorisations for the abstraction of surface water will not be applicable.

All requirements of DHSWS and relevant Best Practices have been taken into consideration during this IWWMP's development.

7.3.6 Section 27(1)(f): The likely effect of the Water Use to be authorised on the water resource and on other Water Users

There are no significant groundwater users in the area. Groundwater is mostly used for livestock watering and domestic water at farmsteads. There are no large irrigation projects in a 10 km radius and the volume of water abstracted is also very low.

There are no water users of the water in the deep aquifer, as this is an unexploitable aquifer.

7.3.7 Section 27(1)(g): The class and the resource quality objectives of the water resource

There are no official resource quality objectives for sources in the area.

7.3.8 Section 27(1)(h): Investments already made and to be made by the Water User in respect of the Water Use in question

The investments made towards the Pit's rehabilitation relates to the appointment of specialists and consultants to conduct studies and prepare applications for processing. It is expected that the investments made to date is in the region of R2 Million.

Should the water use be licensed it is expected that further investments will be made to construct infrastructure (i.e. conveyor and pipe) and prepare the surface. Additional investments will also be made to appoint specialists to conduct continuous monitoring on groundwater and develop additional reports.

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7.3.9 Section 27(1)(i): The strategic importance of the Water Use to be authorised

The strategic importance of the water to be authorised is the cleaning of the surface of the surrounding environment with creating better land use by removal of the surface Tailings Dumps. This will create land for communal agriculture and a lower potential of pollution of water in the exploitable shallow aquifer.

7.3.10 Section 27(1)(j): The quality of water in the water resource which may be required for the Reserve and for meeting international obligations

The water in the Shaft is not regarded as a feasible water resource due to the depth of the water underground and significant funds required to abstract the water. However, the water in the shaft is crucially important for the Tailings Operation.

7.3.11 Section 27(1)(k): The probable duration of any undertaking for which a Water Use is to be authorised

The estimated life of the operation is estimated to be between 6 and 8 years if the water use is licensed.

7.4 Key commitments

JD commits to the following conditions:

• The engineers report will be implemented after licensing of the water use, in order to backfill the Pit according to the engineer design;

• A monitoring plan will be implemented as per the engineers' design report, to monitor the impact of the Project on the water in the deep and shallow aquifers;

• Create a budget and secure funds for the appointment of a specialist team to conduct monitoring and provide constant advise and planning;

• Constantly giving feedback to the DHSWS regarding the project;

• With the licensing of the water use applied for JD furthermore commits to removing all surface tailings from the surrounding environment and cleaning the environment;

• Improve surface flow and drainage of the surrounding environment to prevent ponding and allowing water to drain to natural drainage patterns and preventing pollution and erosion.

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8. REFERENCES AND SPECIALIST STUDIES

Bijengsi, FFI 2013 A geo-hydrological assessment of arsenic as a contaminant in the Jagersfontein area and remediation options

C&A Mining exploration consultants (2017) Jagersfontein Developments Underground Recce No1 and 2 M.R.S Shaft Final Report

Department of Water Affairs and Forestry (1998) Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste.

Department of Water Affairs and Forestry (2002). Middle Vaal Water Management Area: Water Resources Situation Assessment. Volume 1 of 3

Department of Water Affairs and Forestry (2003). River Health Programme. State-of-Rivers Report: Free State Region River Systems.

Department of Water Affairs and Forestry (2006). Best Practice Guideline G1: Storm Water Management.

Department of Water Affairs and Forestry (2007). Best Practice Guideline G3: Water Monitoring Systems.

Department of Water Affairs and Forestry (2010) Draft Operational Guideline in M-Series to assist in the compilation of an Integrated Water and Waste Management Plan.

Department of Water Affairs and Forestry (2011) Background Information Document: Classification of Significant Water Resources in the Three Vaal Water Management Areas.

Gericke, OJ (2013) Surface Water Resource Assessment

GHT Consulting (2017) Geohydrological Study, Jagersfontein Mine

GHT Consulting (2017) Pit modelling for the Jagersfontein Mine

Hoon, GJ (2013) Impact Assessment of the Diamond Recovery Operation at Jagersfontein on Surface and Groundwater Resources

SRK Consulting (2008) Potential Break-Back Assessment for Jagersfontein Pit, South Africa

SRK Consulting (2012) Review of Jagersfontein Pit Stability and Backfilling Options

SRK Consulting (2016) Waste Classification and Assessment of the Tails at Jagersfontein

SRK Consulting (2019) Jagersfontein Pit Backfill Design Report

Van Rensburg, DP (2013) Biodiversity Management Plan

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