Basic Assessment Report and Environmental Management

BASIC ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED INCREASE OF THE FLASH DRYER CAPACITY AND ASSOCIATED FEED CIRCUIT MODIFICATIONS AT THE IMPALA RUSTENBURG SMELTER COMPLEX

Impala Smelter Complex

MARCH 2021

SUBMITTED FOR ENVIRONMENTAL AUTHORISATION IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (ACT 107 OF 1998) AND THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT (ACT 59 OF 2008) IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT (ACT 28 OF 2002) (AS AMENDED)

Name of applicant: Impala Platinum Limited Tel no: (011) 123-4567 Fax no: (011) 123-4567 Postal address: Private Bag X18, Northlands, 2116 Physical address: 2 Fricker Road, Illovo, 2196 File reference number SAMRAD: NW-00288-MR/102

SLR Project No.: 710.09003.00140 Revision No.: Draft BAR for public review March 2021 Impala Platinum Limited Basic Assessment Report and Environmental Management Programme for the proposed increase 710.09003.00140 of the flash dryer capacity and associated feed circuit modifications at the Impala Rustenburg March 2021 Smelter Complex

DOCUMENT INFORMATION

Title Basic Assessment Report and Environmental Management Programme for the proposed increase of the flash dryer capacity and associated feed circuit modifications at the Impala Rustenburg Smelter Complex Project Manager Reinett Mogotshi Project Manager e-mail [email protected] Author Rizqah Baker, Reinett Mogotshi and Natasha Smyth Reviewer Rob Hounsome Status Draft Basic Assessment Report for public review SLR Project No 710.09003.00140

DOCUMENT REVISION RECORD

Rev No. Issue Date Description Issued By

1 March 2021 Final RM

BASIS OF REPORT

This document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescales and resources devoted to it by agreement with (Impala Platinum Limited) part or all of the services it has been appointed by the Client to carry out. It is subject to the terms and conditions of that appointment.

SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or collateral warranty.

Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.

SLR disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the work.

The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this report remain vested in SLR unless the terms of appointment state otherwise.

This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which may be unclear to it.

Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents referenced explicitly herein and should then only be used within the context of the appointment.

Impala Platinum Limited Basic Assessment Report and Environmental Management Programme for the proposed increase 710.09003.00140 of the flash dryer capacity and associated feed circuit modifications at the Impala Rustenburg March 2021 Smelter Complex

EXECUTIVE SUMMARY PROJECT BACKGROUND Impala Platinum Limited (Impala), a member of the Implats group of companies, operates platinum group metals mining and processing operations that is located approximately 16 km north-north-west of the town of Rustenburg in the Bojanala Platinum District Municipality in the North West Province. Refer to Figure 1 and Figure 2 for the regional and local setting respectively. The mine operates in accordance to: • an approved Environmental Management Programme (EMPr) (Department of Mineral Resources (DMR) Reference number: NW30/5/1/2/3/2/1/130,131,132 and 133 EM) for their mining and processing operations; and • an Atmospheric Emissions Licence (AEL) (Reference Number: BPDM – RA2- March 2014 / Drying and Smelting) for drying and smelting activities. Impala’s Smelter Complex operates flash and spray dryers on Portion 2 of the farm Beerfontein 263 JQ. Impala is proposing to increase the flash drying capacity at its Smelter Complex (the “Proposed project”), which entails: • the installation of a second flash dryer (Phase 1); and • an upgrade to the flash drying feed circuit (Phase 2). SLR, an independent firm of Environmental Assessment Practitioners (EAPs), has been appointed by Impala to manage the environmental authorisation process.

SUMMARY OF AUTHORISATION REQUIREMENTS Prior to the commencement of the Proposed project, the following is required: • an amended EMPr from the Department of Mineral Resources and Energy (DMRE) (previously the DMR) in terms of Section 102 of the Mineral and Petroleum Resources Development Act, No 28 of 2002 (MPRDA), as amended; • an environmental authorisation from the DMRE in terms of the National Environmental Management Act, No. 107 of 1998 (NEMA), as amended. The Environmental Impact Assessment (EIA) Regulations being followed are Government Notice Regulation (GNR) 982 of 4 December 2014, as amended; and • an update of the AEL from the Bojanala District Municipality in terms of the National Environmental Management: Air Quality Act, No. 39 of 2004 (NEM: AQA), as amended.

STAKEHOLDER ENGAGEMENT The stakeholder engagement process commenced prior to the submission of the Basic Assessment Report (BAR) and has continued throughout the environmental assessment process. As part of this process, the following activities were undertaken:

i Impala Platinum Limited Basic Assessment Report and Environmental Management Programme for the proposed increase 710.09003.00140 of the flash dryer capacity and associated feed circuit modifications at the Impala Rustenburg March 2021 Smelter Complex

• focussed meetings were held with the Mine Community Leadership Engagement Forum; • a focussed meeting was held with the North West Provincial Department of Environment, Conservation and Tourism; • distribution of public participation material (flyers, advertisements, site notices and Background Information Document (BID)) to inform commenting authorities and Interested and Affected Parties (I&APs) of the Proposed project; and • the electronic review of the Background Information Document by Interested and Affected Parties (I&APs). Commenting authorities and I&APs now have the opportunity to review this BAR. All comments submitted to date by the commenting authorities and I&APs have been included and addressed in this BAR. Further comments arising during the review of the BAR will be handled in a similar manner.

OPPORTUNITY TO COMMENT This BAR will be distributed for a 30-day period from 1 April to 5 May 2021 in order to provide I&APs with an opportunity to comment on any aspect of the Proposed project and the findings of the Basic Assessment (BA) process. Copies of the full report are available on the SLR website (at https://slrconsulting.com/public- documents) and the SLR data free website (at slrpublicdocs.datafree.co). Electronic copies (compact disk) of the report are available on request from SLR at the contact details provided below. All comments received during the review process will be addressed in the BAR. Issues and concerns raised to-date, including responses, are provided in Section 7.3.

SLR Consulting (South Africa) (Pty) Ltd Attention: Reinett Mogotshi

PO Box 1596, Cramerview 2060 (if using post please call SLR to notify us of your submission) Tel: (011) 467 0945 E-mail: [email protected]

IMPACTS AND MANAGEMENT ACTIONS This section provides a summary of the assessment of the potential impacts of the Proposed project and provides measures to prevent or mitigate the impacts. The potential impacts associated with the mine activities and infrastructure can be categorised into those that have low, medium, high and/or insignificant significance in the unmitigated scenario. Impacts with a low, medium and/or high category require a measure of management actions which, if successfully implemented will reduce the significance of the impacts. Cumulative impacts (in the context of existing operations), where applicable are also summarised in the table below. The table below provides a summary of the potential impacts in no particular order of importance.

ii Impala Platinum Limited 710.09003.00140 Basic Assessment Report and Environmental Management Programme for the proposed increase of the flash dryer capacity and March 2021 associated feed circuit modifications at the Impala Rustenburg Smelter Complex

TABLE A – POTENTIAL IMPACT SUMMARY Aspect Potential impact Impact discussion and reference to mitigation measures Significance Un M Geology Loss and sterilisation of Impact Insignificant mineral resources • Mineral resources can be sterilized and/or lost through the placement of infrastructure and activities in close proximity to mineral resources. • The Proposed project footprint is within an existing Impala Smelting Complex and does not influence current underground mining activities. It follows that the Proposed project will not result in the sterilisation of any mineral reserves.

Mitigation measures • Not applicable. Topography Altering topography Impact Insignificant • The Proposed project presents hazardous excavations and infrastructure into or off which third parties and animals can fall and be harmed. • The Proposed project does not present any new infrastructure/activities that differ from those already approved within the Smelter Complex. Further to this the footprint of the Proposed project is within the access controlled secured Smelter Complex.

Mitigation measures • Not applicable. Soil and Loss of soil resources and Impact Insignificant land land capability through • Soil is a valuable resource that supports a variety of ecological functions. Soil is the key to re-establishing capability contamination and post closure land capability. Soil resources can be lost through contamination and through physical physical disturbance disturbance (erosion and compaction). This in turn can result in a loss of soils as an ecological driver because it can create a toxic environment for vegetation and ecosystems that rely on the soil. • Given that the Proposed project footprint is within the concrete lined Smelter Complex, soil resources and associated land capability have already been compromised. It follows that the proposed infrastructure will not have an impact on valuable soil resources or related land capability.

Mitigation measures • Not applicable.

i Impala Platinum Limited 710.09003.00140 Basic Assessment Report and Environmental Management Programme for the proposed increase of the flash dryer capacity and March 2021 associated feed circuit modifications at the Impala Rustenburg Smelter Complex

Aspect Potential impact Impact discussion and reference to mitigation measures Significance Un M Biodiversity Physical destruction and Impact Insignificant general disturbance of • Areas of ecological sensitivity include functioning biodiversity areas with species diversity and associated biodiversity intrinsic value. Linkages between these areas have value because of the role they play in allowing the migration or movement of flora and fauna between the areas, which is a key function for a broader ecosystem. The transformation of land for any purpose increases the destruction of the site-specific biodiversity, the fragmentation of habitats, reduces its intrinsic functionality and reduces the linkage role that undeveloped land fulfils between different areas of biodiversity importance. • The Proposed project is located is within the concrete lined Smelter Complex and as such all-natural vegetation has been removed. Further to this, the Smelter Complex is an enclosed facility and does not allow for the natural movement of faunal species, while noisy and vibrating equipment scare off faunal species. It follows that the Proposed project will not have an impact on biodiversity.

Mitigation measures: • Not applicable. Surface Alteration of natural Impact Insignificant water drainage patterns • Surface water resources include drainage lines and paths of preferential flow of stormwater runoff. Mine related activities have the potential to alter the drainage of surface water through the establishment of infrastructure. Rainfall and surface water run-off will be collected in all areas that have been designed with water containment infrastructure. • The collected run-off will therefore be lost to the catchment and can result in the alteration of drainage patterns. Collected run-off within the Smelter Complex is already contained within the existing stormwater management system for the Complex. The Proposed project location within the existing Smelter Complex will not alter the collected run-off contribution to the exiting stormwater management area. It follows that the Proposed project will not have an impact on the alternation of natural drainage patterns.

Mitigation measures • Not applicable. Contamination of surface Impact High Medium water resources • the project presents contamination sources that have the potential to pollute surface water, through accidental spills and leaks. These do not differ from current Smelter contamination sources;

Aspect Potential impact Impact discussion and reference to mitigation measures Significance Un M • the closest surface water resources are the non-perennial Leragane stream, its tributary and wetland (based on provincial database only, not a true reflection of on-site condition); • without mitigation, contaminates can reach surface water resources, which can be used by third parties for domestic purposes; and • with mitigation it is unlikely for contamination to reach surface water resources as these will be contained within the Smelter Complex. Further to this, the surface water resources are non-perennial and communities do have access to reticulated water.

Mitigation measures • continued implementation of containment of dirty water; • continued monitoring and investigation (where necessary); and • equivalent alternative water supply if Impala operations result in contamination of a surface water resources that cannot be accessed by third parties. Groundwat Contamination of Impact: Insignificant er groundwater resources • Groundwater is a valuable resource and is defined as water which is located beneath the ground surface in soil/rock pore spaces and in the fractures of lithological formations. Activities such as the handling and storage of general and hazardous wastes have the potential to result in the loss of groundwater resources, both to the environment and third-party users, through pollution. • The Proposed project is located within the existing Smelter Complex on an impermeable concrete layer. The Proposed project activities/infrastructure is unlikely to contribute to groundwater contamination impacts.

Mitigation measures • Not applicable. Air quality Air pollution (the flash Impact Low Very Low dryer together with • The Proposed project presents emission sources that have the potential to contribute to air pollution,

existing smelter activities) through dust fallout, fine particulate matter (PM10 and PM2.5) and gaseous emissions (SO2, NOx and CO) as a result of transportation, handling materials as well as operation of the second flash dryer emitting through a dedicated baghouse stack. • Scenario 1 (Flash dryer only): Based on modelled results, with and without mitigation the Proposed project is unlikely to exceed the NAAQS and NDCR limits.

iii Impala Platinum Limited 710.09003.00140 Basic Assessment Report and Environmental Management Programme for the proposed increase of the flash dryer capacity and March 2021 associated feed circuit modifications at the Impala Rustenburg Smelter Complex

Aspect Potential impact Impact discussion and reference to mitigation measures Significance Un M • Scenario 2 (the flash dryer together with existing smelter activities): Based on modelled results, with and without mitigation, the Smelter operations (are unlikely to exceed the NAAQS and NDCR limits).

Mitigation measures • Continued implementation of the Impala air quality monitoring programme. Air quality Air pollution (flash dryer Impact High Medium

with all Impala • Scenario 3 (flash dryer with all Impala operations): Based on the model results, the PM10 NAAQS, PM2.5 Medium Low (Dust operations) NAAQS and the NO2 1-hour NAAQS may be exceeded at the closest receptors in future (post 2030). This may (Dust Fallout) be avoided and mitigated through the implementation of new technology by Impala operations within the Fallout) next 10 years. • Based on the measured data from the ambient air quality monitoring stations, which measures the concentrations rates from all current sources in the area, not just Impala, the NAAQS limits are exceeded at

Kelekitso Early Learning Centre and Impala Platinum Hospital for PM2.5, PM10 and NOx. Crushing and screening, vehicles travelling on paved roads and vehicle exhausts have been identified as the major contributors to air quality in these sites. • Emission sources in the surface use area are not only from the Impala operations but also includes surrounding industries/mines and community activities.

• Modelled SO2 levels in terms of the NAAQS are not exceeded. Therefore, it is highly unlikely that the Impala

operations will generate human health impacts relating to SO2 emissions. • The modelled results exceed the daily average NDCR limit on-site and for residential areas at the Platinum Village. However, it is believed that this sample was contaminated or tampered with as a result of construction activities in the vicinity and cannot be used for compliance. • Based on monitoring data, the dustfall rates from all current sources in the area, not just Impala, the dustfall rates are compliant with the NDCR at all sites.

Mitigation measures • Continued implementation of the Impala air quality monitoring programme. • Implementation of measures for reduction of fugitive PM and vehicle exhaust emission. Noise Increase in disturbing Impact Insignificant noise levels • Mining activities and infrastructure have the potential to cause an increase in ambient noise levels that may cause a disturbance to nearby sensitive receptors. It is however important to note that, the noise contributions associated with the Proposed project are unlikely to be noticeable in the context of the existing noise environment within the Smelter Complex.

iv Impala Platinum Limited 710.09003.00140 Basic Assessment Report and Environmental Management Programme for the proposed increase of the flash dryer capacity and March 2021 associated feed circuit modifications at the Impala Rustenburg Smelter Complex

Aspect Potential impact Impact discussion and reference to mitigation measures Significance Un M

Mitigation measures • Not applicable. Visual Negative visual views Impact Insignificant • Mining infrastructure has the potential to alter the landscape character of an area through the establishment of infrastructure. It is however important to note, that the establishment of infrastructure as a result of the Proposed project will be absorbed within the Smelter Complex. • The Proposed project is unlikely to generate additional negative views that will be noticeable from Ga-Luka, located approximately 2 km away from the Proposed project location.

Mitigation measures • Not applicable. Traffic Road disturbance Impact Insignificant influence on the level of • Existing traffic volumes comprising public traffic and traffic from the Impala Smelter operations utilise several service roads intersections. With reference to Section 7.4.3.3, the existing road network of relevance to the Proposed project (Lefaragatlha Road, Luka Road and R565) are considered to have an acceptable level of service. • The Proposed project is not anticipated to generate a significance increase in the number of additional trucks (additional 26 trucks per day, transporting toll) and would therefore have an insignificant impact on the condition of the existing road network.

Mitigation measures • Not applicable.

v Impala Platinum Limited 710.09003.00140 Basic Assessment Report and Environmental Management Programme for the proposed increase of the flash dryer capacity and March 2021 associated feed circuit modifications at the Impala Rustenburg Smelter Complex

Aspect Potential impact Impact discussion and reference to mitigation measures Significance Un M Road safety impacts Impact: High Medium • traffic from mining projects has the potential to result in public road safety issues such as pedestrian accidents and vehicle accidents. • the project will result in additional trucks transporting toll material using Lefaragatlha Road, Luka Road and Road R565. Construction related traffic is limited. • the Lefaragatlha Road and Luka Road have a medium sensitivity as they run through communities. These roads require geometric upgrade in the context of existing public infrastructure. • in the unmitigated scenario the significance is high, particularly where the geometric upgrades are not implemented. • in the mitigated scenario the significance reduces to medium because the frequency of accidents is expected to reduce. Mitigation measures: • undertake a road safety assessment on roads adjacent the Impala Smelter Complex including Intersections A, B, C and F to determine the need for the reflective studs, updating and maintaining road markings and provision of relevant road traffic signs where required. • provide Impala Smelter Complex workers and contractor workers with training on road safety; and • Run road safety and awareness campaigns at the mine. Heritage/cul Loss of heritage/cultural Impact Insignificant tural and and Palaeontological • In general, the Proposed project area is situated in the Central Bankeveld which has a rich archaeological palaeontolo resources heritage dating from prehistoric and historic (or colonial) periods, which form a record of cultural heritage gical of most groups living in South Africa. However, none of the identified heritage resources lies within the resources Proposed project footprint. • The palaeontological studies conducted indicated that the surface use areas are situated on underlying igneous rocks of the Precambrian Rustenburg Layered Suite of the Bushveld Igneous Complex and as such palaeontological resources are not associated with this underlying geology. In addition, the site is located within the disturbed footprint of the Smelter Complex.

Mitigation measures • Not applicable. Socio- Inward migration Impact Insignificant economic • Mines tend to bring with them an expectation of employment in all project phases prior to closure. This expectation can lead to the influx of job seekers to an area which in turn increases pressure on existing communities, housing, basic service delivery and raises concerns around safety and security.

vi Impala Platinum Limited 710.09003.00140 Basic Assessment Report and Environmental Management Programme for the proposed increase of the flash dryer capacity and March 2021 associated feed circuit modifications at the Impala Rustenburg Smelter Complex

Aspect Potential impact Impact discussion and reference to mitigation measures Significance Un M • The Proposed project is located within an existing Smelter Complex and will result in limited short-term employment opportunities through usage of registered community vendors during construction, therefore negative project-related socio-economic impacts including inward migration, which could place additional pressure on housing and municipal services, are not expected to occur.

Mitigation measures: • Not applicable. Economic impact Impact: Insignificant Very Low • Mining activities contribute towards a positive economic impact. (Positive) • The Proposed project will allow for the creation of limited short-term employment for communities during the construction. • The Proposed project will allow continuation of the current employment opportunities during operation, decommission and closure.

Mitigation measures: • Continued implementation of the existing Impala management actions pertaining to the procurement of local people (where possible) and procurement of local goods. Land use Change in land use Impact: Insignificant • There are a number of land uses in the surrounding Proposed project area which may be influenced by the Proposed project and associated potential environmental impacts. • Given that the Land use within the Proposed project is limited to mining as a result of the existing smelter operations, the Proposed project will not result in changes to the current land use.

Mitigation measures • Not applicable.

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ENVIRONMENTAL STATEMENT The assessment of the proposed project presents the potential for negative impacts to occur (particularly in the unmitigated scenario in particular) on the biophysical, cultural and socio-economic environments both on the Proposed project site and in the surrounding area. With management actions these potential impacts can be prevented or reduced to acceptable levels. It follows that provided the EMPr is effectively implemented there is no biophysical, social or economic reason why the Proposed project should not proceed.

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Impala Platinum Limited

CONTENTS

EXECUTIVE SUMMARY ...... I INTRODUCTION ...... XVI PART A - SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT ...... I DETAILS OF THE EAP...... 1 DETAILS OF THE EAP WHO PREPARED THE REPORT ...... 1 EXPERTISE OF THE EAP ...... 1 SLR PROJECT TEAM ...... 1 LOCATION OF ACTIVITY ...... 3 LOCATION OF OVERALL ACTIVITY ...... 3 LOCALITY MAP ...... 3 DESCRIPTION OF THE SCOPE OF THE ACTIVITY ...... 4 OVERVIEW OF EXISTING OPERATIONS ...... 4 UNDERGROUND MINING ...... 4 MINERAL PROCESSING ...... 4 PROPOSED LISTED AND SPECIFIED ACTIVITIES ...... 7 DESCRIPTION OF THE PROPOSED ACTIVITIES ...... 7 OVERVIEW OF THE PROPOSED PROJECT ...... 7 SECOND FLASH DRYER (PHASE 1)...... 12 FLASH DRYING FEED CIRCUIT UPGRADE (PHASE 2) ...... 13 TRANSPORTATION SYSTEM ...... 14 EMPLOYMENT ...... 15 POLICY AND LEGISLATIVE CONTEXT ...... 16 LEGISLATIVE CONSIDERATION IN THE PREPARATION OF THE BASIC ASSESSMENT REPORT ...... 16 MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 ...... 17 NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998, AS AMENDED ...... 17 EIA REGULATIONS 2014 (GNR. 982), AS AMENDED ...... 18 NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT ...... 18 SOUTH AFRICAN NATIONAL AMBIENT AIR QUALITY STANDARDS ...... 18 NATIONAL DUST CONTROL REGULATIONS ...... 19 GUIDELINES, POLICIES, PLANS AND FRAMEWORKS ...... 19 LEGISLATIVE BAR CONTENT REQUIREMENTS ...... 20 NEED AND DESIRABILITY OF THE PROJECT ...... 25 BACKGROUND ...... 25 NATIONAL POLICY AND PLANNING FRAMEWORK ...... 25 NATIONAL DEVELOPMENT PLAN 2030 ...... 25 NEW GROWTH PATH ...... 26 REGIONAL AND LOCAL POLICY AND PLANNING FRAMEWORK ...... 26 CONSISTENCY WITH POLICY AND PLANNING CONTEXT ...... 28 CONSISTENCY WITH NEMA PRINCIPLES ...... 28 ECOLOGICAL SUSTAINABLE DEVELOPMENT AND USE OF NATURAL RESOURCES ...... 31 PROMOTING JUSTIFIABLE ECONOMIC AND SOCIAL DEVELOPMENT ...... 31 MOTIVATION FOR THE PREFERRED SITE, ACTIVITIES AND TECHNOLOGY ALTERNATIVES ...... 32 FULL DESCRIPTION OF THE PROCESS FOLLOWED TO REACH THE PROPOSED PREFERRED ALTERNATIVES WITHIN THE SITE ...... 33 DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED ...... 33 SITE ALTERNATIVE ...... 33

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TECHNOLOGY ALTERNATIVES ...... 33 ACTIVITY ALTERNATIVE ...... 33 THE “NO-GO” ALTERNATIVE ...... 33 DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED ...... 33 PUBLIC PARTICIPATION PROCESS UNDERTAKEN ...... 33 SUMMARY OF ISSUES RAISED BY I&APS ...... 37 ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH PROPOSED PROJECT AND THE ALTERNATIVES ...... 61 BASELINE BIOPHYSICAL ENVIRONMENT AFFECTED BY THE PROPOSED ACTIVITY ...... 61 BASELINE CULTURAL ENVIRONMENT AFFECTED BY THE PROPOSED ACTIVITY ...... 80 BASELINE SOCIO-ECONOMIC ENVIRONMENT AFFECTED BY THE PROPOSED ACTIVITY ...... 82 ENVIRONMENTAL IMPACTS AND RISKS OF THE ALTERNATIVES ...... 93 METHODOLOGY USED IN DETERMINING THE SIGNIFICANCE OF ENVIRONMENTAL IMPACTS ...... 93 POSITIVE AND NEGATIVE IMPACTS OF THE PROPOSED ACTIVITY AND ALTERNATIVES ...... 95 POSSIBLE MANAGEMENT ACTIONS THAT COULD BE APPLIED AND THE LEVEL OF RISK ...... 96 MOTIVATION WHERE NO ALTERNATIVE SITES WERE CONSIDERED ...... 100 STATEMENT MOTIVATING THE PREFERRED ALTERNATIVE ...... 100 FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY, ASSESS AND RANK THE IMPACTS AND RISKS THE ACTIVITY WILL IMPOSE ON THE PREFERRED SITE THROUGH THE LIFE OF THE ACTIVITY .... 101 DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY IMPACTS ...... 101 DESCRIPTION OF THE PROCESS UNDERTAKEN TO ASSESS AND RANK THE IMPACTS AND RISKS ...... 101 A DESCRIPTION OF THE ENVIRONMENTAL IMPACTS AND RISKS IDENTIFIED DURING THE ENVIRONMENTAL ASSESSMENT PROCESS ...... 101 ASSESSMENT OF THE SIGNIFICANCE OF EACH IMPACT AND RISK AND AN INDICATION OF THE EXTENT OF TO WHICH THE ISSUE AND RISK CAN BE AVOIDED OR ADDRESSED BY THE ADOPTION OF MANAGEMENT ACTIONS ...... 102 ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND RISK ...... 103 SUMMARY OF SPECIALIST REPORT FINDINGS...... 108 ENVIRONMENTAL IMPACT STATEMENT ...... 109 SUMMARY OF KEY FINDINGS ...... 109 FINAL SITE MAP ...... 110 SUMMARY OF THE POSITIVE AND NEGATIVE IMPACTS AND RISKS OF THE PROPOSED ACTIVITY AND IDENTIFIED ALTERNATIVES ...... 110 IMPACT MANAGEMENT OBJECTIVES AND OUTCOMES FOR INCLUSION IN THE EMPR ...... 111 PROPOSED MANAGEMENT OBJECTIVES AND OUTCOMES FOR ENVIRONMENTAL AND SOCIO-ECONOMIC IMPACTS ...... 111 IMPACTS THAT REQUIRE MONITORING PROGRAMMES ...... 111 ACTIVITIES AND INFRASTRUCTURE ...... 111 MANAGEMENT ACTIONS ...... 111 ROLES AND RESPONSIBILITIES ...... 112 ASPECTS FOR INCLUSION AS CONDITIONS OF THE AUTHORISATION ...... 113 ASSUMPTIONS, UNCERTAINTIES, LIMITATIONS AND GAPS IN KNOWLEDGE ...... 114 ENVIRONMENTAL ASSESSMENT LIMIT ...... 114 PREDICTIVE MODELS IN GENERAL...... 114 AIR QUALITY ...... 114 TRAFFIC ...... 115 REASONED OPINION AS TO WHETHER THE PROPOSED ACTIVITY SHOULD OR SHOULD NOT BE AUTHORISED ...... 116 REASONS WHY THE ACTIVITY SHOULD BE AUTHORIZED OR NOT ...... 116 CONDITIONS THAT MUST BE INCLUDED IN THE AUTHORISATION ...... 116 SPECIFIC CONDITIONS FOR INCLUSION IN THE EMPR ...... 116 REHABILITATION REQUIREMENTS ...... 116

Impala Platinum Limited

PERIOD FOR WHICH AUTHORISATION IS REQUIRED ...... 117 UNDERTAKING ...... 118 FINANCIAL PROVISION ...... 119 METHODOLOGY APPLIED TO LIABILITY MODEL ...... 119 ASSESSMENT METHODOLOGY ...... 119 QUANTITIES ...... 120 UNIT RATES ...... 120 CONFIRM THAT THE AMOUNT CAN BE PROVIDED FOR FROM OPERATING EXPENDITURE ...... 120 SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY ...... 121 IMPACT ON THE SOCIO-ECONOMIC CONDITIONS OF ANY DIRECTLY AFFECTED PERSON ...... 121 IMPACT ON ANY NATIONAL ESTATE REFERRED TO IN SECTION 3(2) OF THE NATIONAL HERITAGE RESOURCES ACT121 DEPARTMENT OF ENVIRONMENTAL AFFAIRS SCREENING TOOL...... 121 OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A) AND (B) OF THE ACT ...... 123 PART B - ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT ...... II DETAILS OF THE EAP...... 122 DESCRIPTION OF THE ASPECTS OF THE ACTIVITY ...... 123 COMPOSITE MAP ...... 124 DESCRIPTION OF THE IMPACT MANAGEMENT OBJECTIVES INCLUDING MANAGEMENT STATEMENT 125 DETERMINATION OF CLOSURE OBJECTIVES ...... 125 VOLUMES AND RATE OF WATER USE FOR MINING ...... 125 HAS A WATER USE LICENCE BEEN APPLIED FOR? ...... 125 IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES ...... 125 IMPACT MANAGEMENT OUTCOMES ...... 127 IMPACT MANAGEMENT ACTIONS ...... 131 FINANCIAL PROVISION ...... 134 DETERMINATION OF THE AMOUNT OF THE FINANCIAL PROVISION ...... 134 CLOSURE OBJECTIVES DESCRIPTION AND THE ALIGNMENT WITH THE BASELINE ENVIRONMENT ...... 134 CONFIRMATION THAT CLOSURE OBJECTIVES HAVE BEEN CONSULTED WITH I&APS ...... 134 REHABILITATION PLAN ...... 134 COMPATIBILITY OF THE REHABILITATION PLAN WITH THE CLOSURE OBJECTIVES ...... 135 CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION...... 135 CONFIRMATION THAT THE FINANCIAL PROVISION WILL BE PROVIDED ...... 135 MECHANISMS FOR MONITORING COMPLIANCE AND PERFORMANCE AGAINST THE EMPR ...... 136 FREQUENCY OF PERFORMANCE ASSESSMENT REPORT ...... 139 CLOSURE COST REPORTING ...... 139 ENVIRONMENTAL AWARENESS PLAN ...... 140 MANNER IN WHICH APPLICANT INTENDS TO INFORM EMPLOYEES OF THE ENVIRONMENTAL RISKS ...... 140 ENVIRONMENTAL POLICY ...... 140 STEPS TO ACHIEVE THE ENVIRONMENTAL POLICY OBJECTIVES ...... 141 TRAINING OBJECTIVES OF THE ENVIRONMENTAL AWARENESS PLAN ...... 142 GENERAL CONTENTS OF THE ENVIRONMENTAL AWARENESS PLAN ...... 142 MANNER IN WHICH RISKS WILL BE DEALT WITH TO AVOID POLLUTION OR DEGRADATION ...... 144 ON-GOING MONITORING AND MANAGEMENT ACTIONS ...... 144 PROCEDURES IN CASE OF ENVIRONMENTAL EMERGENCIES ...... 144 TECHNICAL, MANAGEMENT AND FINANCIAL OPTIONS ...... 147 SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY ...... 148 UNDERTAKING ...... 149 REFERENCES ...... 150

Impala Platinum Limited

APPENDICES

APPENDIX A: EXISTING AUTHORISATIONS ...... 151 APPENDIX B: EAP CURRICULUM VITAE AND REGISTRATION...... 152 APPENDIX C: STAKEHOLDER ENGAGEMENT ...... 153 APPENDIX D: DETAILED ASSESSMENT OF POTENTIAL IMPACTS ...... 154 APPENDIX E: AIR QUALITY STUDY (AIRSHED, 2020) ...... 170 APPENDIX F: TRAFFIC STUDY (SIYAZI, 2020) ...... 171 APPENDIX G: COMPOSITE MAP ...... 172 APPENDIX H: FINANCIAL PROVISION ...... 173 APPENDIX I: COMPOSITE MAP ...... 174

LIST OF TABLES

TABLE 1-1: DETAILS OF THE EAP ...... 1 TABLE 2-1: DESCRIPTION OF THE PROPERTY...... 3 TABLE 3-1: OVERVIEW OF THE MINERAL PROCESSING OPERATIONS ...... 5 TABLE 3-2: PROPOSED PROJECT LISTED AND SPECIFIED ACTIVITIES ...... 7 TABLE 3-3: PROPOSED PROJECT COMPONENTS FOR THE INCREASED FLASH DRYING CAPACITY ...... 8 TABLE 3-4: LIST OF PROPOSED PROJECT ACTIONS / ACTIVITIES / PROCESSES ...... 10 TABLE 4-1: LEGAL FRAMEWORK ...... 16 TABLE 4-2: NATIONAL AMBIENT AIR QUALITY STANDARDS ...... 19 TABLE 4-3: GUIDELINE AND POLICY FRAMEWORK ...... 19 TABLE 4-4: STRUCTURE OF THE BAR ...... 20 TABLE 5-1: CONSIDERATION OF THE NEMA PRINCIPLES IN RELATION TO THE PROPOSED PROJECT ...... 28 TABLE 7-1: PUBLIC PARTICIPATION PROCESS UNDERTAKEN AS PART OF THE BAR ...... 34 TABLE 7-2: SUMMARY OF ISSUES RAISED BY I&APS ...... 37 TABLE 7-3: MONTHLY TEMPERATURE SUMMARY (AERMET PROCESSED MEASURED DATA, JAN 2019 TO DECEMBER 2020) (AIRSHED, 2020) ...... 65 TABLE 7-4: DUST FALLOUT RATES SUMMARY FOR EXTERNAL BUCKETS (AIRSHED, 2020) ...... 75 TABLE 7-5: MINING / PROSPECTING RIGHTS ...... 84 TABLE 7-6: LAND OWNERSHIP WITHIN THE SURFACE USE AREA ...... 86 TABLE 7-7: TRAFFIC COUNT INFORMATION (SIYAZI, 2020) ...... 91 TABLE 7-8: IMPACT ASSESSMENT METHODOLOGY ...... 93 TABLE 7-9: POSSIBLE MANAGEMENT ACTIONS AND THE ANTICIPATED LEVEL OF RISK ...... 96 TABLE 8-1: LIST OF POTENTIAL IMPACTS AS THEY RELATED TO THE PROPOSED PROJECT ...... 101 TABLE 9-1: ASSESSMENT OF SIGNIFICANT IMPACTS AND RISKS ...... 103 TABLE 10-1: SUMMARY OF SPECIALIST RECOMMENDATIONS ...... 108 TABLE 11-1: SUMMARY OF POTENTIAL IMPACTS ...... 109 TABLE 12-1: ENVIRONMENTAL OBJECTIVES AND OUTCOMES ...... 111 TABLE 19-1: FINDINGS OF THE DEA SCREENING TOOL ...... 121 TABLE 24-1: MEASURES TO REHABILITATE THE ENVIRONMENT AFFECTED BY THE UNDERTAKING OF ANY LISTED ACTIVITY...... 126 TABLE 25-1: DESCRIPTION OF IMPACT MANAGEMENT OUTCOMES ...... 127 TABLE 26-1: DESCRIPTION OF IMPACT MANAGEMENT ACTIONS ...... 131 TABLE 28-1: MONITORING OF COMPLIANCE AND PERFORMANCE ...... 137 TABLE 29-1: EMERGENCY RESPONSE PROCEDURES ...... 146 TABLE 32-1: NATIONAL AMBIENT AIR QUALITY STANDARDS ...... 159 TABLE 32-2: ACCEPTABLE DUSTFALL RATES ...... 159

LIST OF FIGURES

FIGURE 1: REGIONAL SETTING ...... XVIII

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Impala Platinum Limited

FIGURE 2: LOCAL SETTING ...... XIX FIGURE 3: OVERVIEW OF PROCESSING OPERATIONS WITHIN THE SMELTER COMPLEX ...... 6 FIGURE 4: IMAGE OF EXISTING RUSTENBURG SMELTER AND AREAS IDENTIFIED FOR THE LOCATION OF PHASE 1 AND PHASE 2 PROPOSED PROJECT COMPONENTS ...... 8 FIGURE 5: THE DETAILED SITE LAYOUT ...... 9 FIGURE 6: IMAGE OF EXISTING HOT GAS GENERATOR AND DISINTEGRATOR WHICH FORMS PART OF THE PROPOSED PROJECT COMPONENTS FOR THE SECOND FLASH DRYER ...... 12 FIGURE 7: THE PROPOSED LOCATION FOR THE FILTER PLANT, THE EXISTING RE-PULPING STATION WILL BE DEMOLISHED...... 14 FIGURE 8: MONTHLY RAINFALL (LEBONE AMBIENT STATION MEASURED DATA, JAN 2017 - JUL 2020) (AIRSHED, 2020) ...... 63 FIGURE 9: PERIOD, DAY- AND NIGHT-TIME WIND ROSES (AERMET PROCESSED WRF DATA, (AERMET PROCESSED MEASURED DATA, JAN 2019 TO DECEMBER 2020) (AIRSHED, 2020) ...... 64 FIGURE 10: SEASONAL WIND ROSES (AERMET PROCESSED WRF DATA, (AERMET PROCESSED MEASURED DATA, JAN 2019 TO DECEMBER 2020) (AIRSHED, 2020) ...... 65 FIGURE 11: CATCHMENT MAP ...... 70 FIGURE 12: SURFACE WATER RESOURCES ...... 71 FIGURE 13 RECORDED HERITAGE RESOURCES WITHIN THE IMPALA SURFACE USE AREA ...... 81 FIGURE 14: REGIONAL LAND USE MAP ...... 88 FIGURE 15: LOCAL LAND USE MAP ...... 89 FIGURE 16: SENSITIVE ROAD SECTIONS AND INTERSECTIONS INDICATING EXISTING SENSITIVE AREAS AND INTERSECTIONS (SIYAZI, 2020) ...... 92 FIGURE 17: MONITORING PROGRAMME ...... 138

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Impala Platinum Limited

ACRONYMS AND ABBREVIATIONS

Acronym / Abbreviation Definition

AEL Atmospheric Emissions License AQMS Air Quality Monitoring Station AQSR Air Quality Sensitive Receptors BA Basic Assessment BAR Basic Assessment Report BIC Bushveld Igneous Complex BID Background Information Document BPDM Bojanala Platinum District Municipality CO Carbon Monoxide DEA Department of Environmental Affairs DEFF Department of Environment, Forestry and Fisheries DMRE Department of Mineral Resources and Energy DRDLR The Department of Rural Development and Land Reform EAP Environmental Assessment Practitioner EIA Environmental Impact Assessment EMPr Environmental Management Programme GDP Gross Domestic Product GHG Greenhouse gas GVA total Gross Value Added IBA Important Bird Areas IDP Integrated Development Plan LOM Life of Mine MES Minimum National Emission Standards MPRDA Mineral and Petroleum Resources Development Act (No. 28 of 2002) NAAQS National Ambient Air Quality Standards NDCR The National Dust Control Regulations NDP The National Development Plan 2030 NEM: AQA National Environmental Management: Air Quality Act, 2004 NEM:BA National Environmental Management: Biodiversity Act (No. 10 of 2004) NEMA National Environmental Management Act No. 107 of 1998) NGP The New Growth Path

NO2 Nitrogen Dioxide NPAES National Protected Areas Expansion Strategy 2008 PM Particulate Matter

xiv

Impala Platinum Limited

Acronym / Abbreviation Definition

PSDF North West Provincial Spatial Development Framework RBA Royal Bafokeng Administration RLM Rustenburg Local Municipality RLS Rustenburg Layered Suite SACAD South Africa Conservation Areas Database SANS South Africa National Standard SDF Spatial Development Framework SLR SLR Consulting (Africa) (Pty) Ltd TSP Total Suspended Particles

Impala Platinum Limited

INTRODUCTION This chapter provides a brief description of the Proposed project background, describes the purpose of the report, summarises the legislative authorisation requirements and outlines the opportunity for stakeholders to comment.

PROJECT BACKGROUND Impala Platinum Limited (Impala), a member of the Implats group of companies, operates platinum group metals mining and processing operations that is located approximately 16 km north-north-west of the town of Rustenburg in the Bojanala Platinum District Municipality in the North West Province. Refer to Figure 1 and Figure 2 for the regional and local setting respectively. The mine operates in accordance to: • an approved EMPr (DMR Reference number: NW30/5/1/2/3/2/1/130,131,132 and 133 EM) for their mining and processing operations; and • an AEL (Reference Number: BPDM – RA2- March 2014 / Drying and Smelting) for drying and smelting activities. Impala’s Smelter Complex operates flash and spray dryers on Portion 2 of the farm Beerfontein 263 JQ. Impala is proposing to increase flash drying capacity at its Smelter Complex (the “Proposed project”), and which entails: • the installation of a second flash dryer (Phase 1); and • an upgrade to the flash drying feed circuit (Phase 2). SLR, an independent firm of EAPs, has been appointed by Impala to manage the environmental authorisation processes for the Proposed project.

PURPOSE OF THIS REPORT This BAR has been compiled and distributed for review and comment as part of a BA process that is being undertaken for the Proposed project. This BAR provides a description of the Proposed project and the affected environment; summarises the BA process followed to date; identifies and assesses the key Proposed project impacts and presents management and mitigation measures that are recommended to enhance positive and limit negative impacts. I&APs are asked to comment on the BAR. The document will then be updated into a final report, giving due consideration to the comments received. The BAR will be submitted to the DMRE for decision-making purposes.

SUMMARY OF AUTHORISATION REQUIREMENTS Prior to the commencement of the Proposed project, the following is required: • an amended EMPr from the DMRE in terms of Section 102 of the MPRDA, as amended; • an environmental authorisation from the DMRE in terms of the NEMA, as amended. The Environmental Impact Assessment Regulations being followed are Government Notice Regulation (GNR) 982 of 4 December 2014, as amended; and • an update of the AEL from the Bojanala District Municipality in terms of the NEM: AQA, as amended.

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Impala Platinum Limited

TERMS OF REFERENCE SLR, as the independent EAP, is responsible for undertaking the required environmental regulatory process including the required public participation process. The terms of reference for the environmental regulatory process are to: • make application for Environmental Authorisation of the Proposed project in terms of NEMA; • ensure the BA process is undertaken in accordance with the requirements of NEMA, Environmental Impact Assessment (EIA) Regulations 2014 and MPRDA; • ensure the BA is undertaken in an open, participatory manner to ensure that all potential issues of concern and their associated impacts are identified; • undertake a formal public participation process, which includes the distribution of information to I&APs and provides the opportunity for I&APs to raise any concerns/issues, as well as an opportunity to comment on all BA documentation; and • integrate all the information, including the findings of the specialist studies and other relevant information, into a BAR to allow an informed decision to be taken on the Proposed project by the relevant authorities.

Further to this and in accordance with Appendix 1 of the EIA Regulations 2014 (as amended) and the DMRE reporting requirements, the key objectives of this BA process are to: • determine the policy and legislative context within which the proposed activity is located and how the activity complies with and responds to the policy and legislative context; • identify and assess possible activity, location, and technology alternatives; • describe the need and desirability of the proposed alternatives; • undertake an impact and risk assessment process inclusive of cumulative impacts which focused on determining the geographical, physical, biological, social, economic, heritage, and cultural sensitivity of the sites and locations within the sites and the risk of impact of the proposed activity and technology alternatives on these aspects in order to determine the following: o the nature, significance, consequence, extent, duration, and probability of the impacts occurring; o the degree to which these impacts can be reversed, may cause irreplaceable loss of resources and can be avoided, managed or mitigated; o possible impacts the activity and technology alternatives will impose on the sites and location identified through the life of the activity using site sensitivities ranking to: ▪ identify and motivate a preferred site, activity and technology alternative; ▪ identify suitable measures to avoid, manage or mitigate identified impacts; and ▪ identify residual risks that need to be managed and monitored.

xvii

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OPPORTUNITY TO COMMENT This BAR will be distributed for a 30-day period from 1 April to 5 May 2021 in order to provide I&APs with an opportunity to comment on any aspect of the Proposed project and the findings of the BA process. Copies of the full report are available on the SLR website (at https://slrconsulting.com/public-documents) and the SLR data free website (at slrpublicdocs.datafree.co). Electronic copies (compact disk) of the report are available on request from SLR at the contact details provided below. All comments received during the review process will be addressed in the BAR. Issues and concerns raised to- date, including responses, are provided in Section 7.3.

SLR Consulting (South Africa) (Pty) Ltd Attention: Reinett Mogotshi PO Box 1596, Cramerview 2060 (if using post please call SLR to notify us of your submission) Tel: (011) 467 0945 E-mail: [email protected]

Impala Platinum Limited

PART A - SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT

Impala Platinum Limited

DETAILS OF THE EAP This chapter provides the details, qualifications and experience of the Environmental Assessment Practitioner (EAP) undertaking the BA process.

DETAILS OF THE EAP WHO PREPARED THE REPORT SLR Consulting (South Africa) (Pty) Ltd (SLR) has been appointed as the independent EAP to undertake the BA for the proposed increase of the flash dryer capacity and associated feed circuit modifications at the Impala Rustenburg Smelter Complex. The details of the EAP project team that are undertaking this BA process are provided in Table 1-1 below. SLR has no vested interest in the Proposed project other than fair payment for consulting services rendered as part of the BA process and has declared its independence as required by the EIA Regulations, 2014 (as amended). An undertaking the SLR is provided in Section 17.

TABLE 1-1: DETAILS OF THE EAP

General Organisation SLR Consulting (South Africa) (Pty) Ltd Postal Address PO Box 1596, Cramerview, 2060 Tel. No. (011) 467 0945 Fax. No. (011) 467 0978 Name Tasks and roles Email Address Rob Hounsome Document and process review, quality control - Natasha Smyth Project Director, report compilation [email protected] Project Manager, management of BA process, including public Reinett Mogotshi [email protected] consultation and report compilation

EXPERTISE OF THE EAP

SLR PROJECT TEAM Rob Hounsome holds a MSc in Environmental Geochemistry and has approximately 26 years relevant experience. Rob has managed or served as a project director undertaking more than 200 Environmental Social Impact Assessments and Environmental and Social Due Diligence services in nearly 40 countries in accordance with requirements of national governments, industry associations, and various funding agencies including all the major International Finance Institutes, Equator Principle Banks, and/or legal firms, including both Due Diligence Assessments for project financing and advisory on Lender expectations (and associated project financing negotiations). Natasha Smyth holds an Honours degree in Geography and Environmental Management and has approximately 12 years of relevant experience. Natasha has managed and assisted in a wide range of projects for major and small-scale minerals developments throughout South Africa, as well as in Namibia and Zambia. Her areas of expertise include EIAs, Environmental Compliance and Monitoring and Environmental Due Diligence. Reinett Mogotshi holds an Honours degree in Environmental Analysis and Management and has five years of experience in both public and private sectors, primarily agriculture, oil and gas, telecommunication, infrastructure, renewable energy and mining. Her focus is execution and management of environmental

Impala Platinum Limited

Basic Assessment Report and Environmental Management Programme for the proposed increase 710.09003.00140 of the flash dryer capacity and associated feed circuit modifications at the Impala Rustenburg March 2021 Smelter Complex authorisation processes and waste management. She is a Registered Cand.Sci.Nat (Environmental Science) and is a member of the International Association for Impact Assessment South Africa (IAIAsa). Relevant curriculum vitae (including proof of registrations) are attached as Appendix B.

Impala Platinum Limited

LOCATION OF ACTIVITY This chapter provides details of the Proposed project location.

LOCATION OF OVERALL ACTIVITY A description of the property on which the Proposed project is located is provided in Table 2-1.

TABLE 2-1: DESCRIPTION OF THE PROPERTY

Description Details Farm Name Beerfontein 263 JQ Application area (ha) The Proposed project covers an area of approximately 0.14 ha Magisterial district Rustenburg Magisterial District Distance and direction from 16 km north-north-west of the town of Rustenburg in the Bojanala Platinum District nearest town municipality 21-digit Surveyor General Code B0JQ00000000026300002

LOCALITY MAP The regional and local settings are illustrated Figure 1 and Figure 2 respectively.

Impala Platinum Limited

DESCRIPTION OF THE SCOPE OF THE ACTIVITY This chapter introduces the Proposed project and identifies the listed and specified activities. A description of the proposed operations and associated infrastructure is also provided.

Impala Platinum Limited (Impala), a member of the Implats group of companies, own a platinum group metals mining and processing operation that is located approximately 16 km north-north-west of the town of Rustenburg in the Bojanala Platinum District Municipality in the North West Province (see Figure 1). The mine operates with an approved consolidated Environmental Management Programme report (EMPr) (DMRE Reference number: NW30/5/1/2/3/2/1/130,131,132 and 133 EM) for the Smelter Complex and an AEL (Reference Number: BPDM-RA2-MARCH 2014) for drying and smelting. Impala is proposing to amend its AEL to increase its flash drying capacity at its Smelter Complex. The Proposed project will require an amendment to the approved EMPr and environmental authorisation from the DMRE.

OVERVIEW OF EXISTING OPERATIONS Impala’s mining and mineral processing operation is located approximately 16 km north-north-west of the town of Rustenburg. In broad terms, the existing activities of the Impala Rustenburg operations include underground mining and mineral processing. It should be noted that historic opencast mining operations have ceased, and the last pit was rehabilitated in December 2013. Further detail is provided in the sections below.

UNDERGROUND MINING As part of the current Impala underground mining operations, two separate reefs are mined. These include the UG2 reef and the Merensky reef, the mining depths range between 800 m – 2000 m. Impala has a total of 23 mining shafts. Fifteen of these are operational and are used for the extraction of underground Merensky and/or UG2 ore. Three of these are still under construction. Five of these are under care and maintenance. The two types of mining methods can be summarised as follows: • conventional mining: Utilises underground conventional stoping to conduct mining operations. The underground tunnel development is drilled using handheld compressed air powered rockdrills, the subsequent hole drilled for rock extraction are filled with explosives and blasted at a set time. The blasted rocks are extracted, pulled to the main rock transfer system and then hoisted to surface. In underground conventional stoping the cleaning of the blasted rock is conducted using electric powered winches which uses wire ropes to pull on scrapers to scrape the rock into an ore pass which then gets loaded into the hoppers and transported to the shaft ore transfer system. • the mechanised mining operations (trackless mining): Utilises Diesel powered vehicles and hydroelectric drills to conduct the mining operations. The drilling operation is conducted using large hydroelectric drills, the subsequent hole drilled for rock extraction are filled with explosives and blasted at a set time. The blasted rocks are transported to the mine’s ore transfer system.

MINERAL PROCESSING Table 3-1 below provides a high-level overview of the mineral processing activities that currently take place at Impala.

Impala Platinum Limited

TABLE 3-1: OVERVIEW OF THE MINERAL PROCESSING OPERATIONS

Activity Detail Concentrator complex Ore beneficiation The Impala processing operation entails milling of ore from the Merensky and UG2 reefs via concentrator plants. Particles containing precious metals from the milled ore are separated as concentrate and pumped as slurry into the smelter operations for drying. Impala also treats third party materials that are introduced into the furnaces via the spray driers, flash dryer or fed directly into the furnaces. Smelter Complex Drying The concentrate drying within the Impala Smelter Complex is conducted by means of coal-fired spray dryers and a flash dryer.

Spray Dryers Impala uses coal fired spray dryers to dry concentrate that is delivered to the smelter in a slurry form

Flash Dryer Impala uses a single coal fired flash dryer to dry concentrate that is delivered to the smelter in a filter cake form. This flash dryer uses less coal (40% reduction) than the existing spray dryers because the moisture content of the filter cake is less than the slurry.

Please note that the filtration of third party concentrate to produce a filter cake does not take place at the Impala Smelter Complex. The concentrate is delivered as filter cake and dried in the flash dryer. Furnaces The Impala Smelter Complex currently comprises three furnaces. The furnaces have a combined maximum operational electrical capacity of 105 MW (1 x 38 MW, 1 x 35MW and 1 x 32 MW). These furnaces use electrically fed electrodes to smelt the dried concentrate to produce a slag and a furnace matte. Converter Currently Impala uses a converter plant that comprises six vessels with a combined throughput capacity of 375 tonnes per day. The converter plant is used to remove iron (in the form of a slag) from the furnace matte by creating an exothermic reaction that is caused by blowing air through the molten furnace matte. Following converter slag removal, converter matte is poured from the open converter port into ladles and granulated in a high-pressure water stream. The granulated converter matte is the final product and is transported by road to the refinery in Springs.

Figure 3 Overview of Smelting Operations within the Smelter Complex

EMERGENCY ONLY – WHEN CONVERTOR TO AIR/GAS GAS CLEANING PLANT IS NOT AVAILABLE CLEANING SYSTEM EVAPORATED RAND WATER WATER

EVAPORATED OFF GAS WATER TO AIR/GAS DUST CLEANING SYSTEM FURNACE GRANULATOR POLLUTED AIR MATTE

CONCENTRATE 2 OPERATIONAL FROM IMPALA SPRAY DUST CLOSED GRANULATED AND OTHER SLURRY DRIER FURNACES MATERIAL MINES Each furnace = 38 megawatts HEAT

COMBUSTION DUST STOCKPILE CHAMBER 3 SILOS AREA (6 000 tons) 1 REFURBISHED COAL AIR CLOSED FURNACE FEED TO ALL NORMAL DUST 3 FURNACES Furnace = 32 megawatts OPERATING FLASH (157 tons/hour) FILTER DRIER CONDITIONS CAKE FURNACE MATTE

PROCESS 1 SILO HEAT WATER (7 200 tons) FILTER CAKE HAS A COMBUSTION SLAG TO AIR/GAS LOWER MOISTURE CHAMBER CONTENT THAN EVAPORATED CLEANING SLURRY WATER COOLING SYSTEM TOWER LESS AIR COAL AIR GRANULATOR OFF GAS

EVAPORATED WATER EXISTING CONVERTOR SLURRY SLAG PLANT PROCESSING GRANULATOR SLAG (7 vessels) PLANT LEGEND OLD SLAG DUMP

WASTE BLACK/ Existing smelter operations Return circuits IMPALA REFINERY EVAPORATED GREY (IN SPRINGS) WATER

BLUE Water circuit To air cleaning system RAND CONVERTOR MATTE GRANULATOR (FINAL PRODUCT) TAILINGS DAM WATER Impala Platinum Limited

PROPOSED LISTED AND SPECIFIED ACTIVITIES Listed activities in terms of NEMA and NEMA:QA that require authorisation as a result of the proposed increase of the flash drying capacity are included in the table below.

TABLE 3-2: PROPOSED PROJECT LISTED AND SPECIFIED ACTIVITIES

Description of the Proposed project Extent of the activity Listed Listed activity number, applicable listing notice activity (ha) activity and activity description (mark with an x) National Environmental Management Act (No. 107 of 1998), as amended Installation of an additional flash The total Proposed X Listing Notice 1, GNR 983, Activity 34: The dryer, upgrade of the flash drying feed project area for Phase 1 expansion of existing facilities or infrastructure for and integration of a filtration plant and Phase 2 covers an any process or activity where such expansion will into the feed circuit. area of approximately result in the need for a permit or licence or an 0.14 ha amended permit or licence in terms of national or provincial legislation governing the release of emissions, effluent or pollution.

Relevance: The increase of the flash drying capacity requires an amendment of the existing AEL. National Environmental Management: Air Quality Act, 2004 (No. 39 of 2004, NEM: AQA), as amended Installation of an additional flash Not applicable X Subcategory 4.1: Drying and calcining of mineral dryer, upgrade of the flash drying feed solids including ore. and integration of a filtration plant into the feed circuit. Relevance: The increase of the flash drying capacity requires an amendment of the existing AEL in terms of Subcategory 4.1.

DESCRIPTION OF THE PROPOSED ACTIVITIES The section below provides a discussion on the activities that will take place during the construction and operational phases of the Proposed project. Where existing infrastructure needs to be decommissioned in order to allow for the establishment of the Proposed project components, this has been indicated in the section below. It is important to note that decommissioning and closure related activities for the Proposed project components will form part of the existing approved activities for the mine.

OVERVIEW OF THE PROPOSED PROJECT Impala is planning to increase its flash drying capacity, which requires the installation of a second flash dryer (Phase 1) and associated feed circuit modifications (in Phase 2). This will increase filter cake treatment capacity, which in turn will increase and improve toll concentrate stockpile reclamation capabilities. The main Proposed project components that make up each phase are listed in Table 3-3 below.

Impala Platinum Limited

TABLE 3-3: PROPOSED PROJECT COMPONENTS FOR THE INCREASED FLASH DRYING CAPACITY Second Flash Dryer (Phase 1) Flash Drying Feed Circuit Upgrade (Phase 2) The main components of Phase 1 include: The main components of Phase 2 include: • transfer tower; • structural modifications include; • wet feeder; • feed distribution tower; • wet feed conveyors; • filter plant; and • flash dryer (similarly sized to the existing dryer); • wet feed conveyors. and • bag house.

An image of the existing Rustenburg Smelter Complex showing the areas identified for the location of Phase 1 and Phase 2 Proposed project components is shown in Figure 4 below. The detailed site layout is presented in Figure 5. It is anticipated the construction phase activities would be undertaken for a period of 30 months (2.5 years) and in a phased approach (i.e. Phase 1 (18 Months) and Phase 2 (12 months)). This will allow for the continuation of the current flash drying throughput. An overview of the activities and infrastructure are provided in Table 3-4.

FIGURE 4: IMAGE OF EXISTING RUSTENBURG SMELTER AND AREAS IDENTIFIED FOR THE LOCATION OF PHASE 1 AND PHASE 2 PROPOSED PROJECT COMPONENTS

Impala Platinum Limited Basic Assessment Report and Environmental Management Programme for the proposed increase of the flash dryer capacity and associated feed 710.09003.00140 circuit modifications at the Impala Rustenburg Smelter Complex March 2021

TABLE 3-4: LIST OF PROPOSED PROJECT ACTIONS / ACTIVITIES / PROCESSES

Main activity/process Sub-activities Construction Operation Decommissioning Closure Site preparation Repurposing and removal of existing structures . On-going Demolition of existing re-pulping station. At start of phase Establishing the construction contractor’s laydown area (if At start of phase required). Earthworks Use of existing vehicle maintenance, wash bays, storage of On-going fuel and lubricants. Cleaning, grubbing and bulldozing activities. On-going Digging trenches and foundations. On-going Civil works Site excavation. On-going Civil works on site relate Installation of re-bar. On-going mainly to any steel and concrete work. Mixing of concrete and concrete work, such as casting of On-going plinths. Steel work (including grinding and welding). On-going Storage and handling of fuel, lubricants, sand, rock, cement, On-going chemical additives in cements. Installation of flash dryer and feed circuit upgrade. On-going Transport System The use of parking, loading and off-loading areas for trucks, On-going On-going On-going busses and other vehicles. Transportation of staff to and from site (using private cars On-going On-going On-going and busses via existing roads). Transport of toll and matte via trucks. On-going General site management Appointment of contractors and establishment of On-going On-going On-going contractor laydown area. Site management (monitoring, inspections, maintenance, On-going On-going On-going security, access control). Operation and maintenance of mechanical equipment, electrical equipment and reticulation.

Main activity/process Sub-activities Construction Operation Decommissioning Closure Environmental awareness training and emergency response. On-going On-going On-going Implementing and maintaining management plans. On-going On-going On-going Demolition (part of Removing contractor laydown area At end of phase At end of phase existing approved Dismantling and demolition of infrastructure and For maintenance On-going activities) equipment. Rehabilitation (part of Replacing soil resources On-going existing approved Slope stabilisation and erosion control. On-going activities) Landscaping. On-going Re-vegetation of disturbed areas and where infrastructure On-going was removed. Removal of alien invasive species from rehabilitated sites. On-going Maintenance and Initiation of aftercare and maintenance program. As required aftercare Maintenance and repair of post closure landforms, facilities, As required and rehabilitated areas.

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SECOND FLASH DRYER (PHASE 1) The main Proposed project components associated with Phase 1 of the Proposed project include the following: • wet feed: A wet concentrate screw feeder inclusive of a transfer feed conveyor, a magnetic separator and intermediate conveyor transfer tower; • heat source: A fluid bed combustor inclusive of a coal reticulation system, hot ducts, stack and integrated diesel burner system; • second flash dryer: The flash dryer comprising a twin shaft back mixer, disintegrator, drying column, primary cyclones, multi-clone, a baghouse, exhaust fan, stack and a 500-tonne product silo and interconnecting ducting; • dry product pneumatic transfer system: Two dense pneumatic concentrate transfer systems; • utility reticulation: An air and diesel reticulation system, comprising piping, pumps and air dyers; • electrical equipment and reticulation: Additional electrical equipment and reticulation (cable racking, electrical panels, lighting and lightening protection as well as a 380V transformer); and • instrumentation: Provision of plant PLC and control equipment, cable racking and cables as well as all relevant instrumentation. This package also includes systems integration and process interfacing.

Hot gas generator Disintegrator FIGURE 6: IMAGE OF EXISTING HOT GAS GENERATOR AND DISINTEGRATOR WHICH FORMS PART OF THE PROPOSED PROJECT COMPONENTS FOR THE SECOND FLASH DRYER

The second flash dryer will be similarly sized and be of similar design to the existing dryer (i.e. 52.8 tph wet; 45 tph dry), since this will allow scheduled maintenance with minimal impact on throughput, as well as ensure maximum compatibility of spares between the two production units.

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The design enhancements which were developed since the installation of the existing flash, which will be incorporated in the design of the second flash dryer include: • improved burner and fluidised bed hot gas generator design, with a more effective combustion circuit which reduces diesel consumption during start-up and stand-by (caretaker) operating modes; • revised design of back mixer, which utilises the same components in an alternative arrangement, simplifying maintenance; • split casing design of the disintegrator, reducing maintenance related downtime requirements; • revised silo footing design and placement, which reduces the structural support required from the flash dryer building, thereby improving Proposed project costs; • supply and installation of structural and civil components required to extend the feed shed roof to ensure all feed points are safeguarded against rainwater and associated feeder blockages; and • upgrade of the existing pneumatic transfer systems to augment inter-silo transfer capabilities, thereby catering for the increase in concentrate transfers that will be received from the extended flash drying circuit.

FLASH DRYING FEED CIRCUIT UPGRADE (PHASE 2) The main Proposed project components associated with Phase 2 of the Proposed project include the following: • feed distribution: Installation and commissioning of two new wet concentrate screw feeders complete with a common wet feed bin; • wet feed conveyor: Installation of all structures, conveyors and the restructuring and extension of the existing primary wet feed conveyor; • filter plant: Design, procurement, supply as well as installation and commissioning of a filtration plant, complete with conveyor transfer to the common wet feed bin. The existing re-pulping station will be demolished to allow for the establishment of the filter plant; • electrical equipment and reticulation: Additional electrical equipment and reticulation (cable racking, electrical panels, lighting and lightening protection as well as variable speed drives); and • instrumentation: Provision of plant PLC and control equipment, cable racking and cables as well as all relevant instrumentation. This package also includes systems integration and process interfacing.

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FIGURE 7: THE PROPOSED LOCATION FOR THE FILTER PLANT, THE EXISTING RE-PULPING STATION WILL BE DEMOLISHED.

The feed circuit upgrade will enable both dryers to be fed simultaneously via the existing circuit, while addressing inconsistent feed challenges inherent to the current feed system. Furthermore, the upgrade will also negate the need for additional dedicated labour to maintain feed profiles at two separate feeding stations. The installation of a filter plant to pre-treat Platinum Group Metals concentrate slurry for processing through the enlarged flash dryer circuit will yield the following benefits: • unlock water recovery potential currently lost through evaporation within the spray drying circuit, while improving coal unit consumption by offsetting a portion of the throughput from the least efficient spray drying units, by means of complete utilisation of available flash dryer capacity; and • provide relief in terms of production pressure on the spray dryer installations, thereby facilitating more regular maintenance.

TRANSPORTATION SYSTEM Traffic-related information as a result of the Proposed project is provided below: • during construction, the Proposed project will result in 5 additional heavy vehicles per day at peak delivery of construction materials; and • during operation, the Proposed project will result in 26 additional 30 tonnes trucks per day delivering third party toll to be processed via the flash dryers. Access to the Smelter Complex will be through existing road networks (via Lefaragatlha or Luka road). Given that the capacity of the Smelter Complex does not change as a result of the Proposed project, it is likely that there would not be an increase of matte transported offsite.

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EMPLOYMENT Due to the nature of the project, the Proposed project is not anticipated to generate significant job opportunities. Limited job opportunities will be available during the construction phase of the Proposed project and will be limited to a period of 2.5 years. During the operational phase of the Proposed project, no new job opportunities are anticipated as existing employees will be utilised.

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POLICY AND LEGISLATIVE CONTEXT This chapter outlines the key legislative requirements applicable to the Proposed project and outlines the guidelines, policies and plans that have been considered during the BA process.

LEGISLATIVE CONSIDERATION IN THE PREPARATION OF THE BASIC ASSESSMENT REPORT In accordance with the EIA Regulations 2014 (as amended) and the DMRE BAR template requirements, all legislation and guidelines that have been considered in the BA process must be documented. Table 4-1 below provides a summary of the applicable legislative context.

TABLE 4-1: LEGAL FRAMEWORK

Applicable legislation and Reference where How does this development comply with and respond to the policy and guidelines used to compile the applied legislative context? report Mineral and Petroleum Resources Introduction Authorisation is required from the DMRE in terms of Section 102 of the Development Act (No. 28 of 2002) MPRDA to amend the existing EMPr to take cognisance of the Proposed (MPRDA), as amended project. This BAR and EMPr will support this application.

The Section 102 application was lodged on 29 March 2021. National Environmental Introduction, The proposed project requires environmental authorisation in terms of the Management Act No. 107 of 1998) Section 3.2 and NEMA for Listed activities included in Listing Notice 1 of GNR 983, as (NEMA), as amended Section 7.2.1 amended. The relevant NEMA listed activities are included in Section 3.2. A copy of the NEMA application is included in Appendix C. The NEMA Regulations 982 of 4 December application form was submitted to the DMRE on 29 March 2021. 2014 (EIA Regulations), as amended The public participation process has also been undertaken in accordance with Chapter 6 of the EIA Regulations. National Environmental Introduction and The increase of the flash drying capacity requires an amendment of the Management: Air Quality Act, Section 3.2. existing AEL. The relevant listed activities are included in Section 3.2. 2004 and regulations National Atmospheric Emission Section 26 Registration and reporting on the National Emissions Inventory System. Reporting Regulations in terms of the National Environmental Management: Air Quality Act (No. 39 of 2004) National Water Act (No. 36 of Section 7.4.1 This Act provides for the conservation, management and protection of the 1998), as amended nation’s water resources. The Smelter Complex is located adjacent to a non- perennial stream and several wetlands. However, there are no surface water features within 100 m of the project footprint. National Environmental Section 7.4.1.5 Biodiversity was taken into consideration as part of the proposed project. It Management: Biodiversity Act is however important to note that the proposed project area is located (No. 10 of 2004) (NEM:BA) within an already disturbed area. National Protected Areas Expansion Strategy 2008 (NPAES) South Africa Conservation Areas Database (SACAD, 2017) South Africa Protected Area Database (SAPAD, 2017)

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Applicable legislation and Reference where How does this development comply with and respond to the policy and guidelines used to compile the applied legislative context? report Mining and Biodiversity Guidelines (2013) North West Biodiversity Sector Plan (2015) Important Bird Areas (IBA’s) (2015) According to the NEM:BA, Alien and Invasive Species list of July 2016 National Freshwater Ecosystem Priority Areas (NFEPA). National Heritage Resources Act, Section 7.4.2 Heritage/cultural and paleontological resources were taken into 1999 consideration as part of the propose project. It is important to note that the proposed project area is located within the disturbed footprint of the Smelter Complex.

MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 The MPRDA (No. 28 of 2002), as amended governs the acquisition, use and disposal of mineral and petroleum resources. The objectives of the act, amongst others, are to promote economic growth and mineral and petroleum resources development in the Republic, particularly development of downstream industries through provision of feedstock and development of mining and petroleum inputs industries and also to promote employment and advance the social and economic welfare of all South Africans. Chapter 4 of the Mineral and Environmental Regulation provides a framework on the application of mining, prospecting and closure rights. The DMRE must apply the range of environmental principles included in Section 2 of NEMA when taking decisions that significantly affect the environment. To give effect to the general objectives of Integrated Environmental Management, the potential impacts on the environment of listed or specified activities must be considered, investigated, assessed and reported on to the competent authority. Section 24(4) of NEMA provides the minimum requirements for procedures for the investigation, assessment, management, and communication of the potential impacts. In addition, Section 102 of the MPRDA governs the amendment of rights, permits, programmes and plans. In terms of the act, authorisation is required to amend the approved EMPr to take cognisance of the proposed project.

NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998, AS AMENDED The National Environmental Management Act, 1998 (No. 107 of 1998), as amended (NEMA), establishes principles and provides a regulatory framework for decision-making on matters affecting the environment. All organs of state must apply the range of environmental principles included in Section 2 of NEMA when taking decisions that significantly affect the environment. Included amongst the key principles is that all development must be socially, economically and environmentally sustainable and that environmental management must place people and their needs at the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably. The participation of I&APs is stipulated, as is that decisions must take into account the interests, needs and values of all I&APs. Chapter 5 of NEMA provides a framework for the integration of environmental issues into the planning, design, decision-making and implementation of plans and development proposals. Section 24 provides a framework for granting of environmental authorisations. To give effect to the general objectives of Integrated Environmental

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Management, the potential impacts on the environment of listed or specified activities must be considered, investigated, assessed and reported on to the competent authority. Section 24(4) provides the minimum requirements for procedures for the investigation, assessment, management and communication of the potential impacts. In terms of the management of impacts on the environment, Section 24N details the requirements for an EMPr.

EIA REGULATIONS 2014 (GNR. 982), AS AMENDED The EIA Regulations, 2014 (as amended by GN No. 326 of 7 April 2017) promulgated in terms of Chapter 5 of NEMA provide for control over certain listed activities. These listed activities are detailed in Listing Notice 1 (as amended by GN No. 327 of 7 April 2017), Listing Notice 2 (as amended by GN No. 325 of 7 April 2017) and Listing Notice 3 (as amended by GN No. 324 of 7 April 2017). The undertaking of activities specified in the Listing Notices is prohibited until Environmental Authorisation has been obtained from the competent authority. Such Environmental Authorisation, which may be granted subject to conditions, will only be considered once there has been compliance with the EIA Regulations, 2014. The EIA Regulations, 2014 (as amended) set out the procedures and documentation that need to be complied with when applying for Environmental Authorisation. A Basic Assessment process must be applied to an application if the authorisation applied for is in respect of an activity or activities listed in Listing Notices 1 and/or 3 and a Scoping and EIA process must be applied to an application if the authorisation applied for is in respect of an activity or activities listed in Listing Notice 2. The proposed project triggers activities in terms of Listing Notice 1, Table 3-2) and therefore a Basic Assessment process is required in order for the DMRE to consider the application in terms of NEMA.

NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT This Act regulates all aspects of air quality, including prevention of pollution and environmental degradation; providing for national norms and standards regulating air quality monitoring, management and control; and licencing of activities that result in atmospheric emissions and have or may have a significant detrimental effect on the environment. The NEM: AQA has established a National Framework for Air Quality Management with various standards being implemented. The updated Listed Activities and Minimum National Emission Standards (MES) were published in 2013 (GN 893, in Government Gazette No. 37054) as amended by GN 551, 12 June 2015; GN 1207, 18 October 2018; GN 687, 22 May 2019 and GN 421, 27 March 2020). The proposed project triggers listed activities in terms of these regulations and require an amendment to the existing AEL.

SOUTH AFRICAN NATIONAL AMBIENT AIR QUALITY STANDARDS Criteria pollutants are considered those pollutants most commonly found in the atmosphere, that have proven detrimental health effects when inhaled and are regulated by ambient air quality criteria. These generally include PM10, PM2.5, SO2, NO2, CO and O3. The initial National Ambient Air Quality Standards (NAAQS) were published for comment in the Government Gazette on 9 June 2007. The revised NAAQS were subsequently published for comment in the Government Gazette on the 13th of March 2009. The final revised NAAQS were published in the Government Gazette on the 24th of December 2009 (GN 1210, Government Gazette 32816) and additional standards for PM2.5 were published on the 29th June 2012 (GN 486, Government Gazette no. 35463). NAAQS for the pollutants assessed in this study are listed in Table 4-2 below.

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TABLE 4-2: NATIONAL AMBIENT AIR QUALITY STANDARDS Pollutant Averaging Period Concentration Permitted Compliance Date (µg/m³) Frequency of Exceedance

PM10 24-hour 75 4 Currently enforceable 1 year 40 - Currently enforceable

PM2.5 24-hour 40 4 1 January 2016 till 31 December 2029 (currently enforceable) 24-hour 25 4 1 January 2030 1 year 20 - 1 January 2016 till 31 December 2029 (currently enforceable) 1 year 15 - 1 January 2030

SO2 10-minutes 500 526 Currently enforceable 1-hour 350 88 Currently enforceable 24-hour 125 4 Currently enforceable 1 year 50 - Currently enforceable

NO2 1-hour 200 88 Currently enforceable 1 year 40 - Currently enforceable CO 1-hour 30 000 88 Currently enforceable 8-hour 10 000 11 Currently enforceable

NATIONAL DUST CONTROL REGULATIONS The National Dust Control Regulations (NDCR) prescribe general measures for the control of dust in all areas including residential and light commercial areas. The regulations provide a guideline for monitoring and measuring dust fall. Dust fall is assessed for nuisance impact and not an inhalation health impact. Potential dust fall from the refined closure plan will be assessed against the NDCR.

GUIDELINES, POLICIES, PLANS AND FRAMEWORKS The guidelines, policies and plans listed in Table 4-3 have been taken into account during the BA process and as part of specialist studies, where applicable.

TABLE 4-3: GUIDELINE AND POLICY FRAMEWORK

Guideline Governing body Relevance Public participation guideline in Department of The purpose of this guideline is to ensure that an adequate public participation terms of NEMA (2017) Environmental process is undertaken during the BA process (Section 7.2). Affairs Guideline on need and Department of This guideline informs the consideration of the need and desirability aspects of desirability (2017) Environmental the proposed project as outlined in Section 5. Affairs National Development Plan NPC The National Development Plan 2030 (NDP) is the overarching development 2030 planning policy for the country, to which all other development planning, in particular spatial planning must be aligned. The NDP outline South Africa’s Vision, and provides the Framework for eliminating poverty and reducing inequality by 2030 (Section 5).

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Guideline Governing body Relevance New Growth Path (2011) Department of The New Growth Path (NGP) (2011) reflects the commitment of Government to Economic prioritise employment creation in all economic policies and sets out the key Development drivers and sectors for employment which will be the focus of Government (Section 5). Rustenburg Local Municipality Rustenburg Local The Rustenburg Local Municipality Integrated Development Plan is the principle Integrated Development Plan Municipality strategic instrument guiding all planning, management, investment and 2018-2019 development within the province in order to provide best solutions towards sustainable development (Section 5). Bojanala Platinum District Bojanala Platinum The Bojanala Platinum District Municipality Integrated Development Plan is the Municipality Integrated District principle strategic instrument guiding all planning, management, investment and Development Plan 2017-2022 Municipality development within the province in order to provide best solutions towards sustainable development (Section 5). North West Provincial Spatial Office of the Sets out the key spatial challenges faced by the Province and the proposed spatial Development Framework Premier North policies, which have been formulated to address these challenges. As such, it West supports the spatial development vision to achieve the North West Development Plan 2030 (Section 5). North West Development North West The vision of the strategic plan is to ensure that the North West province Corporation Strategic Plan Provincial becomes the cornerstone of sustainable economic development and job 2015-2020 Government creation. This would be achieved through the province’s contribution to economic growth through sustained focus on agriculture, culture and tourism through villages, townships and small dorpies (Section 5).

LEGISLATIVE BAR CONTENT REQUIREMENTS This document has been prepared in accordance with the DMRE BAR template format and was informed by the guidelines posted on the official DMRE website. This is in accordance with the requirements of the MPRDA. This report also complies with the requirements of the NEMA and Appendix 2 and Appendix 4 of EIA Regulations 2014 (GNR. 982), as amended. Table 4-4 provides a summary of the requirements, with cross references to the report sections where these requirements have been addressed.

TABLE 4-4: STRUCTURE OF THE BAR

BAR requirement as per the BAR requirements as per the 2014 NEMA Regulations (GNR. Reference in the report DMR template 982), as amended Part A of DMR report Appendix 2 of the NEMA regulations, as amended Section/Appendix template Details of the EAP. Details of the EAP who prepared the report. Section 1.1. Expertise of the EAP. Details of the expertise of the EAP, including curriculum vitae. Section 1.2 and Appendix B Location of overall activity. The location of the activity, including - the 21-digit Surveyor General Section 2 code of each cadastral land parcel. Where available the physical address and farm name. Where the required information is not available, the coordinates of the boundary of the property or properties. Locality plan. A plan which locates the proposed activity or activities applied for Section 2. as well as the associated structures and infrastructure at an appropriate scale, or, if it is a linear activity, a description and coordinates of the corridor in which the proposed activity or

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BAR requirement as per the BAR requirements as per the 2014 NEMA Regulations (GNR. Reference in the report DMR template 982), as amended activities is to be undertaken or on land where the property has not been defined, the coordinates within which the activity is to be undertaken. Description of the scope of the A description of the scope of the proposed activity, including all Section 3. proposed overall activity. listed and specified activities triggered. A description of the activities to be undertaken, including associated structure and infrastructure. Policy and legislative context. A description of the policy and legislative context within which the Section 4. development is located and an explanation of how the proposed development complies with and responds to the legislation and policy context. Need and desirability of the A motivation for the need and desirability for the proposed Section 5. proposed activity. development including the need and desirability of the activity in the context of the preferred location. Motivation for the overall A motivation of the preferred development footprint within the Section 6. preferred site, activities and approved site including. technology alternative. A full description of the process A full description of the process followed to reach the proposed Section 7. followed to reach the proposed development footprint within the approved site. development footprint within the site. Details of the development Details of all the alternatives considered. Section 7.1. footprint alternatives considered. Details of the public participation Details of the public participation process undertaken in terms of Section 7.2. process followed. regulation 41 of the Regulations, including copies of the supporting documents and inputs. Summary of issues raised by A summary of the issues raised by interested and affected parties, Section 7.3. I&APs. and an indication of the manner in which the issues were incorporated, or the reasons for not including them. Environmental attributes The environmental attributes associated with the alternatives Section 7.4. associated with the alternatives. focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects. Impacts and risks identified The impacts and risks identified, including the nature, significance, Section 7.5. including the nature, significance, consequence, extent, duration and probability of the impacts, consequence, extent, duration including the degree to which these impacts can be reversed, may and probability of the impacts cause irreplaceable loss of resources and can be avoided, managed including the degree of the and mitigated. impacts. Methodology used in determining The methodology used in determining and ranking the nature, Section 7.6. the nature, significance, significance, consequences, extent, duration and probability of consequence, extent, duration potential environmental impacts and risks. and probability of potential environmental impacts and risks. The positive and negative impacts Positive and negative impacts that the proposed activity and Section 7.7. that the proposed activity (in alternatives will have on the environment and on the community terms of the initial site layout) and that may be affected focusing on the geographical, physical, alternative will have on the biological, social, economic, heritage and cultural aspects. environment and the community that may be affected.

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BAR requirement as per the BAR requirements as per the 2014 NEMA Regulations (GNR. Reference in the report DMR template 982), as amended The possible management actions The possible management actions that could be applied and level Section 7.8. that could be applied and the of residual risk. level of risk. Motivation where no alternative The outcome of the site selection matrix. If no alternatives, Section 7.9. sites were considered. including alternative locations for the activity were investigated, the motivation for not considering such. Statement motivating the A concluding statement indicating the preferred alternatives, Section 7.10. alternative development location including preferred location within the approved site. within the overall site. Full description of the process A full description of the process undertaken to identify, assess and Section 8. undertaken to identify, assess and rank the impacts the activity and associated structure and rank the impacts and risks the infrastructure will impose on the preferred location through the life activity will impose on the of the activity including a description of all environmental issues preferred site (in respect of the and risks that were identified during the environmental impact final site layout) through the life assessment process and an assessment of the significance of each of the activity. issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of management actions. Assessment of each identified An assessment of each identified potentially significant impact and Section 9 potentially significant impact and risk including cumulative impacts, the nature, significant and risk. consequence of the impact and risk, the extent and duration of the impact and risk, the probability of the impact and risk occurring, the degree to which the impact can be reversed, the degree to which the impact and risk may cause irreplaceable loss of a resources and the degree to which the impact and risk can be mitigated. Summary of specialist reports. Where applicable the summary of the findings and Section 10 recommendations of any specialist report complying with Appendix 6 of these Regulations and an indication as to how these findings and recommendations have been included in the final assessment report. Environmental impact statement. An environmental impact statement which contains a summary of Section 11 the key findings of the environmental impact assessment, a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers and a summary of the positive and negative impacts and risks of the proposed activity and identified alternatives. Proposed impact management Based on the assessment, and where applicable, recommendations Section 12 objectives and the impact from specialist reports, the recording of proposed impact management outcomes for management objectives, and the impact management outcomes inclusion in the EMPr. for the development for inclusion in the EMPr. Aspects for inclusion as Any aspects which were conditional to the findings of the Section 13 conditions of authorisation. assessment either by the EAP or specialist which are to be included as conditions of authorisation. Description of any assumptions, A description of any assumptions, uncertainties and gaps in Section 14 uncertainties and gaps in knowledge which relate to the assessment and management knowledge. actions proposed.

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BAR requirement as per the BAR requirements as per the 2014 NEMA Regulations (GNR. Reference in the report DMR template 982), as amended Reasoned opinion as to whether Reasoned opinion as to whether the proposed activity should or Section 14.3 the proposed activity should or should not be authorised, and if the opinion is that it should be should not be authorised. authorised, any conditions that should be made in respect of that authorisation. Period for which environmental Where the proposed activity does not include operational aspects, Section 16 authorisation is required. the period for which the environmental authorisation is required and the date on which the activity will be concluded, and the post construction monitoring requirements finalised. Undertaking. An undertaking under oath or affirmation by the EAP in relation to Section 17 the correctness of the information provided in the reports, the inclusion of comments and inputs from stakeholders and l&APs, the inclusion of inputs and recommendations from the specialist reports where relevant and any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested or affected parties. Financial provision. Where applicable, details of any financial provisions for the Section 18 rehabilitation, closure, and ongoing post decommissioning management of negative environmental impacts. Specific information required by Any specific information required by the competent authority. Section 19 the competent authority. Other matter required in terms of Any other matter required in terms of section 24(4)(a) and (b) of Section 20 section 24(4)(a) and (b) of the Act. the Act. Part B of the DMR report Appendix 4 of the NEMA regulations Section/Appendix template Details of EAP. Details of the EAP who prepared the EMPr and the expertise of that Section 21 EAP to prepare the EMPr, including curriculum vitae. Description of the aspects of the A detailed description of the aspects of the activity that are covered Section 22 activity. by the EMPr as identified by the project description. Composite map. A map at an appropriate scale which superimposes the proposed Section 23 activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that any areas that should be avoided, including buffers. Description of impact A description of the impact management objectives, including Section 24 management objectives including management statements, identifying the impacts and risks that management statements. need to be avoided, managed and mitigated as identified through the environmental impact assessment process for all phases of the development including planning and design, pre-construction activities, construction activities, rehabilitation of the environment after construction and where applicable post closure; and where relevant, operation activities. Impacts to be mitigated in their - Section 24.4 respective phases. Impact management outcomes. A description and identification of impact management outcomes Section 25 required for the aspects contemplated in paragraph. Impact management actions. A description of proposed impact management actions, identifying Section 26 the manner in which the impact management objectives and outcomes be achieved, and must, where applicable, include actions to avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation;

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BAR requirement as per the BAR requirements as per the 2014 NEMA Regulations (GNR. Reference in the report DMR template 982), as amended comply with any prescribed environmental management standards or practices; comply with any applicable provisions of the Act regarding closure, where applicable comply with any provisions of the Act regarding financial provisions for rehabilitation, where applicable. Financial provision. - Section 27. Mechanism for monitoring The method of monitoring the implementation of the impact Section 28. compliance with and management actions. performance assessment against the environmental management programme and reporting thereon. - The frequency of monitoring the implementation of the impact Section 28 management actions. - An indication of the persons who will be responsible for the implementation of the impact management actions. - The time periods within which the impact management actions must be implemented. - The mechanism for monitoring compliance with the impact management actions. - A program for reporting on compliance, taking into account the requirements as prescribed by the Regulations. Environmental Awareness Plan. An environmental awareness plan describing the manner in which Section 29. the applicant intends to inform his or her employees of any environmental risk which may result from their work; and risks must be dealt with in order to avoid pollution or the degradation of the environment. Specific information required by Any specific information that may be required by the competent Section 30. the competent authority. authority. Undertaking. - Section 31.

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NEED AND DESIRABILITY OF THE PROJECT This Chapter aims to provide an overview of the need and desirability of the proposed project with the strategic context of national development policy and planning, broader societal needs and regional and local planning, as well as the NEMA principles and sustainable development.

BACKGROUND The Department of Environmental Affairs (DEA) (currently known was the Department of Environmental Forestry and Fisheries (DEFF) guideline on need and desirability (GNR 891, 20 October 2014) notes that while addressing the growth of the national economy through the implementation of various national policies and strategies, it is also essential that these policies take cognisance of strategic concerns such as climate change, food security, as well as the sustainability in supply of natural resources and the status of our ecosystem services. Thus, the overarching framework for considering the need and desirability of development in general is taken at the policy level through the identification and promotion of activities / industries / developments required by civil society as a whole. The DEA guideline further notes that at a project level (as part of an EIA process), the need and desirability of the project should take into consideration the content of regional and local plans, frameworks and strategies. In light of the above, this section aims to provide an overview of the need and desirability of the proposed project by firstly, highlighting mining processing operations in the South African context and, secondly, how this industry is aligned with the strategic context of national development policy and planning, broader societal needs and regional and local planning, as appropriate.

NATIONAL POLICY AND PLANNING FRAMEWORK This section aims to provide an overview of the regional and local policy and planning context relating to the proposed project.

NATIONAL DEVELOPMENT PLAN 2030 The NDP 2030 provides the context for all growth in South Africa. The NDP provides a broad strategic framework, setting out an overarching approach to confronting poverty and inequality through the promotion of development, based on the six focused and interlinked priorities. One of the key priorities is “faster and more inclusive economic growth”. In order to transform the economy and create sustainable expansion for job creation, an average economic growth exceeding 5% per annum is required. The NDP sets out that transforming the economy also requires changing patterns of ownership and control. It is also acknowledged that environmental challenges are in conflict with some of these development initiatives. As such, it is emphasised that there is also a need to: • protect the natural environment; • enhance the resilience of people and the economy to climate change; • reduce carbon emissions in line with international commitments; • make significant strides toward becoming a zero-waste economy; and • reduce greenhouse gas emissions and improve energy efficiency.

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NEW GROWTH PATH The NGP (2011) reflects the commitment of Government to prioritise employment creation in all economic policies and sets out the key drivers and sectors for employment which will be the focus of Government. The sectors identified for prioritisation include infrastructure, agriculture, mining, manufacturing, tourism and the green economy.

REGIONAL AND LOCAL POLICY AND PLANNING FRAMEWORK This section aims to provide an overview of the regional and local policy and planning context relating to the proposed project.

North West The North West Provincial Spatial Development Framework (PSDF) sets out the key spatial challenges faced by the Province and the proposed spatial policies, which have been formulated to address these challenges. As such, it supports the spatial development vision to achieve the North West Development Plan 2030. Five strategic objectives have been identified to provide foundation for spatial development strategies in North West. These objectives are outlined below: • strategic objective 1: Focus development on regional spatial development initiatives, development corridors, development zones and nodes; • strategic objective 2: Protect biodiversity, water and agricultural resources; • strategic objective 3: Promote Infrastructure Investment; • strategic objective 4: Support economic development and job creation guiding the spatial development pattern of North West; and • strategic objective 5: Balance urbanisation and the development of rural areas within North West. To achieve high growth scenarios and strategic objectives above, seven development mechanisms were identified. These include land use planning and management, settlement planning, economic development, infrastructure investment, human resources development, facilitative governance and industrialisation. These mechanisms will ensure that the province enjoys high growth by shifting from social needs-based policy to infrastructure and economic growth-based policies.

Bojanala Integrated Development Plan and Spatial Development Framework The Bojanala Platinum District Municipality Integrated Development Plan is the principle strategic instrument guiding all planning, management, investment and development within the province in order to provide best solutions towards sustainable development. The vision of the Bojanala Platinum District Municipality Integrated Development Plan (IDP) (2017 to 2021) is to provide a model of cooperative governance for effective and efficient service delivery in partnership with local municipality and all stakeholders.

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The IDP aims to realize the NDP, the North West PSDP by identifying the following priority issues and challenges within the district: • water and sanitation; • roads and storm water; • electricity; • land and housing; • economic development; • institutional development; • municipality healthy; and • social services. Economic opportunities abound in mining and agriculture and can be exploited further when skills of the people are in line with economic and technological needs.

Rustenburg Local Municipality The Rustenburg Local Municipality Integrated Development Plan is the principle strategic instrument guiding all planning, management, investment and development within the province in order to provide best solutions towards sustainable development. The Rustenburg Local Municipality’s IDP (2017 – 2022) identifies strategic focus areas it has identified as the cornerstones of a successful and thriving council within the developed Master Plan 2040, and which form the foundation of its Five-year Integrated Development Plan. The approved master plan has 5 goals which reads as follows: • city of vibrant and diversified economy; • city of identity; • city of smart liveable homes; • city of excellence in Education and sport; and • city of sustainable resources management

The IDP identifies agriculture, mining, manufacturing, utilities, trade, transport, finance, community and personal services, general government services and tourism as sectors that contributes to local economic development.

North West Development Corporation Strategic Plan 2015 - 2020 The vision of the strategic plan is to ensure that the North West province becomes the cornerstone of sustainable economic development and job creation. This would be achieved through the province’s contribution to economic growth through sustained focus on agriculture, culture and tourism through villages, townships and small dorpies.

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CONSISTENCY WITH POLICY AND PLANNING CONTEXT The previous sections have considered the policy and planning context at national, regional and local level, which are relevant to the proposed project. As highlighted above, there is a drive from national and provincial Governments to stimulate development and grow the economy of South Africa with a strong focus on job creation in all sectors. Industry and agriculture have been identified as drivers of economic growth and job creation and are furthermore considered particularly important in the North West provincial economy. The proposed project is considered to be consistent with and in support of the broad national policy framework for the development of the mining industry in South Africa. At the regional level, the proposed project will allow for the creation of short-term employment during construction and sustainable continuation of the current employment opportunities which is aligned with the objectives of the North West PSDF and the vision of the Bojanala Platinum Spatial Development Framework (SDF). It is therefore deemed consistent with the North West PSDF, the Bojanala Platinum SDF and the North West Development Corporation Strategic Plan.

CONSISTENCY WITH NEMA PRINCIPLES The national environmental management principles contained in NEMA serve as a guide for the interpretation, administration and implementation of NEMA and the EIA Regulations. In order to demonstrate consistency with the NEMA principles, a discussion of how these principles are taken into account during the BA process is provided in Table 5-1 below.

TABLE 5-1: CONSIDERATION OF THE NEMA PRINCIPLES IN RELATION TO THE PROPOSED PROJECT

National Environmental Management Principles Comment (2) Environmental management must place people and their Mining has long been one of the key drivers of economic needs at the forefront of its concern, and serve their physical, growth and employment in South Africa. The EIA process psychological, developmental, cultural and social interests identifies the needs and interests of potentially affected equitably. parties and attempts to address issues and concerns raised through the course of the study. (3) Development must be socially, environmentally and Government has set development goals aimed at reducing economically sustainable. poverty, unemployment and inequality. The New Growth Path identifies the mining value chain as one of the seven key economic sectors for job creation. Mining is promoted in the national, regional and local policy and planning frameworks; thus, the proposed project aims to find acceptable environmental management strategies for that promotes sustainable development during processing operations. (4)(a) Sustainable development requires the consideration of all The BA process considers resultant social, economic, relevant factors including the following: biophysical impacts through the implementation of the (i) That the disturbance of ecosystems and loss of biological proposed project’s activities. Measures to avoid, minimise diversity are avoided, or, where they cannot be altogether and/or remedy potential pollution that may occur as a result avoided, are minimised and remedied; of the Project are included in this report. (ii) that pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied; (iii) that the disturbance of landscapes and sites that constitute the nation’s cultural heritage is avoided, or where it cannot be altogether avoided, is minimised and remedied; (iv) that waste is avoided, or where it cannot be altogether avoided, minimised and re-used or recycled where possible and otherwise disposed of in a responsible manner;

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National Environmental Management Principles Comment (v) that the use and exploitation of non-renewable natural resources is responsible and equitable, and takes into account the consequences of the depletion of the resource; (vi) that the development, use and exploitation of renewable resources and the ecosystems of which they are part do not exceed the level beyond which their integrity is jeopardised; (4)(a)(vii) that a risk-averse and cautious approach is applied, Assumptions, uncertainties and limitations associated with which takes into account the limits of current knowledge about the compilation of this BAR is included in Section 14. the consequences of decisions and actions; and Compliance with the various legislative requirements is presented in this BAR. (4)(a)(viii) that negative impacts on the environment and on The BA process considers and assesses the resultant social, people’s environmental rights be anticipated and prevented, and economic and biophysical impacts of the project. The EMPr where they cannot be altogether prevented, are minimised and provide the recommended management measures to remedied. mitigate the significance of identified impacts. (4)(b) Environmental management must be integrated, The BA process that is being followed recognises that all acknowledging that all elements of the environment are linked elements of the environment are linked and interrelated. and interrelated, and it must take into account the effects of DMRE, as the decision-making authority, will be responsible decisions on all aspects of the environment and all people in the for taking all aspects of the environment, including whether environment by pursuing the selection of the best practicable or not the potential impacts of the project would unfairly environmental option. discriminate against any person, into consideration when making a decision regarding the proposed project. (4)(c) Environmental justice must be pursued so that adverse environmental impacts shall not be distributed in such a manner as to unfairly discriminate against any person, particularly vulnerable and disadvantaged persons. (4)(d) Equitable access to environmental resources, benefits and The Proposed project is within a disturbed footprint of the services to meet basic human needs and ensure human well- existing Smelter Complex and will not limit access to being must be pursued and special measures may be taken to environmental resources that meet basic human needs. ensure access thereto by categories of persons disadvantaged by unfair discrimination. (4)(e) Responsibility for the environmental health and safety The applicant is committed to comply with environmental consequences of a policy, programme, project, product, process, health and safety obligations for their current operations. service or activity exists throughout its life cycle. (4)(f) The participation of all interested and affected parties in The public participation process has been undertaken in environmental governance must be promoted, and all people accordance with the requirements of the EIA Regulations must have the opportunity to develop the understanding, skills 2014, as amended. and capacity necessary for achieving equitable and effective participation, and participation by vulnerable and disadvantaged persons must be ensured. (4)(g) Decisions must take into account the interests, needs and The Basic Assessment process will take into the account the values of all interested and affected parties, and this includes interests, needs and values of all I&APs, through the recognizing all forms of knowledge, including traditional and submission of comments on the proposed project. Thus, the ordinary knowledge. decision-makers will have all the necessary information before them on which to base an informed decision. (4)(h) Community wellbeing and empowerment must be The BAR prepared for the proposed project will be placed on promoted through environmental education, the raising of the SLR data free portal for communities to review and environmental awareness, the sharing of knowledge and comment. A5 flyers which will provide an overview of the experience and other appropriate means. proposed project including the link to the SLR website and SLR data-free website where the BAR can be accessed were distributed to the communities. (4)(i) The social, economic and environmental impacts of The BAR considers identified potential social, economic, activities, including disadvantages and benefits, must be biophysical impacts of the project in an integrated manner.

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National Environmental Management Principles Comment considered, assessed and evaluated, and decisions must be The significance of these impacts has been assessed as part of appropriate in the light of such consideration and assessment. the BA process (4)(j) The right of workers to refuse work that is harmful to human Impala would be required to comply with the requirements health or the environment and to be informed of dangers must of the Occupational Health and Safety Act. Existing be respected and protected. Environmental Awareness Plan for the Smelter Complex will be adhered to during construction and operation. (4)(k) Decisions must be taken in an open and transparent The public consultation process is being undertaken in manner, and access to information must be provided in accordance with the requirements of the EIA Regulations accordance with the law. 2014 (as amended) and will allow for the distribution of the BAR for public review and comment. This information will be provided in an open and transparent manner. (4)(l) There must be intergovernmental co-ordination and The public participation process for the proposed project harmonisation of policies, legislation and actions relating to the provides an opportunity for the organs of state to provide environment. comment on the proposed project and address any potential conflicts between policies or other developmental proposals administered by them that may be in conflict with the proposed project before decision-making. (4)(m) Actual or potential conflicts of interest between organs of It is not anticipated that the proposed project would result in state should be resolved through conflict resolution procedures. any conflicts between organs of state. (4)(n) Global and international responsibilities relating to the It is not anticipated that the proposed project will environment must be discharged in the national interest. compromise any of South Africa’s international commitments. DMRE, as the decision-making authority, will be responsible for taking cognisance of any international obligations that could have an influence on the proposed project. (4)(o) The environment is held in public trust for the people, the The BA process considers and assesses the identified beneficial use of environmental resources must serve the public potential social, economic, biophysical impacts of the interest and the environment must be protected as the people’s proposed project common heritage. (4)(p) The costs of remedying pollution, environmental Impala will be responsible for the implementation of the degradation and consequent adverse health effects and of measures that will be included in the EMPr preventing, controlling or minimizing further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment. (4)(q) The vital role of women and youth in environment The public participation process for the proposed project has management and development must be recognised and their full been and will continue to be inclusive of women and the participation therein must be promoted. youth. (4)(r) Sensitive, vulnerable, highly dynamic or stressed The project area falls within a concrete lined plant, it follows ecosystems, such as coastal shores, estuaries, wetlands and that there are no sensitive ecosystems within the planned similar systems require specific attention in management and project footprint. planning procedures, especially where they are subject to significant human resource usage and development pressure.

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ECOLOGICAL SUSTAINABLE DEVELOPMENT AND USE OF NATURAL RESOURCES The project area is within an already disturbed concrete lined area, it follows that no vegetation and valuable soil resources will be damaged as the result of the increase in the flash drying capacity.

PROMOTING JUSTIFIABLE ECONOMIC AND SOCIAL DEVELOPMENT Community/society priorities are officially expressed through public documents including the provincial growth and development strategy and spatial development framework documents. Although provincial growth and development plans mostly focus on municipal priorities over a five-year cycle, they do provide some insight and guidance in terms of future planning for the municipalities. Spatial Development Frameworks (SDFs) which usually have a longer life cycle aim to guide and facilitate the implementation of Integrated Development Plans (IDPs) for the municipality. The vision of the North West Provincial Growth and Development Plan and SDF is to eliminate income poverty, reduce inequality and unemployment rate by creating an enabling environment for sustainable employment, economic growth and infrastructure development. The local municipal IDP identifies mining, agriculture, construction and infrastructure and tourism as sectors to be prioritised for driving economic growth and reducing unemployment. The proposed increase in the flash dryer capacity will allow for the creation of short-term employment during construction and sustainable continuation of the current employment opportunities. Negative project-related socio-economic impacts including inward migration, which could place additional pressure on housing and municipal services, are not expected to occur. The economic benefits associated with these projects have previously been accounted for i.e. when the processing operations within the Smelter complex were commissioned, therefore there is no material increase expected with respect to economic benefits.

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MOTIVATION FOR THE PREFERRED SITE, ACTIVITIES AND TECHNOLOGY ALTERNATIVES This section provides a motivation for the preferred site, activities and technology alternatives relative to the proposed project.

No feasible alternatives exist for the proposed project and as such this section is not applicable. Refer to Section 7.1 for further detail.

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FULL DESCRIPTION OF THE PROCESS FOLLOWED TO REACH THE PROPOSED PREFERRED ALTERNATIVES WITHIN THE SITE This chapter describes the alternatives considered for the project and summarises the process being followed to reach the preferred alternatives.

DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED

SITE ALTERNATIVE The development footprint was determined by the location of the existing flash dryer at the Smelter Complex. It follows that no site alternatives were considered due to this fixed position.

TECHNOLOGY ALTERNATIVES The upgrade of the flash dryer feed circuit will enable both dryers (existing and new) to be fed simultaneously via the existing circuit, while addressing inconsistent feed challenges inherent to the current feed system. The installation of a filter plant unlocks water recovery potential currently lost through evaporation within the spray drying circuit, while improving coal unit consumption by offsetting a portion of the throughput from the least efficient spray drying units, by means of complete utilisation of available flash dryer capacity. It will also provide relief in terms of production pressure on the spray dryer installations, thereby facilitating more regular maintenance. In addition, the second flash dryer will be designed to include the improved burner and fluidised bed hot gas generator design, with a more effective combustion circuit which reduces diesel consumption during start-up and stand-by (care-taker) operating modes. It is for these technical benefits that no technology alternatives were considered.

ACTIVITY ALTERNATIVE The project is within an existing Smelter Complex and as such it is compatible with the current land use. Therefore, no activity alternatives were considered.

THE “NO-GO” ALTERNATIVE The “no-go” alternative would mean that the inconsistent feed challenges inherent to the current feed system will continue, the production pressure will not be relieved and regular maintenance will not be facilitated. In addition, benefits associated with reduced water losses and reduced carbon emissions will also not be realised. The “no-go” option would not allow the optimisation of the current feed system.

DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED This section describes the public participation process undertaken during the BAR process. The public participation process was undertaken in accordance with the requirements of Chapter 6 of Regulations 982 of 4 December 2014 (EIA Regulations), as amended. In addition to this, consideration was also given to the public participation guideline in terms of the NEMA (2017).

PUBLIC PARTICIPATION PROCESS UNDERTAKEN A public participation process was undertaken to inform the BA process. A record of the public participation process undertaken is outlined in Table 7-1 below. The purpose of the public participation process was to notify landowners, land users and other key stakeholders of the proposed project and to provide them with opportunity to raise any initial issues or concerns regarding the proposed project.

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TABLE 7-1: PUBLIC PARTICIPATION PROCESS UNDERTAKEN AS PART OF THE BAR

Step Detail Pre-application Phase DMR Pre-application Pre-application meeting was held with the DMRE via Microsoft Teams/Skype on 18 September 2020. The meeting purpose of this meeting was: • to provide information pertaining to the project; • to outline the motivation and alternatives considered; • to provide an overview of the environmental process relevant to the project; • to provide an overview of the existing status of the environment; • to outline and obtain input on the potential biophysical, cultural and socio-economic impacts; and • to outline and obtain input on the planned public participation process. A copy of the pre-application meeting minutes is included in Appendix C. Environmental Authorisation Application Phase Environmental Submission of this NEMA environmental authorisation application to the DMRE. A copy of the application is authorisation included in Appendix C. application submission Notification of commenting authorities and I&APs undertaken to date Desktop social scan The identification of I&APs was achieved by undertaking a desktop social scan. This consisted of an update to the existing I&AP database and verification of I&APs’ and authority (competent and commenting) details. Land claims The Department of Rural Development and Land Reform (DRDLR) (Land Claims Commissioner) in North West commissioner has be contacted to confirm if there were any land claims on Portion 2 of the farm Beerfontein 263 JQ. The consultation Land Claims Commissioner has confirmed that no land claims have been lodged on Portion 2 of the farm Beerfontein 263 JQ. Refer to Appendix C for a copy of correspondence with the land claims commissioner. Focussed Meetings An initial focussed meeting was held with the Mine Community Leadership Engagement Forum from the with the Traditional communities surrounding the Impala operations and the Royal Bafokeng Nation (RBN)/ Royal Bafokeng Authority and Administration (RBA) on 21 October 2020. The purpose of the initial focus meeting was: Community Leaders • to provide information pertaining to the proposed project; • to outline the motivation and alternatives considered for the proposed project; • to provide an overview of the environmental authorisation process relevant to the project; • to provide an overview of the existing status of the environment; • to outline and obtain input on the potential biophysical, cultural and socio-economic impacts; and • to provide information on how I&APs and commenting authorities can have input into the environmental assessment process.

Initial focussed meeting was held with the Royal Bafokeng Nation (RBN)) on 20 November 2020. The purpose of the focus meeting was: • to provide information pertaining to the proposed project; • to outline the motivation and alternatives considered for the proposed project; • to provide an overview of the environmental authorisation process relevant to the project; • to provide an overview of the existing status of the environment; • to outline and obtain input on the potential biophysical, cultural and socio-economic impacts; and • to provide information on how I&APs and commenting authorities can have input into the environmental assessment process.

A focussed feedback meeting with the Mine Community Leadership Engagement Forum was held on 01 December 2020. The purpose of the meeting was: • to provide information pertaining to the proposed project; • to outline the motivation and alternatives considered for the proposed project; • to provide a summary of the impacts findings;

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Step Detail • to provide feedback to issues and concerns raised during the initial focussed meeting held on 29 October 2020; and • to record any additional comments and concerns raised.

A focussed feedback meeting with the North West Provincial Department of Environment, Conservation and Tourism (DEDECT) was held on 04 December 2020. The purpose of the meeting was: • to provide an overview of the proposed project; • to provide an overview of the environmental assessment process that will be undertaken for the proposed project; • to provide an overview on the existing status of the bio-physical, cultural and socio-economic environment; • to provide an overview outline on potential bio-physical, cultural and socio-economic impacts identified for the proposed project; • to outline and obtain input on the planned public participation process; • to obtain input and confirmation of the competent authority for the proposed project; and • to record any issues and concerns raised. Minutes of the focussed meetings are included in Appendix C. Background A BID (English and Setswana) was compiled by SLR. The BID provided: Information • information about the proposed project; Document (BID) • information about the baseline environment; distribution • information about the environmental assessment process (BA Process); • information pertaining to potential biophysical, cultural and socio-economic impacts; and • information on how I&APs and commenting authorities can have input into the environmental assessment process.

A registration and response form were attached to the BID, which provided I&APs and commenting authorities with an opportunity to register and submit comments on the proposed project. The BID was distributed electronically (email) to commenting authorities and I&APs registered on the project database. Copies of the BID were also made available on the SLR website (at https://slrconsulting.com/za/slr- documents/) and the data-free website (at slrpublicdocs.datafree.co ). Emails and text messages containing a link to the SLR website and SLR data-free website, was also sent to all I&APs on the project database.

A copy of the BID including proof of distribution is included in Appendix C. Distribution of flyers SLR prepared 600 A5 flyers which provided an overview of the proposed project including the link to the SLR website and SLR data-free website where the BID could be accessed to. These flyers were distributed by a local supplier appointed by SLR at the following locations (the locations were identified based on the advice received from the RBN and Community Leadership) on the 17th of February 2021: • Main entrance to Ga-Luka • Ga-Luka Clinic • Kelekitso Early Learning Centre • Mogono Community Hall • Royal Bafokeng Enterprise Development Offices • Royal Bafokeng Nation Civic Centre • Royal Bafokeng Library • Bafokeng Plaza • Lefaragatlha Community Hall • Lefaragatlhe Global Garage • Bobuantshwa Primary School C34 • Rustenburg Local Municipality Office A copy of the flyer and proof of distribution is included in Appendix C.

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Step Detail Placement of site Laminated site notices were placed by a local supplier appointed by SLR at the following locations (the notices locations were identified based on the advice received from the RBN and Community Leadership) on the 17th of February 2021 • Main entrance to Ga-Luka • Ga-Luka Clinic • Kelekitso Early Learning Centre • Mogono Community Hall • Royal Bafokeng Enterprise Development Offices • Royal Bafokeng Nation Civic Centre • Royal Bafokeng Library Copies of the site notices, photographic proof and a map illustrating the location of the site notice placements is included in Appendix C. Placement of Block advertisements were placed in local newspapers in the Rustenburg Herald and the Platinum Weekly newspaper on the 23rd of October and 30th of October 2020. The newspaper advertisement contained information on advertisements the nature of the activity, the application process, as well as details of the EAP, and details on how to register as an I&AP and provide comment. In addition to this an advertisement has also been placed in the Daily Sun. Refer to Appendix C for copies of the advertisement. Planned Public Participation Public review and The BAR will be distributed for a 30-day comment period in order to provide I&APs and commenting commenting authorities with an opportunity to comment on any aspect of the proposed project and the findings of the authority review of environmental assessment process. BAR. Full copies of the BAR and the Non-technical summaries will be made available on the SLR website (at https://slrconsulting.com/za/slr-documents/) and the SLR data-free website (at slrpublicdocs.datafree.co ). The Non-technical Summaries will also be emailed to I&APs and commenting authorities registered on the project database. In addition, text messages which contain a link to the SLR website and the SLR data-free website, will be sent to all I&APs on the database. Distribution of flyers SLR will prepare A5 flyers which will provide an overview of the proposed project including the link to the SLR website and SLR data-free website where the BAR can be accessed. Placement of posters SLR will prepare posters which will be placed in areas where the site notices were erected. The posters will provide an overview and findings of the proposed project. The poster will also include the links to the SLR website and the SLR data-free website where the BAR and Non-technical Summaries can be accessed. I&AP Notification of The notification of the competent authorities decision will be communicated via text messages and email to the DMRE decision all I&APs registered on the database. Submission of the BAR to the DMRE for decision making purposes Submission of BAR to The BAR will be updated to include all comment received during the public review and commenting period. the DMRE This updated report will be made available to the DMRE for decision making purposes.

Impala Platinum Limited Basic Assessment Report and Environmental Management Programme for the proposed increase of the flash dryer capacity and 710.09003.00140 associated feed circuit modifications at the Impala Rustenburg Smelter Complex March 2021

SUMMARY OF ISSUES RAISED BY I&APS A record of the issues and concerns raised to date have been included in Table 7-2 below.

TABLE 7-2: SUMMARY OF ISSUES RAISED BY I&APS

Councillor Mekgoe X 29 October 2020 Please make the presentation The presentation was made available to all the community leaders. Not applicable. at the Mine available to us as the community Community leaders. Leadership Engagement Forum Focus Meeting

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted Councillor Mekgoe X 29 October 2020 What are the timeframes for The implementation is dependent on the receipt of a decision from the DMRE Not applicable. at the Mine implementation of the project? and the Bojanala District Municipality as the competent authorities for the Community Proposed project. This may take up to a year from the time the Proposed Leadership project is initiated to the time a decision is received. Engagement Forum Focus Meeting Councillor Mekgoe X 29 October 2020 We are the landowners. Why are In accordance with legislation, the decision-making authorities for this project Not applicable. at the Mine landowners only required to include the DMRE and the Bojanala District Municipality. In terms of Community provide comments to a project? Regulation 39(2) of the NEMA EIA Regulations (2014), as amended, it is not a Leadership Our approval or content to the legal requirement for landowner consent to be obtained for mining related Engagement project should be requested. activities. Input from landowners as part of this process is however important Forum Focus and as such the focussed Mine Community Leadership Engagement Forum Meeting Meeting was arranged. Comments and concerns raised during the focussed Mine Community Leadership Engagement Forum Meeting, have been recorded and included in this BAR that will be made available to the decision- making authorities. Councillor Ntikelane X 29 October 2020 Does this project only focus on This BA process focusses on both phases. It is anticipated that phase 1 Not applicable. at the Mine Phase 1? We want to know if the (installation of the new flash dryer) of the Proposed project will be established Community project phases will run first, following which phase 2 (upgrades to the existing feed circuit) will Leadership simultaneously. Will a separate commence. Engagement EIA be done for phase 2? Forum Focus Meeting Councillor Ntikelane X 29 October 2020 When will responses come back A feedback meeting was held on 1 December 2020. Appendix C at the Mine to us, we would like to have a (Stakeholder Community feedback meeting. Engagement) Leadership

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted Engagement Forum Focus Meeting Councillor Rantho X 29 October 2020 Signing the attendance register at the Mine does not mean that we support Community the project, please bring back Leadership responses. Engagement Forum Focus Meeting Procurement Issues Councillor Mekgoe X 29 October 2020 Is SLR going to partner with the A Request for Quotation for distribution of public participation materials was Section 7.2.1 at the Mine local Small, Medium and Micro issued by SLR on 15 January 2021. As part of the process, a local supplier was Community Enterprises to arrange for the identified and appointed to undertake the scope of work. Leadership distribution of flyers? Engagement Forum Focus Meeting Councillor Mekgoe X 01 December The Mine Community 2020 Feedback Leadership Engagement Forum Meeting with the (MCLEF) would like clarity on Mine Community how SLR will partner with a local Leadership Small, Medium and Micro Engagement Enterprises to print and Forum distribute flyers.

Forum Municipality need to also be involved in the distribution of the PPP material. Please amend the presentation to reflect this Councillor Masilo X 29 October 2020 Three years back, a company SLR has been selected as a supplier due to its extensive experience in Not applicable at the Mine from Joburg was stopped from managing complex environmental authorisation processes for mining Community making a presentation. Why has projects as well as their history of the Impala operations and their knowledge Leadership Impala appointed another of the stakeholder structures. Engagement company from Johannesburg? Forum Focus There is lack of transformation at

Meeting Impala, why are local companies not considered? Why are big companies awarded millions of tenders? Councillor Mekgoe X 01 December Why is Impala always awarding 2020 Feedback tenders to Consultants in Meeting with the Johannesburg? The Rustenburg Mine Community community is being Leadership undermined, and the MCLEF Engagement cannot be subjected to this Forum discrimination. Are these consultants transferring

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted knowledge and skills to the local companies? Councillor Xhinela X 01 December Rustenburg is a subregion to the 2020 Feedback Bojanala Platinum District Meeting with the Municipality. Impala is not Mine Community focusing on the Bojanala Leadership Platinum District Municipality Engagement area when seeking to appoint Forum environmental consultants. Johannesburg is not within the North West province. Impala should first extend the tender opportunities available to the North West province before requesting quotations from other provinces. Councillor Mekgoe X 01 December Please verify when the tender 2020 Feedback was issued as the CLEF never Meeting with the received information regarding Mine Community this tender. The leadership is Leadership willing to help Impala to share Engagement tenders. Forum The presentation and the Impala procurement database imply that we don’t have qualified local companies to provide environmental services to

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted Impala. This statement is incorrect and must be removed as we have a qualified people in Rustenburg. Councillor Mputle X 29 October 2020 Give us statistics on the Impala Platinum is the biggest employer in the North West Province and the Not applicable. at the Mine employment created by Impala. breakdown of the information from provincial to local level is presented Community below. Leadership • North West Province – 14 676 Engagement • Bojanala District Municipality – 9637 Forum Focus • Rustenburg Local Municipality – 8087 Meeting • Royal Bafokeng Nation - 2823 Councillor Mekgoe X 01 December The employment statistics are Not applicable

2020 Feedback not clear, therefore making it Meeting with the difficult for the CLEF to Mine Community understand. The presentation Leadership should be given to the CLEF in Engagement time for them to understand the Forum contents thereof. Councillor Lefyedi X 01 December The procurement system for Impala is currently applying to install the second flash dryer which will be used Not applicable 2020 Feedback third party mining companies to treat concentrate from other mining companies. Impala does not have an Meeting with the (i.e. Marula) delivering toll input on the procurement system of other mining companies based on the Mine Community materials to the Smelter following: Leadership Complex should make provision • Mining companies have their own mine leadership that require them to Engagement to extent opportunities to the extend opportunities to the local communities. Forum communities surrounding the • Mining companies are governed by different procurement systems and Smelter Complex or create a requirements. platform where they can be

engaged by the community

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted Meeting with the tender was not made available identify subcontracting activities that could be extended to the community in Mine Community to the community. future. Leadership Engagement Forum Councillor Mekgoe X 01 December The leadership notes that all the Your feedback has been noted. Not applicable 2020 Feedback concerns raised in the initial Meeting with the meeting have been accurately Mine Community recorded and addressed by Leadership Impala. Engagement Forum Councillor Mekgoe X 01 December What is the budget for the The detail design and engineering must be completed in order to finalise the Not applicable 2020 Feedback proposed Phase 1 and Phase 2 of budget requirements. The development of the engineering packages will also Meeting with the the project? Please provide the be a deliverable from the design phase, which will be subjected to inclusive Mine Community MCLEF with the budget and tender processes as per Impala’s procurement procedures. Leadership outline the subcontracting Engagement opportunities available upfront Forum prior to appointment of a contractor. Councillor Lefyedi X 01 December What can be done to reprimand It is a requirement in terms of NEMA for the EAP to be objective and sign a Section 17 2020 Feedback the consultants for misleading declaration of independence when undertaking an environmental Meeting with the us? Also, what will happen if assessment process. Therefore, SLR has signed the declaration of Mine Community Impala does not fulfil any of its independence in relation to the accuracy of the information presented in this Leadership commitments? BAR. In addition, the conduct of EAPs is regulated with Environmental Engagement Assessment Practitioners Association of South Africa (EAPASA). Forum

Impala is required by law to adhere to the commitments contained in the EMPr as part of the environmental authorisation to be granted by the DMR. Failure to adhere to these conditions would lead to non-compliance. Councillor Masilo X 29 October 2020 Impala leadership needs to The community leadership was informed that Impala is capacitating MCLEF Not applicable at the Mine come and be part of the forum. with Heads of the Departments to enable comprehensive responses on issues Community raised. Additionally, the Chief Executive will attend two MCLEF meetings in Leadership March and September 2021. Engagement Forum Focus Meeting Noise concerns Councillor Ntikelane X 29 October 2020 According to your presentation, The following findings from the BAR in terms of increase in disturbing noise Section 7.4.1.9 at the Mine the potential impacts with levels are noted: and Appendix D Community respect to noise are low. • the closest community to the Smelter complex is the Ga-Luka community, (Detailed Leadership However, we must have control located approximately 2 km north of the proposed project footprint; Impact Engagement measures because the project • the noise contributions associated with the proposed project are unlikely Assessment). Forum Focus results in additional air to be noticeable in the context of the existing noise environment within the Meeting emissions. Smelter Complex; and • in the unlikely event of noise related compliant, this needs to be investigated by Impala.

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted Potential air and related health impact concerns Councillor Ntikelane X 29 October 2020 According to your presentation, Criteria pollutants are considered those pollutants most commonly found in Section 7.7 and at the Mine the potential impacts with the atmosphere, that have proven detrimental health effects when inhaled 7.8 Community respect to air are low. However, and are regulated by ambient air quality criteria. These generally include Appendix E (Air Leadership we must have control measures PM10, PM2.5, SO2, NO2, CO and O3. Main emission sources within and around Quality Study) Engagement because the project results in Impala include dust fallout and gaseous emissions. Dust fallout represents the Forum Focus additional air emissions in coarse fraction >10m of total suspended particles that can visually be seen Meeting relation to existing emissions in by third parties. PM has the potential to contribute to health concerns as

the area. particulate matter with an aerodynamic diameter of less than 10m (PM10) Kgosana Rapebana X 29 October 2020 My main concern is air pollution, and an aerodynamic diameter of less than 2.5m (PM2.5) is the finer inhalable at the Mine we are currently experiencing air fraction. Gaseous emissions (gaseous material released) include SO2, NOx and Community pollution and the project will CO and also contributes to health concerns. Leadership result to an increase in air Engagement pollution in the area. Please Current baseline monitoring indicates that the PM2.5 and PM10 monitored Forum Focus make sure that you monitor air data shows exceedances of the annual and 24-hour NAAQS. The SO2 Meeting pollution. monitored data (specific to the Smelter Complex) shows no exceedances of the annual, daily and hourly NAAQS. The operations off-site dustfall rates Kgosana Mothibe X 29 October 2020 Our women are miscarrying, sampled complies in terms of the NDCR. It is however important to note that at the Mine reports like these will give us Impala is not the only contributor to emission sources. Surrounding Community answers. Currently, the way the industries/mines and community activities such as farming activities, Leadership project is presented, it’s to help domestic fires, vehicle exhaust emissions and dust entrained by vehicles also Engagement Impala make profit. As a contribute to PM and dust fallout concentrations. Impala has submitted an Forum Focus community we will never get a offset plan to DEFF to assist in addressing current air quality related matters. Meeting cent from it. As part of the proposed project, an independent air quality specialist was Councillor Mputle X 29 October 2020 Studies should be done to appointed to determine the contribution that the proposed project will have at the Mine determine the health impacts on existing ambient concentrations. The scope of the study was confined to Community from the Impala operations. the quantification of impacts due to exposures via the inhalation pathway Leadership

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted Engagement only. Simulated ambient pollutant concentrations and fallout rates were Forum Focus compared to NAAQS, health risk screening levels, and NDCR, nuisance Meeting screening levels. Compliance was assessed, and a health risk/nuisance Kgosana Montsho X 29 October 2020 The clinics are full. This is screening completed.

at the Mine because of emissions from the The results of the Air Quality Study indicate that on its own and within the Community Impala plant. Has impala taken context of the existing Smelter Complex the proposed project does not result Leadership time to understand why people in any exceedances of the NAAQS and the NDCR at AQSRS. When the Engagement are sick? Life expectancy is proposed project is considered in the context of the existing Impala Forum Focus questionable, and we don’t have operations exceedances of the future PM2.5 and current PM10 and NOx in Meeting facts. Studies should be done to terms of the NAAQS limits with mitigation was noted. It is however important help us understand this, instead to note that these exceedances are as a result of existing on-site exceedances studies are only done to help and as such the proposed project operations resulted in a minimal increase in Impala kill us. simulated ambient pollutant concentrations and dust fall rates in comparison to what was simulated for existing operations.

A copy of the Air Quality Study is included in Appendix E. Councillor Mekgoe x 01 December What is the air quality The air quality monitoring programme is conducted to monitor air emissions Appendix D 2020 Feedback monitoring programme? associated with Impala operations and community activities. Impala will (Detailed Meeting with the What new technologies that can consider sharing the monitoring results at the MCLEF in future. Impact Mine Community be used to manage air pollution, As part of the air quality impact assessment undertaken, three impact Assessment) Leadership which form part of Scenario 3 assessment scenarios were analysed to understand the impact of the Appendix E (Air Engagement (Modelling scenario that takes proposed project on the current air quality baseline (Scenario 1), the impact Quality Study) Forum into account emissions of the smelter operations including the Proposed project on the current air associated with the proposed quality (Scenario 2) and the cumulative impact of the proposed project, project, smelter operations and smelter operations and all impala operations (Scenario 3). The findings from all impala operations in the area) this assessment indicate that there is a possibility of exceedances of air

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted as per the finding of the air emission limits under Scenario 3 in 10 years’ time, provided that all impala quality assessment undertaken. operations are run simultaneously. The new technologies mentioned with Councillor Masilo x 01 December Can the MCLEF be provided with Scenario 3 refer to any technology that could be identified in future to Appendix D 2020 Feedback more information on the air improve the state of air quality. (Detailed Meeting with the quality legislation (i.e. the Impact Mine Community National Air Quality Standard Assessment) Leadership and Dust Control Regulations) as Appendix E (Air Engagement well as the findings of the Air Quality Study) Forum Quality Study, which states that the project will not affect the community from an air quality perspective in writing. Groundwater Councillor Mputle X 29 October 2020 We can’t use boreholes; the Impala has an existing groundwater monitoring programme that is utilised to Section 7.4.1.7 at the Mine water is salty. Some animals are monitoring the quality and quantity of groundwater within the Impala surface Community dying. use area. Boreholes within the vicinity of the Smelter Complex are only Leadership utilised for monitoring purposes. Any groundwater complaints need to be Engagement directly to Impala and site-specific investigations can be undertaken. Forum Focus Meeting Councillor Lefyedi X 01 December My main concern is The following findings from the BAR in terms contamination of groundwater Appendix D 2020 Feedback groundwater. The information resources are noted: (Detailed Meeting with the provided in the presentation • the proposed project is located within the existing Smelter Complex on an Impact Mine Community states that the project will not impermeable concrete layer; Assessment) Leadership affect our groundwater supply.

Forum an alternative water supply. This is a commitment in the EMPr. Councillor Masilo X 01 December In terms of water, will the The issue raised makes reference to provision of clean water which should be Appendix D 2020 Feedback project not result in addressed by the municipality and the Rand Water Board. (Detailed Meeting with the contamination of our water? If The installation of the flash dryer will not result in significant impact to the Impact Mine Community there are any problems with our localised surface water resources and groundwater resources. Assessment) Leadership water supply, the alternatives Engagement will be rivers Forum Socio-Economic Councillor Nameng X 29 October 2020 This consultation process is a tick Your comment has been noted. Public participation is a legal requirement in Not applicable. at the Mine box exercise for the application terms of the NEMA. The purpose of the public participation process is to allow Community to be lodged in terms of Section for the community to be provided with an opportunity to provide input and Leadership 102. Somebody will benefit, the comment on the proposed project which will enable the authority to make an Engagement status quo must change. informed decision.

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted Councillor Mekgoe X 29 October 2020 The project will result in at the Mine additional traffic that will have Community an impact on communities, Leadership however, external companies Engagement will benefit. If there is no proper Forum Focus plan from Impala on how the Meeting communities will benefit, this community will protest until economic spin-offs are derived from the project. Councillor Lefiedi X 29 October 2020 How will the project affect us The main negative impacts associated with the proposed project that have a Appendix D at the Mine negatively? potential to influence communities include traffic safety impacts and air (Detailed Community quality impacts. Impact Leadership Assessment) Engagement In terms of traffic, the proposed project will result in additional vehicles along Forum Focus the Lefaragatlha road and Luka Road and as such a traffic specialist has been Meeting appointed to determine the impact that this will have on the community. In this regard, the proposed project will not influence the current condition of the roads however, there is a potential for traffic related accidents associated with the movement of trucks. It is however important to note the increase in the number of trucks as a result of the proposed project is considered to be insignificant in the context of the existing Impala transport network along the Lefaragatlha road and Luka Road. As part of the proposed project, the specialist has however recommended additional geometric upgrades along the Lefaragatlha road and Luka Roads given that these roads run through communities. These geometric upgrades aim at reducing the probability of accidents occurring.

Impala operations exceedances of the future PM2.5 and current PM10 and NOx in terms of the NAAQS limits with mitigation was noted. It is however important to note that these exceedances are as a result of existing on-site exceedances and as such the proposed project operations resulted in a minimal increase in simulated ambient pollutant concentrations and dust fall rates in comparison to what was simulated for existing operations. Councillor Ntikelane 29 October 2020 I also don’t agree with the socio- The toll materials transported to the Smelter Complex comes from third party Appendix D at the Mine economic ratings, there will be mining companies. As a result, Impala does not have an input on third party (Detailed Community additional trucks resulting in procurement process including appointment of contractors. It is also Impact Leadership socio-economic benefits. We important to note that the increase in the flash drying capacity does not Assessment) Engagement already have socio-economic increase the production capacity within the Smelter Complex. As a result, the Forum Focus challenges in the area, please proposed project will not result in an increase in the matte that would be Meeting address the impacts and include transported to the Impala Refinery. The proposed project will result in job control measures. opportunities, however due to the nature of the project, the proposed project is not anticipated to generate significant job opportunities. Limited job opportunities will be available during the construction phase of the project and will be limited to a period of 2.5 years. Once an appointed contractor has been appointed to undertake the establishment of the proposed project components, employment opportunities will be extended to communities (where possible). Councillor Mputle X 29 October 2020 Somebody will see the The proposed project is located within an existing Smelter Complex and will Appendix D at the Mine newspaper and assume that result in limited short-term employment opportunities through usage of (Detailed

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted Community there are job opportunities. This registered community vendors during construction, therefore negative Impact Leadership will make people protest, how project-related socio-economic impacts including inward migration, which Assessment) Engagement are we going to resolve that? could place additional pressure on housing and municipal services, are not Forum Focus Where do these diseases come expected to occur. Meeting from? This is not included in the presentation. Councillor Nameng X 29 October 2020 The farm presented belonged to Impala Platinum has a surface signed lease agreement with the RBA which Not applicable. at the Mine my grandfather, but not a single covers Portion 2 of Beerfontein 263 JQ farm. The Title Deed for the said farm Community person benefited from Impala is T373/1883 BP allocated for use. Any claims need to be discussed with the Leadership even by a million or half a RBA. Engagement million. Impala should have Forum Focus compassion. The DRDLR Land Claims Commissioner in North West has been contacted to Meeting confirm if there were any land claims on Portion 2 of the farm Beerfontein 263 JQ. The Land Claims Commissioner has confirmed that no land claims have been lodged on Portion 2 of the farm Beerfontein 263 JQ. Traffic Councillor Mekgoe X 29 October 2020 I disagree with the concept that The installation of the second flash dryer and the upgrades to the existing feed Appendix D at the Mine the project does not encroach circuit project activities will not encroach on community related activities as (Detailed Community on existing communities, an they are confined to the Smelter Complex and are not near any communities Impact Leadership increase in traffic is an and will therefore not influence day to day community activities. The Assessment) Engagement encroachment on communities. proposed project will result in additional vehicles along the Lefaragatlha road Forum Focus and Luka Road and as such a traffic specialist has been appointed to Meeting determine the impact that this will have on the community. In this regard, the proposed project will not influence the current condition of the roads however, there is a potential for traffic related accidents associated with the movement of trucks. It is however important to note the increase in the number of trucks as a result of the proposed project is considered to be insignificant in the context of the existing Impala transport network along the

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted Lefaragatlha road and Luka Road. As part of the proposed project, the specialist has however recommended additional geometric upgrades along the Lefaragatlha road and Luka Roads given that these roads run through communities. These geometric upgrades aim at reducing the probability of accidents occurring. Reotshepile X 19 November With regards to the Traffic The focus of the Traffic Study is the route that will be utilised by trucks Section 7.4.3.3 Tlhapane 2020 at the Royal Study, will there be transporting material to and from site. The proposed project specific and Appendix F Bafokeng Nation transportation of toll material transport route is the Lefaragatlha Road that runs through the Bobuampja (Traffic Study) Virtual Meeting from area A to area B outside the and Lefaragatlha communities. Should this road not be used, an alternative project study area? road would be considered which runs through Phokeng community (Luka road) Where will the toll material be Impala treats third-party toll material from Marula and other mines coming from? transported to the Smelter Complex for processing via trucks., Impala receives third-party toll material from the Impala Group, specifically Marula, Two Rivers Mine, and the Zimplats Mine. Authorities Ellis Thebe X 04 December Please advise if SLR has a project The proposed project schedule is available and takes into consideration Not applicable 2020 Focussed schedule that takes into account Regulation 3(3) of the 2014 NEMA EIA Regulations (as amended). Group Meeting Regulation 3(3) of the EIA with the North Regulations, which states that West Provincial Public Participation Process Department of cannot be undertaken between Environment, the closure period (i.e. from 15 Conservation and December 2020 and 5 January Tourism 2021)? Victor Loate X 04 December What is the sub-category 4.1 Section 3.2 2020 Focussed for?

emissions licence. Therefore,

wording that a new process within the existing facility is being introduced needs to be clearly stated. In addition, the project would require an application for a new air emissions licence. Portia Krisjan X 04 December The issue as to whether a new air Comment noted. Not applicable 2020 Focussed emissions licence needs to be Group Meeting applied for is outside the with the North mandate of the department and West Provincial will be dealt with by Bojanala

Victor Loate X 04 December Did SLR raise the query regarding The DEDECT has been confirmed that the DMRE is the competent authority 2020 Focussed the competent authority with for the proposed project. A copy of the corresponded received from DEDECT Group Meeting the DMRE during the pre- is included in Appendix C. with the North application meeting and what West Provincial was the DMRE’s view on this. Department of Environment, Conservation and Tourism Portia Krisjan X 04 December We will response once the Comment noted. Not applicable 2020 Focussed necessary information has been Group Meeting provided. with the North West Provincial Department of

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph if those reference in who this report must be where the consulted issues and or were in responses were fact incorporated consulted stage. Hoping this will not provoke us any further. Keorapetse X 21 March 2021 Please assist on the right The stakeholder has been registered on the database and will be informed of Appendix C Matlhoko Email procedure on registering to be the progress of the proposed project throughout the environmental (Stakeholder part of the project as per poster assessment process. Engagement) ad

Impala Platinum Limited

ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH PROPOSED PROJECT AND THE ALTERNATIVES An understanding of the environmental and social context and sensitivity within which the proposed project is located is important in understanding the potential impacts of the project. This section provides a description of the attributes of the biophysical, cultural and socio-economic receiving environment of the project area.

BASELINE BIOPHYSICAL ENVIRONMENT AFFECTED BY THE PROPOSED ACTIVITY

INTRODUCTION AND LINK TO IMPACT Mineral resources can be sterilised and/or lost through the placement of infrastructure and activities in close proximity to resources, by preventing access to potential mining areas/ Geological processes can also influence soil forms and the potential for palaeontological resources.

A baseline situational analysis is described below in order to understand: • the potential for sterilisation of mineral reserves; and • the potential for geological lineaments such as faults and dykes. Faults, dykes and other lineaments can act as preferential flow paths of groundwater, which can influence both the dispersion of potential pollution plumes and the inflow of water into mine workings.

DATA SOURCES Information in this section was sourced from the Impala Groundwater Model for the TSF extension (Metago, 2011) and the Impala EIA and EMPr Consolidation Report (SLR, 2012).

DESCRIPTION Impala is situated on the Bushveld Igneous Complex (BIC). The BIC is an intrusive igneous body, extending approximately 400 km from east to west and 250 km from north to south. There are four main limbs to the BIC, aptly named according to its location, namely, Northern, Southern, Eastern and Western Limbs. The Western Limb of the BIC underlies Impala mine. Two lithologically distinct units that are mainly intrusive into the Transvaal Supergroup make up the BIC: a lower sequence of layered mafic and ultramafic rocks, known as the Rustenburg Layered suite (RLS), and an overlying unit of granites, known as the Lebowa Granite Suite. The RLS comprises five stratigraphic zones representing the sequential fractional crystallization that accompanied the cooling of the magmatic body. The Impala Surface Use Area at Impala is located on the Pyramid Gabbro Norite, Mathalagame Norite-Anorthosite, mixed granite and granophyte and Bierkraal Magnetite Gabbro.

CONCLUSION Where infrastructure is placed within close proximity to mineable ore there is the possibility that sterilization can occur. This possibility is greatest in the west of the surface use area where the ore bodies occur close to surface. The project footprint of the second flash dryer is within an existing Impala Smelting Complex, given that the project area falls within the concrete lined Smelting Complex, it follows that the proposed surface infrastructure will not sterilise any mineral reserves.

Impala Platinum Limited

INTRODUCTION AND LINK TO IMPACT Changes to topography through the development of the proposed project may impact on surface water drainage, visual aspects and the safety of both people and animals. To understand the basis of these potential impacts, a baseline situational analysis is described below.

DATA SOURCES Information in this section was sourced from the original EMP Report (SRK, 1997) and the Impala EIA and EMPr Consolidation Report (SLR, 2012).

DESCRIPTION The surface use area is characterised by gentle undulating plains at an altitude of approximately 1 130 meters above mean sea level, approximately 10 km north-east of the northern most section of the Magaliesberg Range. Peaks in this section of the Magalies rise to heights of between 1 400 and 1 500 metres above mean sea level (mamsl). The northern areas of the surface use area are undisturbed and therefore regarded as being in its natural state. The southern area of the Impala Surface Use Area has been disturbed due to the presence of mining activities, infrastructure and communities.

No natural topography is associated with the proposed project area, as the site is located within the disturbed footprint of the Smelter Complex.

CONCLUSION Mining activities, infrastructure and communities have the potential to alter the topography and the natural state of undisturbed areas. An alteration of the natural topography has the potential to impact both animals and people. The proposed activities do not pose safety risks to third parties and animals as the footprint of the project is within an access controlled secured Smelter Complex.

INTRODUCTION AND LINK TO IMPACT Climate can influence the potential for environmental impacts and related mine design. Specific issues are listed below: • rainfall could influence erosion, evaporation, vegetation growth, rehabilitation planning, dust suppression, and surface water management planning; • temperature could influence air dispersion through impacts on atmospheric stability and mixing layers, vegetation growth, and evaporation which could influence rehabilitation planning; and • wind could influence erosion, the dispersion of potential atmospheric pollutants, and rehabilitation planning.

To understand the basis of these potential impacts, a baseline situational analysis is described below.

Impala Platinum Limited

DATA SOURCES Information in this section was sourced from the Impala EIA and EMPr Consolidation Report (SLR, 2012) and the air Quality Specialist Report for the proposed flash dryer (Airshed, 2020).

DESCRIPTION Regional climate The project area falls within the Highveld Climatic Zone. Of the mean annual precipitation, 85% falls during summer thunderstorms. The thunderstorms generally occur every 3 to 4 days in summer and are of short duration and high intensity. Temperatures in this climatic zone are generally mild, but low minima can be experienced in winter due to clear night skies. Frost characteristically occurs in the winter months. Generally, winds are light, but south-westerly winds associated with thunderstorms are typically strong and gusty.

Rainfall Rainfall data obtained from the Impala Lebone ambient station is provided in Figure 7-1, for the period 2017 to 2020. Notably, a significant portion (six months) of the 2019 year did not receive rainfall measurements, thus the total measured rainfall is likely less than the actual rainfall for 2019. No rainfall measurements are available for the last five months of 2020; thus, the total measured rainfall is likely less than what the actual annual rainfall for 2020 will be. Total average annual rainfall from January 2017 to December 2018 is 2 704 mm. The rainfall for 2017 and 2018 was 3 316 mm, and 2 271 mm, respectively. Rainfall in this area occurs mostly during the summer months although it also rains during spring and autumn while the winter months are dry.

FIGURE 8: MONTHLY RAINFALL (LEBONE AMBIENT STATION MEASURED DATA, JAN 2017 - JUL 2020) (AIRSHED, 2020)

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Wind The wind roses comprise 16 spokes, which represent the directions from which winds blew during a specific period. The colours used in the wind roses below, reflect the different categories of wind speeds; the orange area, for example, representing winds between 4 and 5 m/s. The dotted circles provide information regarding the frequency of occurrence of wind speed and direction categories. The frequency with which calms occurred, i.e. periods during which the wind speed was below 1m/s are also indicated. The period wind field and diurnal variability in the wind field are shown in Figure 9, while the seasonal variations are shown in Figure 10. The wind field is dominated by winds from the southerly sectors. Calm conditions occurred 0.39% of the time, with the average wind speed over the period of 1.35m/s. Wind from the east and east-south-east having higher speeds were greater during the day with a lower frequency of calm conditions (0.21% during the day) than during the night (0.57% during the night). Daytime shows dominant easterly and east-south-easterly components to the wind field and during the night winds these winds decrease, and the south-south-westerly winds dominate. Strong winds in excess of 4 m/s occurred most frequently during spring followed by summer. Calm conditions occurred most frequently during the winter months. Although it may appear on the wind roses that the northerly winds are not being measured correctly, it was determined that the frequency of these winds are 0.3%. Assuming all the missing data is for northerly sector the maximum amount of time that the winds may originate from the north is 1.4%.

FIGURE 9: PERIOD, DAY- AND NIGHT-TIME WIND ROSES (AERMET PROCESSED WRF DATA, (AERMET PROCESSED MEASURED DATA, JAN 2019 TO DECEMBER 2020) (AIRSHED, 2020)

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FIGURE 10: SEASONAL WIND ROSES (AERMET PROCESSED WRF DATA, (AERMET PROCESSED MEASURED DATA, JAN 2019 TO DECEMBER 2020) (AIRSHED, 2020)

Ambient Temperature Monthly mean, maximum and minimum temperatures for the period January 2019 to December 2020 are given in Table 7-5. Temperatures ranged between 1°C and 38°C. The highest temperatures occurred in October and the lowest in July. During the day, temperatures increase to reach maximum at around 14:00 in the afternoon. Ambient air temperature decreases to reach a minimum at around 06:00 i.e. just before sunrise.

TABLE 7-3: MONTHLY TEMPERATURE SUMMARY (AERMET PROCESSED MEASURED DATA, JAN 2019 TO DECEMBER 2020) (AIRSHED, 2020) Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Hourly Minimum (°C) 16 14 15 8 6 2 1 5 4 11 15 12

Monthly Average (°C) 25 24 25 19 17 13 13 18 20 25 25 24

Hourly Maximum (°C) 36 36 36 32 28 27 28 30 33 38 36 37

CONCLUSION The project area is characterised by rainy seasons with heavy thunderstorms that last for short periods at a time. High rainfall levels can increase the erosion potential and the formation of erosion gullies. The mixing of layers resulting in the formation of temperature inversion and the presence of cloud cover limits the dispersion of pollutants into the atmosphere. Wind significantly affects the amount of material that is suspended from exposed surface to the atmosphere. The wind speed determines the distance of downward transport as well as the rate of dilution of pollutants in the atmosphere. Where wind speeds increase above 5m/s the possibility of dust dispersion increases and this will require consideration from a planning and management perspective.

Impala Platinum Limited

However, in general, the wind field is dominated by winds from the south, while average wind speeds were captured at 1.35m/s. These climatic aspects need to be taken into consideration during rehabilitation and surface water management planning.

INTRODUCTION AND LINK TO IMPACT Soils are an important component of most ecosystems. As an ecological driver, soil is the medium in which most vegetation grows and a range of vertebrates and invertebrates exist. In the context of mining operations, soil is even more significant if one considers that mining is a temporary land use where after rehabilitation (using soil) is the key to re-establishing post closure land capability that will support post closure land uses.

Mining projects have the potential to damage soil resources through physical loss of soil and/or the contamination of soils, thereby impacting on the soils’ ability to sustain natural vegetation and altering land capability. Contamination of soils may in turn contribute to the contamination of surface and groundwater resources. Loss of the topsoil resource reduces chances of successful rehabilitation and restoration. To understand the basis of these potential impacts, a baseline situational analysis is described below.

DATA SOURCES Information In this section was sourced from the soil and land capability study (ESS, 2010) and the Impala EIA and EMPr Consolidation Report (SLR, 2012)

DESCRIPTION Soil forms Numerous soil forms that were identified within the Impala surface use area. These include Hutton, Shortlands and Valsrivier, Mispah, Mayo and Milkwood, Sterkspruit and Swartland, Arcadia, Sepane, Rensburg, Kroonstad and Katspruit, Glenrosa, Westleigh, Witbank and Outcrop. The soil form within the project area is the Calcic Vertisols. These are predominantly highly structured, relatively shallow soils with a high clay content which allows for high water retention. Soils are therefore not highly erodible but are susceptible to compaction. The proposed project is located within the existing Smelter Complex and as such the natural integrity of soils forms located within this area have already been influenced by existing activities within the Smelter Complex.

Land capability The current land capability within the Impala Surface Use Area is a mixture of grazing, wilderness and wetland with a small percentage consisting of arable potential. The proposed project is located within the existing Smelter Complex and as such the natural soil forms are located within the proposed project footprint and as such any natural related land capability has already been influenced.

CONCLUSION Soil forms found within the surface use area are predominately highly structured, relatively shallow soils with a high clay content which allows for high water retention. These soil forms are therefore not highly erodible but are susceptible to compaction as a result of water retention and swelling clays. Poor drainage capacity of these soil forms reduces the dry production potential as well as the irrigation potential. These soil forms are therefore difficult to work and have a limited utilization potential.

Impala Platinum Limited

Given that the proposed project is located within the concrete lined Smelter Complex, soil resources and related land capability have already been influenced by existing activities within the Smelter Complex.

INTRODUCTION AND LINK TO IMPACT In the broadest sense, biodiversity provides value for ecosystem functionality, aesthetic, spiritual, cultural, and recreational reasons. The known value of biodiversity and ecosystems is as follows: • soil formation and fertility maintenance; • primary production through photosynthesis, as the supportive foundation for all life; • provision of food and fuel; • provision of shelter and building materials; • regulation of water flows and water quality; • regulation and purification of atmospheric gases; • moderation of climate and weather; • control of pests and diseases; and • maintenance of genetic resources.

Mining activities and infrastructure have the potential to result in the loss of vegetation, habitat and related ecosystem functionality through physical disturbance and/or contamination of soil and/or water resources. To understand the basis of these potential impacts, a baseline situational analysis is described below.

DATA SOURCE Information In this section was sourced from the Biodiversity Study of the Impala-Bafokeng Mining Complex (North West University, 2010), Vegetation of South Africa, Lesotho and Swaziland. South African National Biodiversity Institute (Mucina, L., & Rutherford, 2006) and the Impala EIA and EMPr Consolidation Report (SLR, 2012).

DESCRIPTION - FLORA The Savannah Biome is the predominant biome of the region. Within this biome there are various vegetation types, four of which occur within the Impala Surface Use Area. The four vegetation types are the Zeerust Thornveld, Marikana Thornveld, Central Sandy Bushveld and Norite Koppies Bushveld vegetation type. In general, the area surrounding the Smelter Complex is located within the Marikana Thornveld vegetation type which is characterised by undulating plains and lowland hills. The Marikana Thornveld vegetation type occurs on the plains between Rustenburg and Pretoria through the Marikana area. This is more open Vachelia karoo woodland and occurs in valleys, undulating plains and lowland hills. The important tree species that occur in this vegetation type include Vachelia nilotica, Vachelia tortillis subsp. heteracantha, Ziziphus mucronata, Celtis Africana and more. Tall shrubs that can be found in the area include Rhus pyroides var. pyroides, Grewia flava, and Diospyros lycioides subsp. guerkei. Grasses that are found in the area include Elionurus muticus, Fingerhutia africana, Heteropogon contortus and Melinis nerviglumis. Some of the herb species found here are Hermannia depressa, Ledebouria revoluta and Ipomoea obscura.

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It is important to note that as part of the proposed project, consideration was given to provincial and national biodiversity sensitivity databases (NPAES 2008, SACAD 2017, SAPAD 2017, Mining and Biodiversity Guidelines 2013, North West Biodiversity Sector Plan 2015, IBA’s 2015 and the NEM:BA). The project footprint does not fall within any sensitive habitats identified in these databases.

Natural vegetation within the proposed project areas has been removed due to existing activities within the Smelter Complex.

DESCRIPTION – FAUNA The most common mammals occurring within the Impala Surface Use Area are the Multi-Mammate Mouse, the Namaqua Rock Mouse and the Rock Dassie. Mammals are predominantly located in areas such as rocky outcrops, dense mattered vegetation, moist marshy habitats etc, where favourable habitats exist. Five red-listed bird species were identified within the Impala Surface Use Area, these includes Mycteria ibis, Phoenicopterus roseus, Sagittarius serpentarius, Falco biarmicus and Mirafra cheniana. Protected bird species in terms of the Nature Conservation Ordinance include Phalacrocorax lucidus, Phalacrocorax africanus, Streptopelia semitorquata, Streptopelia capicola, Streptopelia senegalensis, Corvus albus, Passer melanurus and Quelea quelea. The proposed project area within the existing Smelter Complex is unlikely to provide a habitat that would support faunal species.

CONCLUSION The vegetation type surrounding the project area and Smelter Complex is that of the Marikana Thornveld. The natural vegetation of this area has, however, been degraded by community activities and current approved mining operations. Given that the proposed project will be located within the concrete lined Smelter Complex, there are no flora and fauna that are located within the planned project footprint.

INTRODUCTION AND LINK TO IMPACT Surface water resources include drainage lines and paths of preferential flow of stormwater runoff. Mine related activities have the potential to alter the drainage of surface water through the establishment of infrastructure and/or result in the contamination of the surface water resources through seepage and/or spillage of process materials, non-mineralised (general and hazardous) and mineralised wastes. To understand the basis of these potential impacts, a baseline situational analysis is described below.

DATA SOURCES Information In this section was sourced from the Impala EIA and EMPr Consolidation Report (SLR, 2012) and the Catchment of South Africa- quaternary data (Department of Water and Sanitation, 2011).

DESCRIPTION Catchments within the Impala Surface Use Area within the context of South Africa The Impala Surface Use Area is located within the three quaternary catchments of the Lower Vaal Water Management Area (Figure 11). These catchments are listed below: • quaternary catchment A22F, with a catchment area of 1 688 km2 and the mean annual runoff of 16 million cubic meters;

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• quaternary catchment A22H, with a catchment area of 579 km2; and the mean annual runoff of 23.7 million cubic meters; and • quaternary catchment A22J, with a catchment area of 591 km2; and the mean annual runoff of 17.1 million cubic meters.

Local Hydrology The proposed project area is located approximately 1.17 kilometres from the non-perennial Leragane stream. located to the west of the project area (which is largely modified) and approximately 230 m from a tributary of the Leragane stream, located to the east of the project area (see Figure 11), which falls in quaternary catchment A22F.

Wetland features within the project area The proposed project is located within the Smelter Complex and approximately 200 m away from the channelled valley-bottom wetland (refer to Figure 12) in terms of the NFEPA. It is however important to note that the site sensitivity of NFEPA wetlands is based on a database and has not been verified with field observations. In terms of the proposed project, these NFEPA wetlands have most likely been influenced by existing Impala mining activities and surrounding community activities.

Surface water use Although many of the communities within and downstream of the Impala Surface Use Area have access to reticulated water supply, it is possible that surface water is abstracted from water courses for domestic purposes and livestock watering. In addition, water in the Bospoort and Vaalkop Dams is used for domestic, recreation and agricultural purposes while water at the Rock Wall Dam is used for livestock watering. Due to the non-perennial nature of the Leragane stream and its associated tributary, there is no third party reliance of these watercourses.

Surface water quality No recent water quality data is available for the Leragane stream and its associated tributary as there has been no recent flow. It should be noted that there have been known discharges from the Omnia operation that is situated upstream of Impala in the Leragane stream catchment.

CONCLUSION Mining infrastructure has the potential to influence contributions of runoff to the catchment and related natural drainage patterns. In addition to this, mining activities and infrastructure present contamination sources that has the potential to pollute surface water resources when water is available in the non-perennial drainage lines. The project presents infrastructure that has the potential to influence contributions of runoff to the catchment and presents a potential for the contamination of surface water resources. These however need to be considered within the context of the non-perennial nature of the streams and the existing alteration of natural drainage patterns as result of existing Impala Smelter activities.

10000 15000 20000 25000 30000

Robega Legend

Maille /" Towns / Villages -2815000 -2815000 Dams ± Rivers Rasimone Impala Surface Use Area Impala Smelter Complex Quaternary Catchments

a A22D

a g A22F n

a A22H

g n A22J o

e p

n a

l a

o g

Mogono M a r e L -2820000 -2820000

Rockwall Dam

A22J A22F Ga Luka

Serutube -2825000 -2825000 Mafika

Impala Smelter Complex Setlhokwe 0 1,5 3 Kilometers

Scale: 1:79 000 @ A3

Projection:Transverse Mercator Datum: Hartebeeshoek, Lo 27 Freedom Park Impala Platinum Limited Phokeng Kana Hex -2830000 A22H -2830000 Lenatong

a Figure 11

e L Bobuantswa Catchment Map A22D Ga-kgale

SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) 467-0945 Fax: +27 (11) 467-0978 Jabula 710.09003.00140 2020/11/16 10000 15000 20000 25000 30000 Meters 2020/11/16 es c esour R SLR Consulting (Africa) (Pty)Consulting SLR Ltd Scale:1:16000 @A3 ater ater Datum: Hartebeeshoek, Lo 27 ImpalaPlatinum Limited Projection:TransverseMercator W 0 300 600 P O Box 1596, Cramerview, 2060, O 1596, Cramerview,Africa Box P South Tel: +27 (11) 467-0945 +27 Tel: (11)+27 Fax: (11) 467-0978 CLASS D: Largely Modified Flat Valleyhead seep Valleyhead Unchannelled valley-bottomwetland Channelled valley-bottom wetland Project Footprint ImpalaSmelter Complex ImpalaSurface Area Use Rivers Railway Line Power Line Roads e c a f 710.09003.00140 ur

NFEPA Rivers NFEPA NFEPA Wetlands NFEPA Legend Figure12 S -2825000 SUser Impala Hospital NES/AirbusDS, USDA, AeroGRID,USGS, IGN, andthe GI 20000 20000 ProjectFootprint Community Source: GeoEye,Esri, Maxar, Earthstar Geographics, C

Ga Luka

e L

Phokeng

± -2825000 Impala Platinum Limited

INTRODUCTION AND LINK TO IMPACT Groundwater is a valuable resource and is defined as water which is located beneath the ground surface in soil/rock pore spaces and in the fractures of lithological formations. Activities such as the handling and storage of hazardous materials and handling and storage of bulk concentrate materials and non-mineralised wastes have the potential to result in the loss of groundwater resources, both to the environment and third-party users, through pollution. To understand the basis of these potential impacts, a baseline situational analysis is described below.

DATA SOURCES Information In this section was sourced from the Impala EIA and EMPr for the Smelter Complex (SLR, 2007), the Impala EIA and EMPr Consolidation Report (SLR, 2012) and Annual Water Quality Monitoring Report 2019 (SW & GW) Impala Platinum.

DESCRIPTION Hydrogeology The unweathered and fractured semi-confined bedrock aquifer consists of fractured norites, anorthosites and pyroxenites underlying the upper weathered aquifer. The intact bedrock matrix has a very low matrix hydraulic conductivity and its effective hydraulic conductivity is determined by fractures and mine voids. Groundwater flows through interconnected fracture systems with the potential of rapid vertical groundwater flow from the weathered overburden (and surface water bodies) to greater depths along interconnected conductive zones. The underlying solid and unweathered crystalline rocks are generally characterized by very low porosity and high hydraulic conductivity values if fractures are intersected. Water is generally stored and transmitted in fractures and fissures within a relatively impermeable matrix. Based on the South African Aquifer Classification System (Parsons, 1995), the aquifer underlying the Impala Surface Use Area is generally classified as a minor aquifer system. These zones are likely to be associated with geological features such as the Hex river fault which is associated with significant volumes of poor-quality water. The definition of aquifer systems is as follows (Parsons, 1995): • “a Minor Aquifer System can be fractures of potentially fractured rocks, which do not have a high primary permeability, or other formations of variable permeability. Aquifer extent may be limited and water quality variable. Although these aquifers seldom produce large quantities of water, they are important both for local supplies and in supplying base flow to rivers”.

Groundwater quality and use Groundwater quality is influenced by existing mining operations in the broader area. Boreholes within and surrounding the project area are used for groundwater monitoring purposes. The nearest groundwater sampling point from the Smelter Complex has indicated the highest concentration of sulphuric and phosphoric acid as well as phosphate concentrations. This is as a result of historic phosphoric acid plant operations at Omnia (third party company) which have been decommissioned. The highly elevated phosphate concentrations of this site also suggest a potential contribution of the Omnia (phosphate and gypsum) stockpiles.

CONCLUSION The project footprint is located within a concrete surface, therefore, no interaction with groundwater resources is expected.

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INTRODUCTION AND LINK TO IMPACT Existing sources of emissions in the region and the characterisation of existing ambient pollution concentrations is fundamental to the assessment of cumulative air impacts. A change in ambient air quality can result in a range of impacts which in turn may cause a disturbance and/or health impacts to nearby receptors. To understand the basis of these potential impacts, a baseline situational analysis is described below.

DATA SOURCES Information in this section was sourced from the Air Quality Specialist Report for the Proposed Increase of the Flash Dryer Capacity and Associated Feed Circuit Modifications at the Impala Rustenburg Smelter Complex (Airshed, 2020).

DISCUSSION Potential receptors Air Quality Sensitive Receptors (AQSR) generally include places of residences and areas where members of the public may be affected by air pollution. Sensitive receptors within a 10 km radius of the proposed project area include Ga-Luka to the north, Phokeng to the south west and south, Freedom Park to the south east and Meriting to the south east (Airshed, 2020). For a location of the AQSR refer to Figure 14.

Ambient air quality within the region The current air quality in the area is mostly influenced by mining and processing activities within the Impala Surface Use Area, surrounding operations (mines), farming activities, domestic fires, vehicle exhaust emissions and dust entrained by vehicles. These emission sources vary from activities that generate relatively course airborne particulates (such as dust from paved and unpaved roads, and the mine sites) to fine PM such as that emitted by vehicle exhausts, diesel power generators and processing operations.

Other sources of PM include occasional fires in the residential areas and farming activities. Emissions from unpaved roads constitute a major source of emissions to the atmosphere in South Africa. When a vehicle travels on an unpaved road, the force of the wheel’s road surface is exposed to strong turbulent air shear with the surface. The turbulent wake behind the vehicle continues to act on the road surface after the vehicle has passed. Dust emissions from unpaved roads are a function of vehicle traffic and the silt loading on the roads. Emissions from paved roads are significantly less than those originating from unpaved roads, however they do contribute to the particulate load of the atmosphere.

Particulate emissions occur whenever vehicles travel over a paved surface. The fugitive dust emissions are due to the re-suspension of loose material on the road surface. Emissions generated by wind erosion are dependent on the frequency of disturbance of the erodible surface. Every time that a surface is disturbed e.g. by mining, agriculture and/or grazing activities, its erosion potential is restored. When a vehicle travels on an unpaved road, the force of the wheels on the road surface causes pulverization of surface material. Particles are lifted and dropped from the rolling wheels, and the road surface is exposed to strong turbulent air shear with the surface.

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Ambient air quality sources from Impala The sources of atmospheric emissions during the operational phase associated with the existing Impala operations include: • particulate and gaseous emissions from underground operations, emitted through the ventilation shaft; • particulate emissions from materials handling at the shafts, waste dumps, conveyor transfer points and stockpiles; • particulate emissions from crushers and screens; • particulate emissions from wind erosion at waste dumps, tailings storage facilities and stockpiles; • particulate emissions from vehicle entrainment along the unpaved and paved on-site roads; and • particulate and gaseous emissions from vehicles’ exhaust.

Atmospheric emissions sources for the Proposed project The sources of atmospheric emissions during the construction and operational phase associated with the Proposed project include: • particulate emissions from general Construction; • particulate and gaseous emissions from mobile construction equipment during construction; • particulate and gaseous emissions from the proposed flash dryer, emitted through the baghouse stack; and • particulate emissions from materials handling at conveyor transfer points.

Baseline data - particulate and gaseous emissions

As part of the proposed project ten-minute (sub-hourly) measured data for PM2.5, PM10 and SO2 at the five Impala ambient stations was made available. The data from the four air quality monitoring stations (AQMS) that fall within areas where the NAAQS are applicable for the period 1 January 2016 to 31 July 2020 is discussed in this section. Ambient monitoring data shows:

• exceedances of the annual NAAQS for PM2.5 at Ga-Luka in 2016, 2018, 2019 and 2020; Lebone in 2017 and 2020; and Ratanang in 2018;

• exceedances of the daily PM2.5 NAAQS were recorded at Boschhoek in 2017, 2019 and 2020; Ga-Luka in 2016, 2017, 2018, 2019 and 2020; Lebone in all 2016, 2017, 2018, 2019 and 2020; and Ratanang in all three years that monitoring data was available (2018, 2019 and 2020);

• exceedances of the annual NAAQS for PM10 at Boschhoek in 2019; Ga-Luka in 2016, 2017, 2018, 2019 and 2020; Lebone in 2016, 2017 and 2019; and Ratanang in 2018;

• exceedances of the daily PM10 NAAQS were measured at Boschhoek, Ga-Luka and Lebone in 2016, 2017, 2018, 2019 and 2020; and Ratanang in 2018 and 2019; and

• no exceedances of the annual, daily and hourly NAAQS SO2 at any of the off-site monitoring stations.

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Baseline data - Dust fallout data Dust fallout sampling is being undertaken at Impala for both external (off-site/residential) and internal (on-site) buckets. The network includes at 36 locations (27 non-residential sites and 9 residential sites) in accordance with ASTM D1739 (1970). Dustfall rates at the external sampling sites from January 2016 to June 2020 are summarised in Table 7-4. There was one exceedance of the NDCR limit for residential areas at Platinum Village in November 2018 (it is believed that this sample was contaminated or tampered with). The operations off-site dust fallout rates shown by the sampling complies in terms of the NDCR as there were no exceedances of more than two times per year at a site or for consecutive months at a site.

TABLE 7-4: DUST FALLOUT RATES SUMMARY FOR EXTERNAL BUCKETS (AIRSHED, 2020) Dustfall Rate (NDCR Limit for Residential Areas = 600 mg/m²-day) Period Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Boschhoek Primary

2016 ND ND ND 37 31 17 27 17 10 99 59 74 2017 49 34 60 23 10 30 19 23 31 53 89 83 2018 98 87 44 47 81 24 27 109 198 67 47 116 2019 90 118 26 51 21 53 64 47 87 65 65 37 2020 58 57 102 29 33 33 ------Ga-Luka South 2016 27 31 10 33 18 7 26 24 21 43 54 54 2017 19 13 27 33 32 37 21 31 51 72 39 54 2018 164 122 33 26 34 31 22 41 103 57 39 180 2019 141 89 75 64 37 47 98 97 59 40 144 49 2020 10 44 59 12 46 57 ------Ga-Luka Primary 2016 19 129 155 63 90 97 122 42 52 59 102 133 2017 70 64 134 48 67 41 68 66 121 63 181 ND 2018 86 265 105 23 37 173 68 102 86 51 128 129 2019 108 233 203 196 33 150 543 233 185 133 326 170 2020 26 156 163 40 30 30 ------Ga-Luka North 2016 173 48 148 47 58 21 30 11 175 75 168 59 2017 27 34 133 43 28 46 33 79 155 65 115 95 2018 65 95 182 64 107 27 71 83 228 ND ND 184 2019 24 41 51 27 36 14 97 65 181 194 321 250 2020 ND 67 229 22 76 88 ------Ga-Luka Village Tailings 2016 381 73 35 ND ND ND ND ND ND ND ND ND 2017 ND ND ND ND ND ND ND ND ND ND ND ND 2018 ND ND ND ND ND ND ND ND ND ND ND ND

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Dustfall Rate (NDCR Limit for Residential Areas = 600 mg/m²-day) 2019 ND ND ND 33 26 138 97 104 57 87 126 59 2020 58 64 53 58 26 159 ------Ga-Luka Village Shaft 17 2016 274 36 92 36 42 19 29 23 79 100 72 58 2017 25 23 58 ND 15 22 23 41 80 113 37 105 2018 84 70 57 16 33 22 14 71 93 85 91 40 2019 189 406 79 25 13 31 82 46 81 96 78 121 2020 65 69 175 5 22 45 ------Phokeng Village

2016 ND ND ND 56 24 17 33 11 170 90 109 69 2017 51 39 122 18 25 29 22 32 189 122 75 143 2018 73 32 31 17 38 16 14 37 48 30 24 79 2019 57 77 18 22 12 36 18 46 39 25 32 91 2020 19 15 44 17 38 13 ------Freedom Park 2016 109 35 43 72 19 18 47 45 38 57 82 99

2017 114 175 57 ND 15 7 36 34 ND 66 41 2018 36 61 52 38 31 34 557 49 81 87 68 85 2019 18 69 40 26 37 42 62 68 70 114 270 50 2020 46 93 ND 7 10 16 ------Platinum Village 2016 106 51 24 42 14 21 28 36 21 50 36 59 2017 17 47 28 9 31 31 18 31 40 37 68 41 2018 99 66 39 16 108 101 87 65 39 37 9186* 65 2019 71 47 38 79 32 38 35 7 72 116 60 119 2020 75 42 76 53 20 15 ------* Possible sample contamination/tampering Based on hourly sequential data

CONCLUSION Air quality within the region has been influenced. Monitoring results at Impala indicate that dust fallout from the existing mining operations do not exceed the NDCR limits (apart from one exceedance at the Platinum Village which is believed to be a contaminated or tampered sample). SO2 sampling at Impala shows that there are no exceedances of the NAAQS, however there are exceedances of PM2.5 and PM10. The proposed project has the potential to present additional emission sources and as such the potential impact should be carefully managed to ensure that contributions from the project remain within acceptable limits at potential receptor sites. It is however important to note that the proposed project will act as a substitute for a portion of the spray dryer’s throughput, which will result in the improvement of the PM emissions.

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INTRODUCTION AND LINK TO IMPACT Mining activities and infrastructure have the potential to cause an increase in ambient noise levels in and around the proposed project area. This may cause a disturbance to nearby receptors. Land uses and potential receptor sites including residential areas surrounding the mine have been described in the land use section below. To understand the basis of these impacts, a baseline situational analysis is described below.

DATA SOURCE Information in this section was sourced from the Impala EIA and EMPr Consolidation Report (SLR, 2012) and Environmental Noise Specialist Study for Impala Platinum Ltd Rustenburg (Airshed, 2020).

DESCRIPTION Airshed conducted a noise survey at on 12 May 2016. Survey points were selected with input from Impala, taking into consideration areas of concern. The results of the noise survey generally indicated representative “background” noise levels i.e. noise levels without traffic, community or industrial influences range between 40 and 45 dBA during the day and 35 and 40 dBA during the night. These levels are typical of rural areas. In terms of the Shaft complex, although audible, is masked by traffic noise during the day. It is however more prominent during the night and audible over longer distances. Types of audible sound include general industrial “hum”, reverse or warning hooters and sirens, and the intermittent sound of ore transferred which sounds like falling rock. The closest community to the Smelter Complex is the Ga-Luka community, located approximately 2 km north of the proposed project footprint. The baseline monitoring indicates that noise levels at Ga-Luka are 64.7 dBA (this exceeds the 55dBA limit for rural areas in terms of SANS 10103 during the day and 46.1 dBA (this exceeds the 45dBA limit for rural areas in terms of SANS 10103) during the night. Impala’s contribution to noise levels within most communities varies between 3 dBA and 4 dBA which would not likely result in annoyance.

CONCLUSION In the regional context, contributions to ambient noise as a result of the proposed project will be low. The additional noise generated from the proposed project will be absorbed by the noise emissions from the existing smelter operations. Despite the proposed project not impacting on ambient conditions, further noise mitigation will be achieved through careful design and planning. This will be of particular importance with regards to the increase in traffic volumes and the operational activities associated with the proposed project.

INTRODUCTION AND LINK Mining infrastructure has the potential to alter the landscape character at the proposed project area and surrounding area through the establishment of both temporary and permanent infrastructure. To understand the basis of these potential impacts, a baseline situational analysis is described below.

DATA SOURCE Information in this section was based on Impala EIA and EMPr Consolidation Report (SLR, 2012), site observations and the review of relevant maps. Data collection was sourced from on-site observations and the review of relevant maps.

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DESCRIPTION Landscape character The landscape character of the Impala Surface Use Area is defined by gentle undulating plains, koppies, communities and mining infrastructure. In addition, the following is noted: • most of the surface use area, specifically the southern part consists of various mining infrastructure, services and activities that has been establish between existing communities with isolated koppies located predominately on the eastern boundary of the surface use area; • an extensive network of roads, power lines and railway lines links shafts and open cast areas to the Smelter Complex and the UG2 concentrator; and • the most northern part of the surface use area is mostly undeveloped.

The landscape character of the proposed project area has been influenced by existing infrastructure at the Smelter Complex.

Scenic quality The scenic quality of the visual resource in the central, southern and western areas of the Impala Surface Use Area is moderate to low due to existing mining and community infrastructure. Resources that are considered to have a high scenic value are isolated Koppies to the east and areas that have not been disturbed by any mining or community activities to the east and north.

Given that the project area is located in a disturbed footprint within the Smelter Complex, the scenic value is considered to be very low.

Sensitivity of Visual Resource The highest value visual resource described above is also the most sensitive to changes. In contrast, areas, which are not considered to have a high scenic value, are expected to be the least sensitive to change such as the mining and community areas.

Sense of place The sense of place results from the combined influence of landscape diversity and distinctive features. Given the dominance of the mining and community infrastructure, and the lack of landscape diversity and distinctiveness, the overall sense of place for the central, southern and western areas is considered to be low. A moderate value is placed on the plains to the north of the Impala Surface Use Area because although the area is relatively undisturbed, it is a fairly common landscape with limited diversity. A high value is placed on the hills and koppies in the east of Impala Surface Use Area because this landscape contains a complex yet coherent special dimension with both diversity and distinctiveness. The low sense of place is associated with the proposed project area, due to the presence of existing infrastructure at the Smelter Complex.

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Visual receptors When viewed from the perspective of tourists and community members mining activities could be associated with a sense of disenchantment. People who benefit from Impala (employees, contractors, service providers etc.) may not experience this disenchantment but rather see the mine with a sense of excitement and anticipation. The less sensitive viewer locations are from within the mining areas, including processing operations along roads and railways that service the mines.

CONCLUSION When considering landscape character, scenic quality, visual resource, sense of place and visual receptors, the Impala Surface Use Area includes three distinct areas of three distinct visual value. The koppies and hills in the east have a high visual value. The plains to the north have a moderate visual value. The developed areas to the centre, west and south have a low visual value which indicates that mining and community developments impact on the available visual resources.

The proposed project is located within the existing Smelter Complex and as such the visual value of the project area has already been influenced.

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BASELINE CULTURAL ENVIRONMENT AFFECTED BY THE PROPOSED ACTIVITY

INTRODUCTION AND LINK This section describes the existing status of the heritage and cultural environment that may be affected by the project. Heritage (and cultural) resources include all human-made phenomena and intangible products that are the result of the human mind. Natural, technological or industrial features may also be part of heritage resources as places that have made an outstanding contribution to the cultures, traditions and lifestyles of the people or groups of people of South Africa.

Paleontological resources are fossils, the remains or traces of prehistoric life preserved in the geological (rock stratigraphic) record. They range from the well-known and well publicized (such as dinosaur and mammoth bones) to the more obscure but nevertheless scientifically important fossils (such as palaeobotanical remains, trace fossils, and microfossils). Paleontological resources include the casts or impressions of ancient animals and plants, their trace remains (for example, burrows and trackways), microfossils (for example, fossil pollen, ostracodes, and diatoms), and unmineralised remains (for example, bones of Ice Age mammals). To understand the basis of the potential impacts, a baseline situational analysis is described below.

DATA SOURCE Information in this section was based on Impala EIA and EMPr Consolidation Report (SLR, 2012) and Impala heritage survey and assessment (2011).

DESCRIPTION Impala is situated in the Central Bankeveld of the North-West Province. The Bankeveld as a whole has a rich archaeological heritage dating from the prehistoric and historical (or colonial) periods, which form a record of cultural heritage of most groups living in South Africa. Heritage sites identified within the Impala Surface Use Area include stone age sites, late iron age sites and historical settlements, houses, graveyards and other features.

The palaeontological studies conducted indicated that the surface use areas are situated on underlying igneous rocks of the Precambrian Rustenburg Layered Suite of the Bushveld Igneous Complex and as such palaeontological resources are not associated with this underlying geology it is unlikely that fossils will be affected by the mining activities.

None of the identified heritage resources lies within the project footprint as shown in Figure 13. In addition, the site is located within the disturbed footprint of the Smelter Complex.

CONCLUSION None of the identified heritage resources within the Impala Surface Use Area lies within the project footprint. In addition, the site is located within the disturbed footprint of the Smelter Complex.

15000 20000 25000 Legend Mogono /" Towns / Villages Main Roads -2820000 -2820000 Power Line ± Railway Line Rivers

Dams

Impala Surface Use Area

Impala Smelter Complex Rockwall Dam Heritage Resources (! Historical site (! Stone wall settlement Ga Luka

GY04 (! -2825000 Impala -2825000 Hospital

Impala Smelter Complex

0 1 2 Kilometers

Scale: 1:50 000 @ A3

Projection:Transverse Mercator Datum: Hartebeeshoek, Lo 27 GY03 LIA05 Freedom Park (! (! Impala Platinum Limited LIA04 (! Phokeng

R LIA03 5 6 5 (! Figure 13 -2830000 -2830000

Recorded Heritage Resources Within Lenatong the Impala Surface Use Area

Bobuantswa SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) 467-0945 Fax: +27 (11) 467-0978 Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community 710.09003.00140 2020/11/16 15000 20000 25000 Impala Platinum Limited

BASELINE SOCIO-ECONOMIC ENVIRONMENT AFFECTED BY THE PROPOSED ACTIVITY

INTRODUCTION AND LINK Mining operations have the potential to result in both positive and negative socio-economic impacts. The positive impacts are usually economic in nature with mines contributing directly towards employment, procurement, skills development and taxes on a local, regional and national scale. In addition, mines indirectly contribute to economic growth in the national, local and regional economies by strengthening the national economy and because the increase in the number of income earning people has a multiplying effect on the trade of other goods and services in other sectors.

The negative impacts can be both social and economic in nature. In this regard, mines can cause: • influx of people seeking job opportunities which can lead to increased pressure on basic infrastructure and services (housing, health, sanitation and education), informal settlement development, increased trespassing, increased crime, introduction of diseases and disruption to the existing social structures within communities; and • a change to not only pre-existing land uses, but also the associated social structure and meaning associated with these land uses and way of life. This is particularly relevant in the closure phase when the economic support provided by mines ends, the natural resources that were available to the pre- mining society are reduced, and the social structure that has been transformed to deal with the threats and opportunities associated with mining finds it difficult to readapt.

To understand the basis of these potential impacts, a baseline situational analysis is described below.

DATA SOURCE Information in this section was sourced from FEED 2018/19 Overview of Provincial Revenue and Expenditure, Bojanala 2020/2021 Review IDP, North West Province Integrated Waste Management Plan 2016.

DESCRIPTION North West Province The socio-economic environment in the province can be summarised as follows: • the North West Province has a population of approximately 4 million residents in 2019; • the economic sectors of growth and opportunity in the province should be targeted: agriculture, mining, manufacturing, trade, finance and business services, general government services and construction. • it was estimated that the unemployment rate of the province in 2016 was 32% (this is slightly higher than the current unemployment rate of 29% in South Africa); • the North West Province is the fourth largest provincial contributor to the gross domestic product (GDP) of South Africa. The Province has a GDP of R55 320 per capita and produces 6.7% of South Africa's GDP. Mining, agriculture and manufacturing contribute to the largest portion of provincial output. Tourism is the fourth most important economic sector in the Province; and • nine percent (9%) of the population has tertiary education. Furthermore, only 67% of the total population in the province have secondary education. The district dad a total number of 697 419 households with piped water inside the dwelling and piped water inside the yard. This constitute 63% of the total households. The number of households using electricity in the Province have been on an

Impala Platinum Limited

increase since 1996, the households with electricity connections increased from 57.3% in 1996 to 87.7% in 2016.

Bojanala Platinum District Municipality (BPDM) and Rustenburg Local Municipalities The socio-economic environment at a municipal level can be summarised as follows: • the population of BPDM is estimated to be 1 670 000. This is approximately 44.1% of the total population of the North-West Province. Rustenburg Local Municipality (RLM) is the largest municipality within the district, with a population concentration of approximately 37% of the total population of BPDM. The total number of households within Bojanala Platinum District Municipality increased at an average annual rate of 3.63% from 2006 to 2016, which is higher than the annual increase of 1.97% in the number of households in South Africa; • in 2016, the largest share of population is within the young working age (25-44 years) age category which constitute 36.4% of the total population; • in 2016, the mining sector is the largest within Bojanala Platinum District Municipality accounting for R 63.5 billion or 51.1% of the total Gross Value Added (GVA) in the district municipality's economy. The sector that contributes the second most to the GVA of the Bojanala Platinum District Municipality is the community services sector at 12.7%, followed by the finance sector with 10.4%. The sector that contributes the least to the economy of Bojanala Platinum District Municipality is the agriculture sector with a contribution of 1.06% of the total GVA; • the unemployment rate within the district has been estimated to be 23.2% in 2014; • the area within district can be classified as rural with very low densities that make the provision of basic services very difficult and expensive. It is estimated that the district has the following dwelling types: very formal- 19.24%, formal – 50.05%, informal- 29.45%, traditional- 0.58% and other dwelling types- 0.67%. RLM have high proportional and actual number of households residing in informal dwellings in the district as compared to the other local municipality. Within the RLM, it is estimated that as much as 30% of households are residing in informal dwellings; • from available information, it is estimated that approximately 452 000 of the households in the district have Electricity for lighting and other purposes. RLM accounts for 40.9% of the households with electricity for lighting and other purposes; • the district had a total number of 275 000 households with piped water inside the dwelling and piped water inside the yard. RLM accounts for 29.1% of households with piped water; and • the amount of waste collected by the different municipalities within the BPDM weekly as part of their legal mandate, has been estimated at 314 235 tonnes/annum. The municipalities collect more than half of the domestic and garden waste generated by the population as this collection figure includes for business waste in certain of the municipalities. Of the five local municipalities in the district, RLM provide the greatest percentage waste collection and cleaning services to their communities. There are currently 12 operational landfills within the district (waste sites) identified, 4 sites within the RLM.

CONCLUSION The proposed increase in the flash drying capacity will allow for the creation of short term employment during construction phase and sustainable continuation of the current employment opportunities, therefore negative project-related socio-economic impacts including inward migration, which could place additional pressure on housing and municipal services, are not expected to occur. The economic benefits associated with these projects have previously been accounted for i.e. when the processing operations within the Smelter Complex were commissioned, therefore there is no material increase expected with respect to economic benefits.

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INTRODUCTION AND LINK Mining activities have the potential to affect land uses both within the mine area and in the surrounding areas. This can be caused by physical land transformation and through direct or secondary impacts. The key related potential environmental impacts are pollution of water, air pollution, noise pollution, visual impacts and the influx of job seekers with related social ills. To understand the basis of the potential land use impacts, a baseline situational analysis is described below.

DATA SOURCE Information in this section was sourced from the EIA and EMPr Consolidation Report (SLR, 2012). Additionally, on-site and surrounding land use data was sourced from site observations, a social scan and Windeed undertaken by SLR and the review of topographical maps and satellite imagery as part of the proposed project.

DESCRIPTION Surface and Mineral Rights Impala’s current mining rights and prospecting rights are listed in Table 7-5 below.

TABLE 7-5: MINING / PROSPECTING RIGHTS

Property description Portion number Mining/Prospecting rights Hartebeestspruit 88 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/131MR Goedgedacht 110 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/131MR and 133 MR Doornspruit Annex 109 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/131MR Klein Doornspruit 108 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/131MR and 133MR Toulon 111 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/131MR Vlakfontein 276 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/133MR and 131MR Goedgedacht 114 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/131MR and 133MR Welbekend 117 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/131MR Doornspruit 106 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/133MR Vaalkop 275 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/131MR Reinkoyalskraal 278 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/131MR and 133MR Elandsheuwel 282 JQ Remainder of portion 2 of the farm and Mining rights held by Impala – reference numbers portion 5 NW30/5/1/2/2/131MR

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Property description Portion number Mining/Prospecting rights Wildebeestfontein 274 JQ Whole farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/133MR Kookfontein 265 JQ Portion of portion 2 Mining rights held by Impala – reference numbers NW30/5/1/2/2/133MR Remainder of portion 3 Portion of portion 5 Portion of portion 11 Portion of portion 14 20 Portion of portion 21 22 23 Portion of portion 24 25 12 Mining rights held by Impala – reference numbers NW30/5/1/2/2/132MR Beerfontein 263 JQ Portion 2 Mining rights held by Impala – reference numbers NW30/5/1/2/2/133MR Turfontien 262 JQ Remainder of farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/133MR Uitvalgrond 105 JQ Portion 1, 2 and Remainder of farm Mining rights held by Impala – reference numbers NW30/5/1/2/2/132MR Boschkoppie 104 JQ Portions on remaining extent of the farm Mining rights held by Impala – reference numbers and portion of portion 2 NW30/5/1/2/2/130MR Klipgat 115 JQ Whole farm Impala as the holder of the prospecting right associated with Klipgat 115 JQ has submitted the closure application in relation to this farm. Diepkuil 116 JQ Whole farm RBN as the holder of the prospecting right associated with Diepkuil 116 JQ has submitted the closure application in relation to this farm. Roodekraalspruit 113 JQ Remaining extent of the farm Impala as the holder of the prospecting right associated with Roodekraalspruit 113 JQ has submitted the closure Portion 2 application in relation to this farm. Portion of portion 3 Portion of portion 4 Portion of portion 5 Remaining portion of 6 Remaining portion of 8 Doornspruit 84 JQ Portion of the whole farm Impala as the holder of the prospecting right associated with Doornspruit 84 JQ has submitted the closure application in relation to this farm.

The surface use area is an area of land that Impala may utilise for mining activities. Impala does not own any portion of land in the surface use area. The surface use area is made up of surface lease agreements with the RBA. The surface right owners and corresponding title deeds numbers of the land in the surface use area are listed in Table 7-6.

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TABLE 7-6: LAND OWNERSHIP WITHIN THE SURFACE USE AREA

Property description Portion number Title Deed reference Registered property owner Reinkoyalskraal 278 JQ 0 T6749/1909BP Republic of Bophuthatswana 2 T9673/1933 Republic of South Africa 3 T373/1992BP Republic of South Africa Elandsheuvel 282 JQ 1 T3783/1907BP Republic of South Africa 2 T3782/1907BP Republic of South Africa 3 T9673/1933BP Government of the Union of South Africa 4 T9673/1933BP 5 T164/1990BP Bafokeng Stam Wildebeestfontein 275 JQ 1 T10990/1937BP Republic of South Africa 3 T11135/2016 FRAJO 180 CC 4 T69867/2013 VALDITIME (PTY) LTD

5 UNKNOWN

6 UNKNOWN 7 T27708/1971BP Motsuenyane Eliphas 8 T35556/2009 Impala Platinum Ltd 9 T99143/2003 Rustenburg Local Municipality 10 T27711/1971BP Motsuenyane Aaron 12 T169772/2003 Rustenburg Local Municipality Kookfontein 265 JQ 2 T6980/1903BP Republic of Bophuthatswana

3 T3691/1931BP 5 T56703/2001 Republic of South Africa 11 T5145/1937BP Republic of South Africa 12 T53474/2017 Seepi Farms (Pty) Ltd 14 T3685/1931BP Republic of South Africa

20 T9910/1937BP Republic of South Africa 21 T3685/1931BP Republic of South Africa 22 T3688/1931BP 23 T9910/1937BP Republic of South Africa 24 T3687/1931BP Republic of Bophuthatswana 25 T9910/1937BP Republic of South Africa Beerfontein 263 JQ 2 T373/1883BP Republic of Bophuthatswana Vaalkop 275 JQ 0 T9495/1904BP Republic of Bophuthatswana Vlakfontein 276 JQ 0 T3781/1907BP Republic of Bophuthatswana Turffontein 262 JQ 0 T183/1989BP Republic of Bophuthatswana Toulon 111 JQ 0 T134/1935BP Republic of Bophuthatswana Doornspruit 106 JQ 0 T110/1935BP Republic of Bophuthatswana Goedgedacht 114 JQ 0 T3786/1907BP August Mokhatler Tribe

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Property description Portion number Title Deed reference Registered property owner Boschkoppie 104 JQ Portion of portion 0 T12173/1937BP Republic of Bophuthatswana Portion of portion 2 T29329/1968BP Rakgokong Edbaal Klein Doornspruit 108 JW 0 T3788/1907BP Republic of Bophuthatswana Klipgat 115 JQ 0 T6461/1937BP Republic of Bophuthatswana 1 T5398/1963BP Republic of Bophuthatswana Diepkuil 116 JQ 0 T1099/1923BP Republic of Bophuthatswana Doornspruit Annex 109 JQ 0 T110/1935BP Republic of Bophuthatswana Goedgedacht 110 JQ 0 T14/1980BP Republic of Bophuthatswana 1 T2249/1930BP Republic of Bophuthatswana Roodekraalspruit 113 JQ 0 T26983/1953 Johanna Trent 2 T5054/1934BP Masito Cornelis 3 T8115/1937BP Republic of South Africa 4 T7039/1937BP 5 T5124/1937BP 6 T4920/1941BP Malemabo Stephanus B – E 8 T10618/1959BP Jakonia Mofoeke Styldrift 90 JQ 0 T73/1980BP Republic of Bophuthatswana Hartebeestspruit 88 JQ 0 T3789/1907BP Republic of Bophuthatswana

Land Claims The DRDLR Land Claims Commissioner in North West has been contacted to confirm if there were any land claims on Portion 2 of the farm Beerfontein 263 JQ. The Land Claims Commissioner has confirmed that no land claims have been lodged on Portion 2 of the farm Beerfontein 263 JQ.

Land use Land use within the Impala Surface Use Area is a mixture of agriculture, community / suburban, mining activities and wilderness. Land use within the proposed project site is limited to mining as a result of the existing smelter operations. Further information is provided below.

Agriculture Agricultural activities currently undertaken within the surface use area include firewood harvesting, crop harvesting (this includes dry land sunflowers and maize), and grazing for livestock. Any crop cultivation is mainly on a subsistence basis and is limited to areas that have not been occupied by mining-related infrastructure and surrounding communities. Farmers in the area rely on rain to water their crops and experience losses when summer rains are late or insufficient. No farming related activities are associated with the proposed project area.

Community / suburban areas Numerous communities located within a 10 km radius of the Smelter Complex within the Impala Surface Use Area and are listed as follows: • Freedom Park, approximately 7 km south-east of the project area; • Mereting, approximately 8 km south-east of the project area;

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• Lefaragatlha, approximately 8 km south-west of the project area; • Bobuampja, approximately 6 km south-west of the project area; • Kgale, approximately 7 km south-west of the project area; • Pudunong, approximately 3 km south-west of the project area; • Masosobane, approximately 7 km south-west of the project area; • Lemenong, approximately 3 km south-west of the project area; and • Ga-Luka, approximately 2 km north of the project area.

Infrastructure and servitudes Impala has an extensive network of railway lines, water pipelines and power and telephone lines. Railway lines located within the surface use area form part of Impala’s internal railway network. This network is extensive and comprises over 100 km of rail which is utilised for the transportation of mining product. There are numerous pipelines within the surface use area that transport compressed air, clean water, sewage, treated sewage effluent, process water, and slurry (amongst other substances). These pipelines are either located above ground or underground and are maintained by Impala except for the Rand Water pipeline feeding the main Rand Water reservoir at the UG2 Concentrator. Power lines located within the surface use area comprise internal Impala power lines, municipal power lines and regional Eskom power lines. In addition to this there are numerous telephone lines within the surface use area that are maintained by Telkom.

The proposed project activities will not influence existing railway, water, power or telephone line networks.

Other mining operations and related industries There are also a number of individual operators that are located within and outside the surface use area that operate on the basis of their own agreements with the Royal Bafokeng and therefore do not fall under the responsibility of Impala even though they may be located in the surface use area. These include (amongst others) communities, Sasol Nitro, Xstrata Merafe and Omnia.

From an environmental management perspective and by law, Impala is responsible for the footprint of its own activities, infrastructure and associated impacts. This footprint is smaller than the surface use area and does not include the activities and related impacts of other entities that are in the area on the basis of their own agreements with the Royal Bafokeng.

CONCLUSION There are a number of activities associated with the proposed project area that have the potential to influence land use. It is however important to note that the proposed project is located in an area were mining related activities take place and as such is unlikely to influence a change of current land uses.

10000 15000 20000 25000 30000 35000 40000 Legend Pilanesberg National Park Vaalkop Dam Impala Surface Use Area

e w k n s Impala Smelter Complex a nd M Ela Residential Areas Letsasing Vaalkop Dam ± Sun City Main Roads -2805000 Nature Reserve -2805000 Power Line Ledig Railway Line Rivers Kapman R5 Lekwadi 56 Tantanana Dams Protected Areas / Nature Reserves

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g Ga-Mogajane -2820000 w -2820000

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Setlhokwe )")" )" (! )" )" )" Freedom Park Bospoort Dam )" (!)" Rankelenyane )")" )" Kana Lekojaneng Figure 14 -2830000 -2830000 Lenatong Matalaneng Regional Land Use Phokeng

Bobuantswa

Q u a r t Ga-kgale z i t e

R S 5 t 6 SLR Consulting (Africa) (Pty) Ltd 5 P O Box 1596, Cramerview, 2060, South Africa Paardekraal Tel: +27 (11) 467-0945 Fax: +27 (11) 467-0978 Lefaragatlhe Source:Jabula Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community -2835000 -2835000 720.19136.00002 2020/11/16 10000 15000 20000 25000 30000 35000 40000 15000 20000 25000 Legend

! Impala No. 7 Shaft Impala Surface Use Area Impala Smelter Complex Residential Areas )" Rockwall ± Dam Mining activities " )" M ) o ! Main Roads l Impala No. 7a Shaft a )" p o n Power Line g ! )" w Impala No. 5 Shaft a m Railway Line o n g a ! n Rivers Impala No. 5c Shaft Kelekitso Early a )" Learning Centre Dams

Impala Tailings! 3 & 4 ! ! Impala Tailings 1 & 2 Railway Stations H! Heritage Resources Ga Luka Historically Man Made Furrows

Impala No.! 4 Shaft ! Sensitive Receptors Impala No. 15 Shaft )" Impala Platinum Hospital

! )" -2825000 -2825000 Kelekitso Early Learning Centre ! " Impala Platinum Hospital Impala No. 10 Shaft ! Boekenhoutfontein Chrome Mine ) Impala No. 17 Shaft )" Schools )" Health Facilities

Impala No.! 5 Shaft

Omnia Fertilizer! Operations

Chrome Recovery! Plant

)" )" )" Impala No.! 9 Shaft )" )"

)" Freedom Park Impala No.16! Shaft Phokeng 0 1 2 Kilometers

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Lenatong

L Figure 15

! R Impala No. 1 Shaft 5 6 5 Bobuantswa Local Land Use 0 1 5 R

Rustenburg Platinum! Operations

Q u a r t Ga-kgale z it e Hex SLR Consulting (Africa) (Pty) Ltd S t P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) 467-0945 Fax: +27 (11) 467-0978 Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community 720.19136.00002 2020/11/16 15000 20000 25000 Impala Platinum Limited

INTRODUCTION AND LINK TO IMPACT Traffic from mining projects has the potential to affect the capacity of existing road networks, as well as result in public road safety issues. To understand the basis of these potential impacts in the context of the project activities, a baseline situational analysis is described below.

DATA COLLECTION Information in this section was derived from The Traffic Study undertaken for Impala by SLR (Siyazi, 2020).

DESCRIPTION Existing road network Existing road intersections within the vicinity of the proposed project area (Figure 16) include: • Impala Smelter Access Road, Road 1 and Road 2; • Road 2 and Road 3; • Lefaragatlha Road, Freedom Park Road, and Road 1; • Road R565 and Lefaragatlha Road; • Road R565 and Luka Road; and • Luka Road and Road 3.

Access to the Smelter Complex is via an access road that runs between two communities (Phokeng and Bobuampja) and is known as the Lefaragatlha Road as illustrated in Figure 16. On occasions, the Luka road can be utlised as an alternative road. Sections of the Lefaragatlha Road, Luka Road and Road R565 (Figure 16) are considered to have a medium sensitivity due to the following reasons: • sections of Lefaragatlha Road and Luka Road have housing located next to the roadway and it could therefore be expected that pedestrian movement (including children) would be present along these road sections; • sections of Road R565 has housing located next to the roadway and it could therefore be expected that pedestrian movement (including children) would be present along these road sections; and • vehicle traffic volumes along Road R565 are high which leads to a higher possibility of accidents.

The existing road networks are considered to have an acceptable level of service.

Existing traffic data Manual 12-hour traffic counts were conducted on 7th of August 2020 at the existing intersections that would potentially be affected by the proposed activities which indicate that the peak traffic hours occur between 06h15 and 07h15 in the morning, and 14h45 and 15h45 in the afternoons (Table 7-7).

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TABLE 7-7: TRAFFIC COUNT INFORMATION (SIYAZI, 2020) Point Intersection AM peak PM Peak Time interval Number of Time interval Number of vehicles vehicles A Impala Smelter Access Road, 06:15 –07:15 843 14:45 –15:45 554 Road 1 and Road 2 B Road 2 and Road 3 06:15 –07:15 677 14:45 –15:45 491 C Lefaragatlha Road, Freedom 06:15 –07:15 1 012 14:45 –15:45 617 Park Road, and Road 1 D Road R565 and Lefaragatlha 06:15 –07:15 1 590 14:45 –15:45 1 858 Road E Road R565 and Luka Road 06:15 –07:15 924 14:45 –15:45 1 540 F Luka Road and Road 3 06:15 –07:15 630 14:45 –15:45 742

CONCLUSION Key potential traffic related impacts include road vehicle capacity and public safety. The proposed project presents additional trucks transporting toll to the Smelter Complex along the Lefaragatlha and Luka roads that will require management and consideration.

FIGURE 16: SENSITIVE ROAD SECTIONS AND INTERSECTIONS INDICATING EXISTING SENSITIVE AREAS AND INTERSECTIONS (SIYAZI, 2020)

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The environmental features in the project area are described in Section 7.4.1 above, however the notable environmental feature is the Leragane stream, located approximately 1.17 kilometres from the proposed project area. The notable infrastructure adjacent to the proposed project area includes extensive network of roads, railway lines, water pipelines and power and telephone lines.

A conceptual map showing land uses on and immediately surrounding the project area is provided in Figure 14 and Figure 15.

ENVIRONMENTAL IMPACTS AND RISKS OF THE ALTERNATIVES This section requires a list of potential impacts on environmental and socio-economic aspects that have been identified in respect of each of the main project actions / activities and processes for each of the project phases in terms of the project alternatives. With reference to Section 7.1, no project alternatives have been considered and as such this section is not applicable.

METHODOLOGY USED IN DETERMINING THE SIGNIFICANCE OF ENVIRONMENTAL IMPACTS The method used for the assessment of environmental issues is set out in Table 7-8. This assessment methodology enables the assessment of environmental issues including: cumulative impacts, the severity of impacts (including the nature of impacts and the degree to which impacts may cause irreplaceable loss of resources), the extent of the impacts, the duration and reversibility of impacts, the probability of the impact occurring, and the degree to which the impacts can be mitigated.

TABLE 7-8: IMPACT ASSESSMENT METHODOLOGY Note: Part A provides the definition for determining impact consequence (combining intensity, spatial scale and duration) and impact significance (the overall rating of the impact). Impact consequence and significance are determined from Part B and C. The interpretation of the impact significance is given in Part D.

PART A: DEFINITIONS AND CRITERIA* Definition of SIGNIFICANCE Significance = consequence x probability Definition of CONSEQUENCE Consequence is a function of intensity, spatial extent and duration Criteria for ranking of VH Severe change, disturbance or degradation. Associated with severe consequences. May result in the INTENSITY of severe illness, injury or death. Targets, limits and thresholds of concern continually exceeded. environmental Substantial intervention will be required. Vigorous/widespread community mobilization against impacts project can be expected. May result in legal action if impact occurs. H Prominent change, disturbance or degradation. Associated with real and substantial consequences. May result in illness or injury. Targets, limits and thresholds of concern regularly exceeded. Will definitely require intervention. Threats of community action. Regular complaints can be expected when the impact takes place. M Moderate change, disturbance or discomfort. Associated with real but not substantial consequences. Targets, limits and thresholds of concern may occasionally be exceeded. Likely to require some intervention. Occasional complaints can be expected. L Minor (Slight) change, disturbance or nuisance. Associated with minor consequences or deterioration. Targets, limits and thresholds of concern rarely exceeded. Require only minor interventions or clean-up actions. Sporadic complaints could be expected.

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VL Negligible change, disturbance or nuisance. Associated with very minor consequences or deterioration. Targets, limits and thresholds of concern never exceeded. No interventions or clean- up actions required. No complaints anticipated. VL+ Negligible change or improvement. Almost no benefits. Change not measurable/will remain in the current range. L+ Minor change or improvement. Minor benefits. Change not measurable/will remain in the current range. Few people will experience benefits. M+ Moderate change or improvement. Real but not substantial benefits. Will be within or marginally better than the current conditions. Small number of people will experience benefits. H+ Prominent change or improvement. Real and substantial benefits. Will be better than current conditions. Many people will experience benefits. General community support. VH+ Substantial, large-scale change or improvement. Considerable and widespread benefit. Will be much better than the current conditions. Favourable publicity and/or widespread support expected. Criteria for ranking VL Very short, always less than a year. Quickly reversible the DURATION of L Short-term, occurs for more than 1 but less than 5 years. Reversible over time. impacts M Medium-term, 5 to 10 years. H Long term, between 10 and 20 years (likely to cease at the end of the operational life of activity). VH Very long, permanent, +20 years (Irreversible, Beyond closure). Criteria for ranking VL A part of the site/property. the EXTENT of impacts L Whole site. M Beyond the site boundary, affecting immediate neighbours. H Local area, extending far beyond site boundary. VH Regional/National

PART B: DETERMINING CONSEQUENCE INTENSITY = VL Very long VH Low Low Medium Medium High Long term H Low Low Low Medium Medium

DURATION Medium term M Very Low Low Low Low Medium Short term L Very low Very Low Low Low Low Very short VL Very low Very Low Very Low Low Low INTENSITY = L Very long VH Medium Medium Medium High High Long term H Low Medium Medium Medium High

DURATION Medium term M Low Low Medium Medium Medium Short term L Low Low Low Medium Medium Very short VL Very low Low Low Low Medium INTENSITY = M Very long VH Medium High High High Very High Long term H Medium Medium Medium High High

DURATION Medium term M Medium Medium Medium High High Short term L Low Medium Medium Medium High Very short VL Low Low Low Medium Medium INTENSITY = H Very long VH High High High Very High Very High DURATION Long term H Medium High High High Very High

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Medium term M Medium Medium High High High Short term L Medium Medium Medium High High Very short VL Low Medium Medium Medium High INTENSITY = VH Very long VH High High Very High Very High Very High Long term H High High High Very High Very High

DURATION Medium term M Medium High High High Very High Short term L Medium Medium High High High Very short VL Low Medium Medium High High

VL L M H VH A part of the Whole site Beyond the Extending far Regional/ site/ property site, affecting beyond site National neighbours but localised EXTENT

PART C: DETERMINING SIGNIFICANCE PROBABILITY Definite/ Continuous VH Medium Medium High Very High Very High (of exposure Probable H Low Medium Medium High Very High to impacts) Possible/ frequent M Low Low Medium Medium High Conceivable L Very Low Low Low Medium Medium Unlikely/ improbable VL Negligible Very Low Low Low Medium VL L M H VVH CONSEQUENCE

PART D: INTERPRETATION OF SIGNIFICANCE Significance Decision guideline Very High Potential fatal flaw unless mitigated to lower significance. High It must have an influence on the decision. Substantial mitigation will be required. Medium It should have an influence on the decision. Mitigation will be required. Low Unlikely that it will have a real influence on the decision. Limited mitigation is likely required. Very Low It will not have an influence on the decision. Does not require any mitigation Negligible Inconsequential, not requiring any consideration. *VH = very high, H = high, M= medium, L= low and VL= very low and + denotes a positive impact.

POSITIVE AND NEGATIVE IMPACTS OF THE PROPOSED ACTIVITY AND ALTERNATIVES As noted in Section 7.1, no site alternatives were considered as the development footprint was determined by the location of the existing flash dryer at the Smelter Complex.

POSSIBLE MANAGEMENT ACTIONS THAT COULD BE APPLIED AND THE LEVEL OF RISK A summary of issues and concerns raised by I&APs during the BAR process is provided in Section 7.3. A list of the potential impacts identified by SLR and/or raised by I&APs, as well as the possible management and mitigation measures, is provided in Table 7-9. The level of residual risk after management or mitigation is also estimated.

TABLE 7-9: POSSIBLE MANAGEMENT ACTIONS AND THE ANTICIPATED LEVEL OF RISK Issue and concern raised Possible management actions or alternatives to Impact significance of the possible address issue management action before and after mitigation Unmitigated Mitigated According to your presentation, the potential impacts with respect to noise are low. • manage through investigation of noise related complaint Insignificant However, we must have control measures because the project results in additional (where applicable) air emissions in According to your presentation, the potential impacts with respect to air are low. Management actions to be implemented during all proposed Low Very Low However, we must have control measures because the project results in additional project phases include: air emissions in relation to existing emissions in the area. • reductions of vehicle exhaust emissions through the use of My main concern is air pollution, we are currently experiencing air pollution and better-quality diesel; and inspection and maintenance the project will result to an increase in air pollution in the area. Please make sure programs; that you monitor air pollution. • continued implementation of the Impala air quality Our women are miscarrying, reports like these will give us answers. Currently, the monitoring programme (see section 28); and way the project is presented, it’s to help Impala make profit. As a community we • record keeping. will never get a cent from it. Studies should be done to determine the health impacts from the Impala operations. What is the air quality monitoring programme? What new technologies that can be used to manage air pollution, which form part of Scenario 3 (Modelling scenario that takes into account emissions associated with the proposed project, smelter operations and all impala operations in the area) as per the finding of the air quality Can the MCLEF be provided with more information on the air quality legislation (i.e. the National Air Quality Standard and Dust Control Regulations) as well as the

Issue and concern raised Possible management actions or alternatives to Impact significance of the possible address issue management action before and after mitigation Unmitigated Mitigated findings of the Air Quality Study, which states that the project will not affect the community from an air quality perspective in writing. The clinics are full. This is because of emissions from the Impala plant. Has impala taken time to understand why people are sick? Life expectancy is questionable, and we don’t have facts. Studies should be done to help us understand this, instead studies are only done to help Impala kill us. We can’t use boreholes; the water is salty. Some animals are dying. • manage through investigation of groundwater related Insignificant My main concern is groundwater. The information provided in the presentation complaint (where applicable) states that the project will not affect our groundwater supply. Please provide this information in writing. We are currently having a water problem in Rustenburg. We are not sure how the During all proposed project phases, Impala will continue: Medium Very Low project will contaminate our water. Please elaborate on an alternative water supply • to implement approved management actions pertaining to In terms of water, will the project not result in contamination of our water? If there the containment of dirty water in accordance with are any problems with our water supply, the alternatives will be rivers Regulation 704 (June 1999), • to implement the approved waste management procedures; • to monitor surface water resources in accordance with the approved surface water monitoring programme; and • where monitoring results indicates that third party water supply has been polluted by Impala, Impala will ensure that an alternative equivalent water supply will be provided. Communities are not benefiting from the project; how do we ensure that • During all project phases, Impala will continue to implement Insignificant Very Low (positive) communities benefit? External trucks will be used for transportation of the existing Impala management actions pertaining to the materials. There must be economic- spin-offs for the community. We propose that procurement of local people (where possible) and we use local companies owned by our people for transportation. procurement of local good. How will the project affect us positively and negatively? How will this benefit me? What are the benefits within the project so that I know how to participate?

Issue and concern raised Possible management actions or alternatives to Impact significance of the possible address issue management action before and after mitigation Unmitigated Mitigated I also don’t agree with the socio-economic ratings, there will be additional trucks resulting in socio-economic benefits. We already have socio-economic challenges in the area, please address the impacts and include control measures. The procurement system for third party mining companies (i.e. Marula) delivering toll materials to the Smelter Complex should make provision to extent opportunities to the communities surrounding the Smelter Complex or create a platform where they can be engaged by the community leadership. Failure to extent such opportunities or to provide a platform where they can be engaged will result in the community making decisions on what happens when they are delivering toll material to the Smelter Complex. According to the presentation, opportunities will be extended to communities where possible? This statement implies that contractors will come and use their own people. There should be a clause in the agreement between Impala and the appointed contractor to extend employment opportunities to the community. Third-party trucks will increase, and the community will not benefit. These truck owners must be forced to provide employment opportunities to the community or to partner with the local people. How was the traffic specialist appointed by Impala? The tender was not made available to the community. What is the budget for the proposed Phase 1 and Phase 2 of the Project? Please provide the MCLEF with the budget and outline the subcontracting opportunities available upfront prior to appointment of a contractor. Every day we bury our people, that indicates that there is poverty in the area. If the project does not provide employment for people, it will not go ahead. Give us statistics on the employment created by Impala. Somebody will see the newspaper and assume that there are job opportunities. • management through local procurement of goods and Insignificant This will make people protest, how are we going to resolve that? Where do these services (where possible) diseases come from? This is not included in the presentation.

Issue and concern raised Possible management actions or alternatives to Impact significance of the possible address issue management action before and after mitigation Unmitigated Mitigated Rustenburg is a subregion to the Bojanala Platinum District Municipality. Impala is not focusing on the Bojanala Platinum District Municipality area when seeking to appoint environmental consultants. Johannesburg is not within the North West province. Impala should first extend the tender opportunities available to the North West province before requesting quotations from other provinces. I disagree with the concept that the project does not encroach on existing During all project phases, Impala will: High Medium communities, an increase in traffic is an encroachment on communities. • undertake a road safety assessment on roads adjacent the The project will result in additional traffic that will have an impact on communities, Impala Smelter Complex including Intersections A, B, C and however, external companies will benefit. If there is no proper plan from Impala on F to determine the need for the following: how the communities will benefit, this community will protest until economic spin- o reflective studs at the relevant intersections and offs are derived from the project. roadways in between intersections I disagree with the concept that the project does not encroach on existing o updating and maintaining road markings which are communities, an increase in traffic is an encroachment on communities. fading; and; o provision of relevant road traffic signs where required. • provide Impala Smelter Complex workers and contractor workers with training on road safety; and • Run road safety and awareness campaigns at the mine

Impala Platinum Limited

MOTIVATION WHERE NO ALTERNATIVE SITES WERE CONSIDERED The development footprint was determined by the location of the existing flash dryer at the Smelter Complex. It follows that no site alternatives were considered due to this fixed position.

STATEMENT MOTIVATING THE PREFERRED ALTERNATIVE No feasible alternatives exist for the proposed project and as such this section is not applicable. Refer to Section 7.1 for further detail.

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FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY, ASSESS AND RANK THE IMPACTS AND RISKS THE ACTIVITY WILL IMPOSE ON THE PREFERRED SITE THROUGH THE LIFE OF THE ACTIVITY This section provides a description of the process that was followed in order to identity the potential biophysical, cultural and socio-economic impacts that are assessed as part of the proposed project.

DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY IMPACTS Biophysical and socio-economic impacts associated with the proposed project were identified through site visits undertaken by SLR and specialists, and the specialist studies.

As part of the public participation process, I&APs and commenting authorities (see Section 7.2) are being provided with opportunities to provide input into the BAR process and comment on the proposed project, including the identification of environmental and socio-economic impacts.

DESCRIPTION OF THE PROCESS UNDERTAKEN TO ASSESS AND RANK THE IMPACTS AND RISKS A description of the assessment methodology use to assess the severity of identified impacts (including the nature of impacts and the degree to which impacts may cause irreplaceable loss of resources), the extent of the impacts, the duration and reversibility of impacts, the probability of the impact occurring, and the degree to which the impacts can be mitigated is provided in Section 7.6.

A DESCRIPTION OF THE ENVIRONMENTAL IMPACTS AND RISKS IDENTIFIED DURING THE ENVIRONMENTAL ASSESSMENT PROCESS Table 8-1 below provides a description of the impacts on biophysical, cultural and socio-economic aspects in respect of each of the main project actions / activities and processes that will be assessed in Appendix D. Where potential impact were considered, but are deemed insignificant as a result of the proposed project these have been listed for completeness purposes, but will not be associated with any activities or project phase.

TABLE 8-1: LIST OF POTENTIAL IMPACTS AS THEY RELATED TO THE PROPOSED PROJECT Potential impact Activity Project phases Loss and Sterilisation of Mineral Resources Not applicable Not applicable Hazardous Excavations and Infrastructure Resulting in Not applicable Not applicable Safety Risks to Third Parties and Animals Loss of Soil Resources and Land Capability through Physical Not applicable Not applicable Disturbance and Contamination Physical Destruction and General Disturbance of Terrestrial Not applicable Not applicable Biodiversity Alteration of Natural Drainage Patterns Not applicable Not applicable Pollution of Surface Water Resources Site preparation Construction Earthworks Operational Civil works Decommissioning Transport systems Closure General site management Demolition

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Potential impact Activity Project phases Maintenance and aftercare Rehabilitation Contamination of Groundwater Resources Not applicable Not applicable Air pollution Site preparation Construction Earthworks Operational Civil works Decommissioning Transport systems Closure General site management Demolition Maintenance and aftercare Rehabilitation Increase in Disturbing Noise Levels Not applicable Not applicable Negative Visual Views Not applicable Not applicable Road Disturbance Influence on the Level ff Service Not applicable Not applicable Road Traffic Safety Transport systems Construction Operational Decommissioning Loss of Heritage/Cultural and Palaeontological Resources Not applicable Not applicable Inward Migration Not applicable Not applicable Economic Impact Site preparation Construction Earthworks Operational Civil works Decommissioning Transport systems Closure General site management Demolition Maintenance and aftercare Rehabilitation Change in Land Use Not applicable Not applicable

ASSESSMENT OF THE SIGNIFICANCE OF EACH IMPACT AND RISK AND AN INDICATION OF THE EXTENT OF TO WHICH THE ISSUE AND RISK CAN BE AVOIDED OR ADDRESSED BY THE ADOPTION OF MANAGEMENT ACTIONS The assessment of the significance of potential biophysical, cultural and socio-economic impacts, including the extent to which impacts can be avoided or mitigated, is included in Section 9 and Appendix D.

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ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND RISK The aim of this section is to provide a summary of the assessment results of the identified biophysical, cultural and socio-economic impacts identified for the proposed project.

A summary of the assessment of the biophysical and socio-economic impacts associated with the proposed project is provided in Table 9-1 below. A full description of the assessment is included in Appendix D.

TABLE 9-1: ASSESSMENT OF SIGNIFICANT IMPACTS AND RISKS Activity Potential impact Aspects affected Phase Significance Management actions type Significance Extent to which the (Unmitigated) (Mitigated) impact can be reversed, avoided or cause irreplaceable loss and the degree to which the impact and risk can be mitigated Not applicable Loss and Geology Not applicable Insignificant Sterilisation of Mineral Resources Not applicable Hazardous Topography Not applicable Insignificant Excavations and Infrastructure Resulting in Safety Risks to Third Parties and Animals Not applicable Loss of Soil Soil and Land Not applicable Insignificant Resources and Capability Land Capability through Physical

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Activity Potential impact Aspects affected Phase Significance Management actions type Significance Extent to which the (Unmitigated) (Mitigated) impact can be reversed, avoided or cause irreplaceable loss and the degree to which the impact and risk can be mitigated Disturbance and Contamination Not applicable Physical Biodiversity Not applicable Insignificant Destruction and General Disturbance of Terrestrial Biodiversity Not applicable Alteration of Surface Water Not applicable Insignificant Natural Drainage Patterns Site preparation Pollution of Surface Water Construction Medium During all Proposed project Very Low Likely with mitigation Earthworks Surface Water Operational phases, Impala will continue: Civil works Resources Decommissioning • to implement approved Transport Closure management actions systems pertaining to the containment General site of dirty water in accordance management with Regulation 704 (June Demolition 1999), Maintenance • to implement the approved and aftercare waste management Rehabilitation procedures; • to monitor surface water resources in accordance with the approved surface water monitoring programme; and

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Activity Potential impact Aspects affected Phase Significance Management actions type Significance Extent to which the (Unmitigated) (Mitigated) impact can be reversed, avoided or cause irreplaceable loss and the degree to which the impact and risk can be mitigated • where monitoring results indicates that third party water supply has been polluted by Impala, Impala will ensure that an alternative equivalent water supply will be provided Not applicable Contamination of Groundwater Not applicable Insignificant Groundwater Resources Site preparation Air pollution Air Quality Construction Low Management actions to be Very Low Health impacts cannot Earthworks Operational implemented during all Proposed be easily reversed. Civil works Decommissioning project phases include: Transport Closure • reductions of vehicle exhaust systems emissions through the use of General site better-quality diesel; and management inspection and maintenance Demolition programs; Maintenance • continued implementation of and aftercare the Impala air quality Rehabilitation monitoring programme (see section 28); and • record keeping. Not applicable Increase in Noise Not applicable Insignificant Disturbing Noise Levels

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Activity Potential impact Aspects affected Phase Significance Management actions type Significance Extent to which the (Unmitigated) (Mitigated) impact can be reversed, avoided or cause irreplaceable loss and the degree to which the impact and risk can be mitigated Not applicable Negative Visual Visual Not applicable Insignificant Views Not applicable Road Traffic Not applicable Insignificant Disturbance Influence on the Level of Service Transport Road Traffic Traffic Construction High During all Proposed project Medium Unlikely in the event of systems Safety Operational phases, Impala will: injury of people or Decommissioning • undertake a road safety animals assessment on roads adjacent the Impala Smelter Complex including Intersections A, B, C and F to determine the need for the following: o reflective studs at the relevant intersections and roadways in between intersections o updating and maintaining road markings which are fading; and; o provision of relevant road traffic signs where required. • provide Impala Smelter Complex workers and

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Activity Potential impact Aspects affected Phase Significance Management actions type Significance Extent to which the (Unmitigated) (Mitigated) impact can be reversed, avoided or cause irreplaceable loss and the degree to which the impact and risk can be mitigated contractor workers with training on road safety; and • Run road safety and awareness campaigns at the mine Not applicable Loss of Heritage/Cultural Not applicable Insignificant Heritage/Cultural and and Palaeontological Palaeontological Resources Resources Not applicable Inward Migration Socio-economic Not applicable Insignificant Site preparation Economic Impact Socio-economic Construction Insignificant • During all Proposed project Very Low With adequate Earthworks Operational phases, Impala will continue (Positive) communication Civil works Decommissioning to implement existing Impala structures positive Transport Closure management actions impacts can be systems pertaining to the procurement enhanced. General site of local people (where management possible) and procurement of Demolition local good. Maintenance and aftercare Rehabilitation Not applicable Change in Land Land Use Not applicable Insignificant Use

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SUMMARY OF SPECIALIST REPORT FINDINGS The aim of this section is to list the various specialist studies undertaken for the Proposed project including the main findings of their reports, which are used to inform the compilation of this BAR.

The relevant specialist studies that were undertaken as part of the Proposed project including the recommendations made by the specialists are summarised in Table 9-1 below. All relevant specialist reports have been attached in the appendices to this report.

TABLE 10-1: SUMMARY OF SPECIALIST RECOMMENDATIONS Specialist study Recommendation of specialist Specialist recommendations Reference to that have been included in applicable section in the EIR (mark with an x) this report

Air quality Management actions to be implemented during all project phases include: X • Section 26 • reductions of vehicle exhaust emissions through the use of better-quality diesel; and inspection and (management maintenance programs; actions) • continued implementation of the Impala air quality monitoring programme (see section 28); and • Section 28 • record keeping. (monitoring). Traffic Management actions to be implemented during all project phases include X • Section 26 • undertaking a road safety assessment on roads adjacent the Impala Smelter Complex including (management Intersections A, B, C and F to determine the need for the following actions)

o reflective road studs at the relevant intersections and roadways in between intersections; o updating and maintaining road markings which are fading; and o need for relevant road traffic signs where not present or are required. • provide Impala Smelter Complex workers and contractor workers with training on road safety; and • run road safety and awareness campaigns at the mine.

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ENVIRONMENTAL IMPACT STATEMENT The aim of this section is to provide a summary of the potential biophysical, cultural and socio-economic impacts identified as well as their significance rating.

SUMMARY OF KEY FINDINGS This section provides a summary of the findings of identified and assessed potential impacts on the receiving environment in both the unmitigated and mitigated scenarios, including cumulative impacts. A summary of the potential impacts (as per Section 9), associated with the preferred alternative (as per Section 6), in the unmitigated and mitigated scenarios for all project phases is included in Table 11-1 below.

The assessment of the Proposed project presents the potential for negative impacts to occur (in the unmitigated scenario in particular) on the biophysical, cultural and socio-economic environments both on the Proposed project site and in the surrounding area. With management actions these potential impacts can be prevented or reduced to acceptable levels.

It follows that provided the EMPr is effectively implemented there is no biophysical, social or economic reason why the Proposed project should not proceed.

TABLE 11-1: SUMMARY OF POTENTIAL IMPACTS Aspect Potential impact Cumulative impact significance of the impact (the ratings are negative unless otherwise specified) Unmitigated Mitigated Geology Loss and Sterilisation of Mineral Resources Insignificant Topography Hazardous Excavations and Infrastructure Resulting in Insignificant Safety Risks to Third Parties and Animals Soil and land capability Loss of Soil Resources and Land Capability Through Insignificant Physical Disturbance and Contamination Biodiversity Physical Destruction and General Disturbance of Insignificant Terrestrial Biodiversity Surface Water Resources Alteration of Natural Drainage Patterns Insignificant Pollution of Surface Water Resources Medium Very Low Groundwater Contamination of Groundwater Resources Insignificant Insignificant Air Quality Air Pollution Low Very Low Noise Increase in Disturbing Noise Levels Insignificant Visual Negative Visual Views Insignificant Traffic Road Disturbance Influence on Level of Service Insignificant Road Traffic Safety High Medium Heritage/Cultural and Loss of Heritage/Cultural and Palaeontological Insignificant Palaeontological Resources Resources Socio-Economic Inward Migration Insignificant Economic Impact Insignificant Very Low (positive) Land Use Change in Land Uses Insignificant

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FINAL SITE MAP The final preferred site layout plan is included in Figure 5.

SUMMARY OF THE POSITIVE AND NEGATIVE IMPACTS AND RISKS OF THE PROPOSED ACTIVITY AND IDENTIFIED ALTERNATIVES As noted in Section 7.1, no site alternatives were considered as the development footprint was determined by the location of the existing flash dryer at the Smelter Complex.

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IMPACT MANAGEMENT OBJECTIVES AND OUTCOMES FOR INCLUSION IN THE EMPR Based on the outcome of the impact assessment and where applicable the recommendations from specialists the proposed management objectives and outcomes specific to the proposed changes and for inclusion into the environmental management programme are detailed in this section.

PROPOSED MANAGEMENT OBJECTIVES AND OUTCOMES FOR ENVIRONMENTAL AND SOCIO- ECONOMIC IMPACTS Specific environmental objectives to control, remedy or prevent potential impacts emanating from the Proposed project are provided in Table 12-1 below.

TABLE 12-1: ENVIRONMENTAL OBJECTIVES AND OUTCOMES Aspect Environmental objective Outcome Surface Water To prevent pollution of surface water resources To ensure that potential contaminates do not reach the Leragane stream and associated tributaries. Air To prevent air pollution health impacts. Ensure that any pollutants emitted as a result of the Proposed project remains within acceptable limits so as to prevent health related impacts. Traffic To prevent transport related accidents and/or Ensure the mine’s use of public roads is done in a injury to people and livestock responsible manner to reduce the potential for safety and vehicle related impacts on road users. Socio-economic To enhance positive economic impacts. Enhance the positive economic impacts by working together with existing structures and organisations.

IMPACTS THAT REQUIRE MONITORING PROGRAMMES Outcomes of the environmental objectives are the implementation of an air monitoring programmes and is outlined in Section 28.

ACTIVITIES AND INFRASTRUCTURE The source activities of potential impacts which require management are detailed in Section 3.3 and include: • site preparation; • earthworks; • civil works; • transport system; • general site management; • demolition; • rehabilitation; and • maintenance and aftercare.

MANAGEMENT ACTIONS Management actions which will be implemented to control the Proposed project activities or processes which have the potential to pollute or result in environmental degradation are detailed in Section 26.

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ROLES AND RESPONSIBILITIES The key personnel to ensure compliance to this BAR and EMPr are the operations executive and the Environmental Department Manager and officers. As a minimum, their roles, as they relate to the implementation of monitoring programmes and management activities, include: • Smelter Manager and Environmental Specialist – Air Quality: o ensure that the monitoring programmes and audits are scoped and included in the annual mine budget; o identify and appoint appropriately qualified specialists/engineers to undertake the programmes; and o appoint specialists in a timeously manner to ensure work can be carried out to acceptable standards. • Stakeholder engagement department: o establish and maintain good working relations with surrounding communities and landowners; and o facilitate stakeholder communication, information sharing and grievance mechanism.

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ASPECTS FOR INCLUSION AS CONDITIONS OF THE AUTHORISATION Management actions including monitoring requirements, as outlined in Sections 26, should form part of the conditions of the environmental authorisation. With reference to Regulation 26 of GNR 982 of NEMA, additional conditions that should form part of the environmental authorisation that are not specifically included in the EMPr report include compliance with all applicable environmental legislation whether specifically mentioned in this document or not and which may be amended from time to time.

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ASSUMPTIONS, UNCERTAINTIES, LIMITATIONS AND GAPS IN KNOWLEDGE This section outlines the assumptions and limitations applicable to this Proposed project.

ENVIRONMENTAL ASSESSMENT LIMIT The EIA focuses on third parties only and does not assess health and safety impacts on employees and contractors because the assumption is made that these aspects are separately regulated by health and safety legislation, policies and standards, and that Impala will adhere to these.

PREDICTIVE MODELS IN GENERAL All predictive models are only as accurate as the input data provided to the modellers. If any of the input data is found to be inaccurate or is not applicable because of Proposed project design changes that occur over time, then the model predictions will be less accurate.

AIR QUALITY The 2020 Air Quality Study (Airshed, 2020) is based on a few assumptions and is subject to certain limitations, these include: • all project information required to calculate emissions for proposed operations was provided by Impala and SLR; it is assumed that all this information is the most recent data and correct • the EA process will be completed by SLR. For this reason, the impact significance of the Proposed project was determined based on the SLR impact significance methodology

• total suspended particles (TSP), PM10, PM2.5, SO2, NO2 and CO are the main pollutants of concern from the Proposed project • the impact of the construction and decommissioning phase impacts are expected to be similar or somewhat less significant than operational phase impacts. Mitigation and management measures recommended for the construction phase are also applicable to the decommissioning phase. No impacts are expected post-closure provided the rehabilitation of final landforms is successful; • meteorology: o data was available from five Impala ambient stations and one Impala weather station. The data for the period January 2019 to December 2019 was used in the dispersion modelling. The Impala “Services” ambient station is the closet to the proposed operations. The terrain and the land use surrounding both the station and the Proposed project are the same and the effects of the terrain and land use on the other meteorological parameters (not measured by these stations) but required for dispersion modelling would not vary between the Impala “Services” station and the proposed operations site. The National Code of Practice for Air Dispersion Modelling described in the Regulations regarding air dispersion modelling (GN 533; 11 July 2014) discusses the effects of land use and it is evident from surface roughness lengths, albedo values and bowen ratios provided in the regulations and international modelling guidelines for different land uses will not vary in terms of these parameters which affect the wind profile, atmospheric mixing and other planetary boundary layer parameters; and o the National Code of Practice for Air Dispersion Modelling described in the Regulations regarding air dispersion modelling prescribes the use of a minimum of one year of on-site data or at least three years of appropriate off-site data for use in Level 2 and Level 3 assessments. It also states that the meteorological data must be for a period no older than five years to the year of assessment. The dataset period is within the timeframe recommended by the National Code of

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Practice for Air Dispersion Modelling as the meteorological data is for one year (on-site measured data) and less than five years old during the assessment period (2020). • emissions: o the impact assessment was limited to the pollutants of concern (listed above). These pollutants are regulated under NAAQS and considered key pollutants released by the operations associated with the Proposed project; and o the quantification of sources of emission was restricted to the Impala existing and proposed operations. Other existing sources of emission within the area including other companies’ mining and processing operations, farming activities, domestic fires, biomass burning, vehicle exhaust emissions and dust entrained by vehicles on public roads were not included as part of the emissions inventory and simulations. Without detailed proposed (for when this Proposed project will be operational) operational data for other companies’ mining and processing operations as well as estimated future vehicle data for public roads it is difficult to quantify these sources for the period of the Proposed project operations. It is difficult to predict the contribution of the domestic and natural fires and farming sources to air quality during the period of the Proposed project operations due to variability of these operations with regards to locality, spatial extent and duration. • dispersion simulations: o all significant fugitive sources were simulated with the current mitigation measures applied; o the most recent average stack emissions were included in the dispersion simulation task; and

o it was assumed that all NOx emitted is converted to NO2. • greenhouse gas (GHG): o emissions estimation and modelling was not included in the scope of work.

TRAFFIC The following assumptions are relevant to the Traffic Study conducted by Siyazi (2020): • the vehicle traffic absorption rate (rate at which existing developments attract vehicular traffic) by all other types of completed developments will maintain the same status for the next ten years; • that the average rate of growth of vehicle traffic in the area under investigation that is not relevant to the proposed activities as part of the proposed new flash dryer (background traffic) between the 2020 to 2030 scenarios was anticipated at 3% per annum; • no information of any latent rights (planned or other known developments within the study area) is readily available at the time of conducting this study, and it was therefore assumed that there were no known approved latent rights within the vicinity of the study area that would have a significant impact on vehicle traffic volumes within the area; • the trip generation rates are based on the “COTO TMH17, South African Trip Data Manual Version 1.01, September 2013”, information provided by the project team and assumptions made based on professional experience where information was not available; and • the Traffic Impact Assessment does not comment on pavement layer attributes in terms of the relevant road sections. The last-mentioned need to be based on recommendations to be made by a Pavement Design Specialist input.

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REASONED OPINION AS TO WHETHER THE PROPOSED ACTIVITY SHOULD OR SHOULD NOT BE AUTHORISED The aim of this section is to provide a reasoned independent opinion, whether or not the Proposed project should proceed or not. This opinion is informed by the outcome of the impact assessment and recommendations made by specialists, I&APs and commenting authorities.

REASONS WHY THE ACTIVITY SHOULD BE AUTHORIZED OR NOT The assessment of the Proposed project presents the potential for significant negative impacts to occur (in the unmitigated scenario in particular) on the biophysical, cultural and socio-economic environments both on the Proposed project sites and in the surrounding area. With management actions, these potential impacts can be prevented or reduced to acceptable levels. It follows that provided the EMPr is effectively implemented there is no biophysical, social or economic reason why the Proposed project should not proceed.

CONDITIONS THAT MUST BE INCLUDED IN THE AUTHORISATION

SPECIFIC CONDITIONS FOR INCLUSION IN THE EMPR Refer to Section 13.

REHABILITATION REQUIREMENTS Refer to Section 27.

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PERIOD FOR WHICH AUTHORISATION IS REQUIRED With specific reference to the listed activities identified in Table 3-2, these activities specifically related to the installation and operation of the flash dryers and associated infrastructure upgrades. It follows that authorisation is required for the remaining life of mine (approximately 20 years).

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UNDERTAKING I, Reinett Mogotshi, the Environmental Assessment Practitioner responsible for compiling this report, undertake that: • the information provided herein is correct. • comments and inputs from stakeholders and I&APs have been included and correctly recorded in this report. • inputs and recommendations from the specialist reports have been included where relevant. • any information provided to I&APs and any responses to comments or inputs made is correct or was correct at that time.

Unsigned draft for public review Signature of EAP Date

Unsigned draft for public review Signature of commissioner of oath Date

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FINANCIAL PROVISION The aim of this section is to provide information pertaining to the methodology considered as part of the closure liability calculation determination.

METHODOLOGY APPLIED TO LIABILITY MODEL The following approach was applied to determine the financial provision (E-Tek, February 2021): • financial models were developed to cater for the requirements of GN R1147; • the costing models were developed to address all the identified closure components applicable to Impala; • the costing models provide the following output: o executive summary (Summary of all closure components and associated costs where applicable); o preliminary and general (P&G’s): Allocation of P&G’s for each component and provides weighted P&G’s, as certain P&G’s allowances, can vary per component); o contingencies (Allocation of Contingencies for each component and provides weighted Contingencies, as certain Contingency allowances can vary per component); o closure Components Summary (Provides a summary of all costs per closure component). The five main closure components have been identified as follows: ▪ infrastructural aspects; ▪ mining aspects; ▪ biophysical closure aspects; ▪ social closure aspects; and ▪ general aspects. o closure Components (Breakdown of the detail facilities and aspects under each of the five main closure components); and o rates Table (Unit rates for various actions required).

ASSESSMENT METHODOLOGY The approach followed with the determination of the closure costs could be summarized as follows: • review of available information, identification of infrastructure that would need to be decommissioned at closure; • gathering of relevant data which forms the basis of the calculation; • all-newly proposed infrastructure was assigned with a reference number which can be referenced directly to the costing model; • reference map was created indicating the position of the proposed infrastructure in relation to the existing infrastructure; • closure criteria was developed and workshopped with Impala as part of the annual liability assessment; • the closure forecast was based on the proposed project timeframe; • compilation of a Bill of Quantities capturing the quantities and actions relating to the closure of the different closure aspects (Microsoft excel format); and • unit rates from E-TEK’s database were updated to be aligned with the current market-related rates acquired from local civil- and demolition contractors.

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QUANTITIES The quantities for the project were calculated by E-Tek and were calculated from the site layout plan (Figure 5) inclusive of the following components which will be constructed in Phase 1 and Phase 2: • wet feeder; • wet Feeder conveyors; • transfer tower; • bag house; • flash dryer; • feed distribution tower; and • filter plant.

UNIT RATES Unit rates for the costing were obtained from E-TEK's existing database and/or through previous experience and consultation with demolition, earthworks contractors, and rehabilitation practitioners. Where required, these were adapted to reflect site-specific conditions.

CONFIRM THAT THE AMOUNT CAN BE PROVIDED FOR FROM OPERATING EXPENDITURE The amount required in order to manage and rehabilitate the environmental disturbance (as a result of Impala’s activities) is provided for in the operating costs.

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SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY IMPACT ON THE SOCIO-ECONOMIC CONDITIONS OF ANY DIRECTLY AFFECTED PERSON The impacts associated with socio-economic conditions are discussed in Appendix D. Management and management actions identified to address any socio-economic impacts are included in Section 26.

IMPACT ON ANY NATIONAL ESTATE REFERRED TO IN SECTION 3(2) OF THE NATIONAL HERITAGE RESOURCES ACT Not applicable. No national estate will be affected as part of the Proposed project.

DEPARTMENT OF ENVIRONMENTAL AFFAIRS SCREENING TOOL The DEA has developed an online screening tool, which is compulsory to use as of 04 October 2019. The report generated by the DEA screening tool was attached to the NEMA environmental authorisation application for the Proposed project. The screening tool report outlines specialist studies that need to be considered as part of the Proposed project. In this regard, the table below outlines the specialist studies proposed in the screening tool report along with an explanation.

TABLE 19-1: FINDINGS OF THE DEA SCREENING TOOL

Theme Sensitivity Requirements Agriculture Medium The footprint of the additional infrastructure is within an existing Smelter Complex, in a disturbed area that was previously assessed. Therefore, it will not result in any additional impacts on agricultural resources and capability. An Agricultural study will not be required. Landscape/visual Sensitivity is not The additional infrastructure will be absorbed within existing views of the Smelter specified in the Complex and will therefore not generate additional negative views and as such a screening tool Visual Study will not be required. Archaeological and Cultural report. The footprint of the additional infrastructure is within an area that was previously Heritage Impact assessed and has already been disturbed, therefore, no cultural or heritage Assessment resources will be affected. The archaeological and cultural heritage specialist study will not be required. Hydrology Assessment The proposed activities are within an existing Smelter Complex, in a disturbed area and where hydrological impacts were previously assessed. Therefore, a Hydrological Study will not be required. Palaeontology The footprint of the additional infrastructure is within an area that was previously assessed and has already been disturbed, therefore, no palaeontology will be affected. A Palaeontology Study will not be required. Noise Impact Assessment The Proposed project activities are within an existing Smelter Complex and will result in notable changes to the noise baseline of the area. Therefore, a Noise Study will not be required. Traffic Assessment A Traffic Study has been undertaken for the Proposed project and is included in Appendix F. Socio-economic The Proposed project activities are not anticipated to influence current socio- Assessment economic conditions at the mine. A Socio-economic Study is therefore not required. Air Quality Assessment An Air Quality Study has been undertaken for the Proposed project and is included Ambient Air Quality in Appendix E. Assessment

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Theme Sensitivity Requirements Health Impact Assessment Based on the result of the Air Quality Study, a health assessment associated with the Proposed project activities is not deemed necessary. Aquatic Biodiversity Low The Proposed project is within an existing Smelter Complex, within an area that was previously disturbed. An Aquatic Study is therefore not required. Civil Aviation Low Not applicable to the Proposed project. The Proposed project will not present any tall structures that could influence flight paths. Plant Species Assessment Low The Proposed project is within an existing Smelter Complex. A Plant Species Study is therefore not required. Animal Species Assessment Low The Proposed project is within an existing Smelter Complex, within an area that was previously disturbed. An Animal Species Study is therefore not required. Terrestrial Biodiversity Very High The Proposed project is within an existing Smelter Complex. A Terrestrial Study is therefore not required. Defence Low The Proposed project area is not located near any areas of defence.

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OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A) AND (B) OF THE ACT No other matters are required in terms of Section 24(4)(A) and (B) of the Act.

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PART B - ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

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DETAILS OF THE EAP The details of the EAPs who undertook the EIA process and prepared this EIR are provided in Part A, Section 1.

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DESCRIPTION OF THE ASPECTS OF THE ACTIVITY The activities that are covered in the EMPr are included in Part A, Section 7.

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COMPOSITE MAP A composite map superimposed on the environmental sensitive areas of the preferred site is included in Appendix I.

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DESCRIPTION OF THE IMPACT MANAGEMENT OBJECTIVES INCLUDING MANAGEMENT STATEMENT This section outlines the determination of the closure objectives and provides a list of management measures specifically identified to mitigated impacts associated with specified listed activities.

DETERMINATION OF CLOSURE OBJECTIVES The closure objectives for the project were determined taking into account the existing type of environment as described in Section 7.4.1, in order to ensure that the closure objectives strive to achieve a condition approximating its natural state as far as possible. Further information pertaining to the closure objectives identified for the Proposed project in provided in Section 27.1.1.

VOLUMES AND RATE OF WATER USE FOR MINING This section is not applicable as the proposed increase in the flash drying capacity does not require the use of large quantities of water.

HAS A WATER USE LICENCE BEEN APPLIED FOR? Not applicable for the Proposed project and it does not require a water use licence.

IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES The detailed assessment of potential impacts is included Appendix D. Management actions which will be implemented to avoid and minimise potential impacts are detailed in Section 26. The section below focuses on mitigation measures that are specific to listed activities based on the actions outlined in Section 26.

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TABLE 24-1: MEASURES TO REHABILITATE THE ENVIRONMENT AFFECTED BY THE UNDERTAKING OF ANY LISTED ACTIVITY Activity (Listed: NEMA and NEM:AQA) Size and scale Time period for Phase Mitigation measures Compliance with standards Number Description of disturbance implementation 34 The expansion of existing facilities or Construction The total Refer to Table 25-1 for the mitigation measures. Refer to Table 26-1 for the Refer to Table 26-1 for the infrastructure for any process or activity where Operational Proposed mitigation measures. mitigation measures. such expansion will result in the need for a project area for permit or licence or an amended permit or Phase 1 and licence in terms of national or provincial Phase 2 covers legislation governing the release of emissions, an area of effluent or pollution. approximately 0.14 ha Subcategory 4.1 Drying and calcining of mineral solids including Operational Not applicable Refer to Table 25-1 for the mitigation measures. Refer to Table 26-1 for the Refer to Table 26-1 for the ore. mitigation measures. mitigation measures.

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IMPACT MANAGEMENT OUTCOMES The purpose of this section is to outline the impact management objectives and outcomes for the potential biophysical, cultural and socio-economic impacts identified for the Proposed project.

Table 25-1 below provides a description of the outcomes and objective of management actions in order to manage, remedy, control or modify potential impacts. The management actions identified to achieve these outcomes and objectives are described in Section 26.

TABLE 25-1: DESCRIPTION OF IMPACT MANAGEMENT OUTCOMES Standard to be Achieved (Impact management Activity Potential Impact Affected Aspect Phase Management actions Type outcome/objectives) Not applicable Loss and Sterilisation of Geology Not applicable Insignificant Mineral Resources Not applicable Hazardous Excavations Topography Not applicable Insignificant and Infrastructure Resulting in Safety Risks to Third Parties and Animals Not applicable Loss of Soil Resources Soil and Land Not applicable Insignificant and Land Capability Capability through Physical Disturbance and Contamination Not applicable Physical Destruction Biodiversity Not applicable Insignificant and General Disturbance of Terrestrial Biodiversity Not applicable Alteration of Natural Surface Water Not applicable Insignificant Drainage Patterns

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Standard to be Achieved (Impact management Activity Potential Impact Affected Aspect Phase Management actions Type outcome/objectives) Site preparation Pollution of Surface Surface water Construction During all Proposed project phases, Management objective: The objective is to prevent Earthworks Water Resources Operational Impala will continue: pollution of surface water resources. Civil works Decommissioning • to implement approved management Management outcome: Transport systems Closure actions pertaining to the containment General site management of dirty water in accordance with Transport systems Regulation 704 (June 1999), General site management • to implement the approved waste Demolition management procedures; Maintenance and aftercare • to monitor surface water resources in Rehabilitation accordance with the approved surface water monitoring programme; and • where monitoring results indicates that third party water supply has been polluted by Impala, Impala will ensure that an alternative equivalent water supply will be provided Not applicable Contamination of Groundwater Not applicable Insignificant Groundwater Resources Site preparation Air pollution Air Quality Construction Management actions to be implemented Management objective: The objective is to prevent Earthworks Operational during all Proposed project phases air pollution health impacts. Civil works Decommissioning include: Management outcome: Ensure that any pollutants Transport systems Closure • reductions of vehicle exhaust emitted as a result of the Proposed project remains General site management emissions through the use of better- within acceptable limits so as to prevent health Demolition quality diesel; and inspection and related impacts. maintenance programs; • continued implementation of the Impala air quality monitoring programme (see section 28); and • record keeping.

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Standard to be Achieved (Impact management Activity Potential Impact Affected Aspect Phase Management actions Type outcome/objectives) Not applicable Increase in Disturbing Noise Not applicable Insignificant Noise Levels Not applicable Negative Visual Views Visual Not applicable Insignificant Not applicable Road Disturbance Traffic Not applicable Insignificant Influence on Level of Service Site preparation Road Traffic Safety Traffic Construction During all Proposed project phases, Management objective: The objective of the Earthworks Operational Impala will: mitigation measures is to prevent transport related Civil works Decommissioning • undertake a road safety assessment accidents and/or injury to people and livestock. Transport systems on roads adjacent the Impala Smelter Management outcome: Ensure the mine’s use of General site management Complex including Intersections A, B, C public roads is done in a responsible manner to Demolition and F to determine the need for the reduce the potential for safety and vehicle related following: impacts on road users. o reflective studs at the relevant intersections and roadways in between intersections o updating and maintaining road markings which are fading; and; o provision of relevant road traffic signs where required. • provide Impala Smelter Complex workers and contractor workers with training on road safety; and • Run road safety and awareness campaigns at the mine Site preparation Economic Impact Socio-Economic Construction During all project phases, Impala will Management objective: The objective is to Earthworks Operational continue to implement existing Impala enhance economic benefits of the Proposed Civil works Decommissioning management actions pertaining to the project. Transport systems Closure procurement of local people (where Management outcome: Enhance the positive General site management possible) and procurement of local good. economic impacts by working together with Demolition existing structures and organisations.

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Standard to be Achieved (Impact management Activity Potential Impact Affected Aspect Phase Management actions Type outcome/objectives) Not applicable Change in Land Use Land Use Not applicable Insignificant

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IMPACT MANAGEMENT ACTIONS The aim of this section is to detail the management action that have been identified (through input from specialist investigations, commenting authorities and I&APs) for the Proposed project.

Management actions identified to prevent, reduce, control or remedy the assessed impacts are presented in Table 26-1 below. The action plans include the timeframes for implementing the management actions together with a description of how management actions comply with relevant standards. Management actions and recommendations identified by specialists have been summarised and are included in the table below.

TABLE 26-1: DESCRIPTION OF IMPACT MANAGEMENT ACTIONS Activity Potential Impact Management actions Time Period for Compliance with Standards Implementation Not applicable Loss and Sterilisation Not applicable Not applicable Not applicable of Mineral Resources Not applicable Hazardous Not applicable Not applicable Not applicable Excavations and Infrastructure Resulting in Safety Risks to Third Parties and Animals Not applicable Loss of Soil Resources Not applicable Not applicable Not applicable and Land Capability through Physical Disturbance and Contamination Not applicable Physical Destruction Not applicable Not applicable Not applicable and General Disturbance of Terrestrial Biodiversity

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Activity Potential Impact Management actions Time Period for Compliance with Standards Implementation Not applicable Alteration of Natural Not applicable Not applicable Not applicable Drainage Patterns Site preparation Pollution of Surface During all Proposed project phases, Impala will continue: Not applicable Earthworks Water Resources • to implement approved management actions pertaining to the On-going Civil works containment of dirty water in accordance with Regulation 704 (June Transport systems 1999), General site • to implement the approved waste management procedures; On-going management • to monitor surface water resources in accordance with the approved On-going Transport systems surface water monitoring programme; and General site • where monitoring results indicates that third party water supply has management been polluted by Impala, Impala will ensure that an alternative As required Demolition equivalent water supply will be provided. Maintenance and aftercare Rehabilitation Not applicable Contamination of Not applicable Not applicable Not applicable Groundwater Resources Site preparation Air pollution Management actions to be implemented during all proposed project National Atmospheric Earthworks phases include: Emission Reporting Civil works • reductions of vehicle exhaust emissions through the use of better- On-going Regulations in terms of the Transport systems quality diesel; and inspection and maintenance programs; National Environmental General site • continued implementation of the Impala air quality monitoring On-going Management: Air Quality Act management programme (see section 28); and (No. 39 of 2004) requires that Demolition • record keeping. On-going holders of mining rights register on the National On-going Atmospheric Emissions Inventory System (NAEIS) and to ensure that annual monitoring reports are uploaded onto the NAEIS.

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Activity Potential Impact Management actions Time Period for Compliance with Standards Implementation Not applicable Increase in Disturbing Insignificant Not applicable Not applicable Noise Levels Not applicable Negative Visual Views Insignificant Not applicable Not applicable Not applicable Road Disturbance Insignificant Not applicable Not applicable Influence on Level of Service Site preparation Road Traffic Safety During all Proposed project phases, Impala will: Not applicable Earthworks • undertake a road safety assessment on roads adjacent the Impala As required Civil works Smelter Complex including Intersections A, B, C and F to determine Transport systems the need for the following: General site o reflective studs at the relevant intersections and roadways in management between intersections Demolition o updating and maintaining road markings which are fading; and; o provision of relevant road traffic signs where required. • provide Impala Smelter Complex workers and contractor workers As required with training on road safety; and • Run road safety and awareness campaigns at the mine. As required Site preparation Economic Impact During all Proposed project phases, Impala will continue to implement As required Not applicable Earthworks existing Impala management actions pertaining to the procurement of Civil works local people (where possible) and procurement of local good. Transport systems General site management Demolition Not applicable Change in Land Use Not applicable Not applicable Not applicable

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FINANCIAL PROVISION The aim of this section is to outline the closure objectives for closure, the rehabilitation plan and the financial liability determined for the Proposed project.

DETERMINATION OF THE AMOUNT OF THE FINANCIAL PROVISION

CLOSURE OBJECTIVES DESCRIPTION AND THE ALIGNMENT WITH THE BASELINE ENVIRONMENT The preliminary closure plan objectives and principles have been developed for the project against the background of the mine location in the North West. These objectives are in line with current approved EMPrs and include the following: • that environmental damage is minimised to the extent that it is acceptable to all parties involved; • that contamination beyond the project area by surface run-off, groundwater movement and wind will be prevented; • that the project closure is achieved efficiently, cost effectively and in compliance with the law; and • that the social and economic impacts resulting from project closure are managed in such a way that negative socio-economic impacts are minimised. Any additional and more specific closure objectives tied to the final land use for the entire Impala operations, will be determined in collaboration with local communities and other stakeholders during the ongoing operations at Impala.

CONFIRMATION THAT CLOSURE OBJECTIVES HAVE BEEN CONSULTED WITH I&APS The closure objectives are outlined in this report which will be made available to I&APs, including landowners for review and comment (Section 7.2).

To date no comments regarding the closure objectives (see Section 27.1.1) have been received from I&APs, including landowners (see Section 7.2 for the details of the public participation process).

REHABILITATION PLAN The project does not require the development of an annual rehabilitation plan as outlined in the Financial Provisioning Regulations, 2015 (GNR 1147 of 20 November 2015) that focusses on rehabilitation for the forthcoming 12 months. The Smelter Complex, inclusive of the project components will be operational for many years to come and the rehabilitation of this area would only be considered nearer to the end of life of mine (in approximately 20 years). It is however important to note, that in accordance with the Financial Provisioning Regulations, 2015 (GNR 1147 of 20 November 2015), Impala is revising their FY2021 annual financial provision update to comply with these Regulations. In this regard, the rehabilitation plan (where relevant) for the Impala operations, will be included as part of the FY2021 annual financial provision update.

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COMPATIBILITY OF THE REHABILITATION PLAN WITH THE CLOSURE OBJECTIVES It can be confirmed that the rehabilitation plan is compatible with the closure objectives given that the closure objectives were taken into account during the determination of the financial provision. The rehabilitation plan is in line with the minimum requirement of the EMPr.

CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION The financial provision for the project represents a 10 Year forecast. The financial provision takes into consideration the project schedule for implementation. Impala are to financially provide for the highest liability figure out of the 10 Year closure forecast, this has been calculated to be R1 668 891.81 (inclusive of VAT) at year 2024.

CONFIRMATION THAT THE FINANCIAL PROVISION WILL BE PROVIDED The financial provision is provided in the form of an insurance guarantee.

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MECHANISMS FOR MONITORING COMPLIANCE AND PERFORMANCE AGAINST THE EMPR The aim of this section is to outline the monitoring programme that will need to be implemented during all mine phases.

Environmental impacts requiring monitoring are listed in Table 28-1 below. As a general approach, Impala will ensure that the monitoring programmes comprise the following: • adherence to a formal monitoring procedure; • use of appropriately calibrated equipment by personnel trained to use the equipment; • the preservation of samples according to laboratory specifications, where samples require analysis; • the identification of monitoring parameters in consultation with a specialist in the relevant field and/or the relevant authority; • the amendment or removal of monitoring parameters, where necessary, following the initial monitoring results and in consultation with a specialist and/or the relevant authority; and • the interpretation of data and reporting of trends will be undertaken by an appropriately qualified person.

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TABLE 28-1: MONITORING OF COMPLIANCE AND PERFORMANCE Activity Impacts requiring Functional requirements for monitoring Roles and Monitoring and reporting monitoring responsibilities frequency and time period for management actions Site preparation Air pollution Under Section 21 of the NEM:AQA it is compulsory to measure PM, NOx expressed Environmental Dust fallout will be monitored on Earthworks as NO2 and SO2 emissions from the dryers stacks and the stacks associated with the Department a monthly basis while ambient Civil works furnaces and converters. It further requires the holder of an AEL to submit an monitoring to measure PM, NOx Transport System emission report in the format specified by the National Air Quality Officer or Licensing expressed as NO2 and SO2 General site Authority on an annual basis. Impala plans to continue to undertake monitoring as emissions must be undertaken as management set out in their current AEL, as shown in the table below. The locations of the air per the AEL. Demolition quality monitoring points are illustrated in Figure 17. Rehabilitation Point Source ID Pollutants to Emission Sampling Reporting onto the National measure sampling/monitoring frequency Emissions Inventory System will method continue to be done on annual Spray dryer 1 PM As per methods and Annual basis. Spray dryer 4 sampling analysis Spray dryer 5 prescribed in Annex A of Spray dryer 6 Section 21 of NEM:AQA. Flash Dryer 1 Tailgas NOx As per methods and Annual scrubber stack expressed as sampling analysis Furnace and NO2 prescribed in Annex A of converter Section 21 of NEM:AQA. fugitive off-gas SO2 As per methods and Annual sampling analysis prescribed in Annex A of Section 21 of NEM: AQA.

In addition to the above, it is recommended that the Impala current dust fallout sampling continue to be conducted and that the ambient monitoring is continued at the existing AQMS as part of the Proposed project’s air quality management plan.

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Figure 17

Air Quality Monitoring (!2a Shaft / Freedom Park

Phokeng SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) 467-0945 Fax: +27 (11) 467-0978 Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community 710.09003.00140 2020/11/16 -2830000 15000 20000 -2830000 Impala Platinum Limited

Basic Assessment Report and Environmental Management Programme for the proposed 710.09003.00140 increase of the flash dryer capacity and associated feed circuit modifications at the Impala March 2021 Rustenburg Smelter Complex

FREQUENCY OF PERFORMANCE ASSESSMENT REPORT Impala will for the period during which the environmental authorisation and the EMPr is valid, submit environmental audit reports to the DMRE. These audits will focus on the mines compliance with the conditions of the environmental authorisation and the commitments in the EMPr. These audits will be undertaken by a qualified independent person and will comply with the relevant NEMA Regulations 2014 (as amended).

The environmental manager will conduct internal management audits against the commitments in the EMPr in accordance with an annual audit plan. During the operational phase, these audits will be conducted on a quarterly basis. The audit findings will be documented for both record keeping purposes and for informing continual improvement.

CLOSURE COST REPORTING The financial provision for the mine will be updated on an annual basis and submitted to the DMRE for the duration of the operation in accordance with the relevant legislation.

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ENVIRONMENTAL AWARENESS PLAN This section outlines the environmental awareness plan that has been developed for the proposed mine.

MANNER IN WHICH APPLICANT INTENDS TO INFORM EMPLOYEES OF THE ENVIRONMENTAL RISKS This section includes an environmental awareness plan for the mine. The plan describes how employees will be informed of environmental risks which may result from their work, the manner in which the risk must be dealt with in order to avoid pollution or degradation of the environment and the training required for general environmental awareness and the dealing of emergency situations and remediation measures for such emergencies. All contractors that conduct work on behalf of Impala are bound by the content of the EMPr and a contractual condition to this effect will be included in all such contracts entered into by the mine. If contractors are used, the responsibility for ensuring compliance with the EMPr will remain with Impala.

The purpose of the environmental awareness plan is to ensure that all personnel and management understand the general environmental requirements of the site. In addition, greater environmental awareness must be communicated to personnel involved in specific activities which can have a significant impact on the environment and ensure that they are competent to carry out their tasks on the basis of appropriate education, training and/or experience. The environmental awareness plan should enable Impala to achieve the objectives of the environmental policy.

ENVIRONMENTAL POLICY Impala will display the environmental policy. To achieve world class environmental performance in a sustainable manner Impala is currently committed to: • integrating environmental management into all aspects of our business, including the entire product life cycle; • complying with all applicable legislation and other requirement to which Impala subscribes; • practising responsible stewardship by adopting world class standards; • proactively identifying and managing significant environmental aspects in order to: o minimise emissions to atmosphere; o minimise the release of effluent; o optimise resource consumption; o mitigate our impacts on climate change; o minimise waste; o rehabilitate disturbed land and protect environmental biodiversity; and o protect cultural heritage resources. • ensuring environmental awareness and appropriate competency among employees and promoting environmental awareness in the community; • engaging with all I&APs towards the shared goal of improving the environment; and • setting objectives and, where possible, quantitative targets, to determine continual improvement in environmental performance and the prevention of pollution.

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STEPS TO ACHIEVE THE ENVIRONMENTAL POLICY OBJECTIVES Impala’s environmental policy will be realised by setting specific and measurable objectives. It is proposed that new objectives are set throughout the life of mine, but initial objectives are as follows: • management of environmental responsibilities: o Impala will establish and appoint Managers at senior mine management level at each site, who will be provided with all necessary resources to carry out the management of all environmental aspects of the site irrespective of other responsibilities, for example: ▪ compliance with environmental legislation and EMPr commitments; ▪ implementing and maintaining an environmental management system with the assistance of the appointed EMS Area Coordinator and the Area Waste Coordinator; ▪ developing environmental emergency response procedures and coordinating personnel during incidents; ▪ manage routine environmental monitoring and data interpretation; ▪ environmental trouble shooting and implementation of remediation strategies; and ▪ closure planning. • communication of environmental issues and information: o meetings, consultations and progress reviews will be carried out, and specifically Impala will: ▪ set the discussion of environmental issues and feedback on environmental projects as an agenda item at all company board meetings; ▪ provide progress reports on the achievement of policy objectives and level of compliance with the approved EMPr to the Department of Minerals Resources; ▪ ensure environmental issues are raised at monthly mine management executive committee meetings and all relevant mine wide meetings at all levels; and ▪ ensure environmental issues are discussed at all general liaison meetings with local communities and other interested and affected parties. • environmental awareness training: o Impala will provide environmental awareness training to individuals at a level of detail specific to the requirements of their job, but will generally comprise: ▪ basic awareness training for all prior to granting access to site (e.g. short video presentation requiring registration once completed). Employees and contractors who have not attended the training will not be allowed on site; ▪ general environmental awareness training will be given to all employees and contractors as part of the Safety, Health and Environment induction programme. All non-Impala personnel who will be on site for more than three days must undergo the SHE induction training; and ▪ specific environmental awareness training will be provided to personnel whose work activities can have a significant impact on the environment (e.g. workshops, waste handling and disposal, sanitation, etc.). • review and update the environmental topics already identified in the EMPr which currently includes the following purpose o topography (hazardous excavations); o soil and land capability management (loss of soil resource); o management of biodiversity;

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o surface water management (alteration of surface drainage and pollution of surface water); o groundwater management (reduction in groundwater levels/availability and groundwater contamination); o management of air quality (dust generation); o noise (specifically management of disturbing noise); o visual aspects (reduction of negative visual impacts); o surrounding land use (traffic management, blast management, land use loss); o heritage resources (management of sites); and o socio-economic impacts (management of positive and negative impacts). • all mine projects will be designed to minimise impact on the environment and to accomplish closure/rehabilitation objectives; and • Impala will maintain records of all environmental training, monitoring, incidents, corrective actions and reports.

TRAINING OBJECTIVES OF THE ENVIRONMENTAL AWARENESS PLAN The environmental awareness plan ensures that training needs are identified, and that appropriate training is provided. The environmental awareness plan should communicate: • the importance of conformance with the environmental policy, procedures and other requirements of good environmental management; • the significant environmental impacts and risks of individuals work activities and explain the environmental benefits of improved performance; • individuals roles and responsibilities in achieving the aims and objectives of the environmental policy; and • the potential consequences of not complying with environmental procedures.

GENERAL CONTENTS OF THE ENVIRONMENTAL AWARENESS PLAN To achieve the objectives of the environmental awareness, plan the general contents of the training plans are as follows: • module 1 – Basic training plan applicable to all personnel entering the site: o Short (15 min) presentation to indicate the site layout and activities at specific business units together with their environmental aspects and potential impacts; and o Individuals to sign off with site security on completion in order to gain access to the site. • module 2 – General training plan applicable to all personnel at the site for longer than 3 days: o general understanding of the environmental setting of the mine (e.g. local communities and industries and proximity to natural resources such as rivers); o understanding the environmental impact of individuals activities on site (e.g. excessive production of waste, poor housekeeping, energy consumption, water use, noise, etc.); o indicate potential site-specific environmental aspects and their impacts; o Impala’s environmental management strategy; o identifying poor environmental management and stopping work which presents significant risks; o reporting incidents;

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o examples of poor environmental management and environmental incidents; and o procedures for emergency response and cleaning up minor leaks and spills. • module 3 – Specific training plan: o environmental setting of the workplace (e.g. proximity of watercourses, vulnerability of groundwater, proximity of local communities and industries, etc.); o specific environmental aspects such as: ▪ spillage of hydrocarbons at workshops; ▪ spillage of explosive liquids in the open pits; ▪ poor waste management such as mixing hazardous and general wastes, inappropriate storage and stockpiling large amounts of waste; ▪ poor housekeeping practices; ▪ poor working practices (e.g. not carrying out oil changes in designated bunded areas); ▪ excessive noise generation and unnecessary use of hooters; and ▪ protection of heritage resources (including palaeontological resources). • impact of environmental aspects, for example: o hydrocarbon contamination resulting in loss of resource (soil, water) to downstream users; o groundwater contamination also resulting in loss of resource due to potential adverse aesthetic, taste and health effects; and o dust impacts on local communities (nuisance and health implications). • Impala’s duty of care (specifically with respect to waste management); and • purpose and function of Impala’s environmental management system.

Individuals required to complete Module 3 (Specific training module) will need to complete Modules 1 and 2 first. On completion of the Module 3, individuals will be subject to a short test (written or verbal) to ensure the level of competence has been achieved. Individuals who fail the test will be allowed to re-sit the test after further training by the training department.

The actual contents of the training modules will be developed based on a training needs analysis. Key personnel will be required to undergo formal, external environmental management training (e.g. how to operate the environmental management system, waste management and legal compliance). In addition to the above Impala will: • conduct refresher training/presentations on environmental issues for mine employees (permanent and contractors) at regular intervals; • promote environmental awareness using relevant environmental topic posters displayed at strategic locations on the mine. These topics will be changed monthly, and will be reviewed annually by the Environmental Department Manager to ensure relevance; and • participate and organise events which promote environmental awareness, some of which will be tied to national initiatives e.g. National Arbour Week, World Environment Day and National Water Week.

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MANNER IN WHICH RISKS WILL BE DEALT WITH TO AVOID POLLUTION OR DEGRADATION

ON-GOING MONITORING AND MANAGEMENT ACTIONS The monitoring programme as described in Section 28 will be undertaken to provide early warning systems necessary to avoid environmental emergencies.

PROCEDURES IN CASE OF ENVIRONMENTAL EMERGENCIES Emergency procedures apply to incidents that are unexpected and that may be sudden, and which lead to serious danger to employees/contractors, the public and/or potentially serious pollution of, or detriment to the environment (immediate and delayed). Procedures to be followed in case of environmental emergencies are described in the table below.

General emergency procedure The general procedure that should be followed in the event of all emergency situations is as follows. • applicable incident controller defined in emergency plans must be notified of an incident upon discovery; • area to be cordoned off to prevent unauthorised access and tampering of evidence; • undertake actions defined in emergency plant to limit/contain the impact of the emergency • if residue facilities/dams, stormwater diversions, etc., are partially or totally failing and this cannot be prevented, the emergency siren is to be sounded (nearest one available). After hours the Operations Engineer on shift must be notified; • take photographs and samples as necessary to assist in investigation; • report the incident immediately to the environmental department for emergencies involving environmental impacts or to the safely department in the case of injury; • the Environment department must comply with Section 30 of the NEMA such that: o the environment department must immediately notify of the relevant departments of; ▪ the nature of the incident; ▪ any risks posed to public health, safety and property; ▪ the toxicity of the substances or by-products released by the incident; and ▪ any steps taken to avoid or minimise the effects of the incident on public health and the environment. • the environment department must as soon as is practical after the incident: o take all reasonable measures to contain and minimise the effects of the incident including its effects on the environment and any risks posed by the incident to the health, safety and property of persons; o undertake clean up procedures; o remedy the effects of the incident; and o assess the immediate and long-term effects of the incident (environment and public health); o within 14 days the Environment department must report to the Director-General DHSWS and DEFF, the provincial head of DEFF, the regional manager of the DMRE, the head of the local and district municipality, the head of the regional DHSWS office such information as is available to enable an initial evaluation of the incident, including: ▪ the nature of the incident;

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▪ the substances involved and an estimation of the quantity released; ▪ the possible acute effects of the substances on the persons and the environment (including the data needed to assess these effects); ▪ initial measures taken to minimise the impacts; ▪ causes of the incident, whether direct or indirect, including equipment, technology, system or management failure; and ▪ measures taken to avoid a recurrence of the incident.

Identification of emergency situations The Proposed project specific emergency situations that have been identified together with specific emergency response procedures are outlined in Table 29-1.

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TABLE 29-1: EMERGENCY RESPONSE PROCEDURES

Item Emergency Response in addition to general procedures 1 Discharge of dirty water to the Apply the principals listed for Item 1 above. environment To stop spillage from the dirty water system the mine will: • redirect excess water to other dirty water facilities where possible; • pump dirty water to available containment in the clean water system, where there is no capacity in the dirty water system; • carry out an emergency discharge of clean water and redirect the spillage to the emptied facility; and • apply for emergency discharge as a last resort. 2 Burst water pipes (loss of resource • Notify authority responsible for the pipeline (if not mine responsibility). and erosion) • Shut off the water flowing through the damaged area and repair the damage. • Apply the principals listed for Item 1 above if spill is from the dirty/process water circuit. 3 Falling into hazardous excavations • Personnel discovering the fallen individual or animal must mobilise the emergency response team to the location of the incident and provide a general appraisal of the situation (e.g. human or animal, conscious or unconscious, etc.). • The injured party should be recovered by trained professionals such as the mine emergency response team. • A doctor (or appropriate medical practitioner)/ambulance should be present at the scene to provide first aid and transport individual to hospital. 4 Road traffic accidents (on site) • The individual discovering the accident (be it bystander or able casualty) must raise the alarm giving the location of the incident. Able personnel at the scene should shut down vehicles where it is safe to do so. • Access to the area should be restricted and access roads cleared for the emergency response team. • Vehicles must be made safe first by trained professionals (e.g. crushed or overturned vehicles). • Casualties will be moved to safety by trained professionals and provided with medical assistance. • Medical centres in the vicinity with appropriate medical capabilities will be notified if multiple seriously injured casualties are expected. • A nearby vet should be consulted in the case of animal injury.

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TECHNICAL, MANAGEMENT AND FINANCIAL OPTIONS Technical, management and financial options that will be put into place to deal with the remediation of impacts in cases of environmental emergencies are described below: • the applicant will appoint a competent management team with the appropriate skills to develop and manage a mine of this scale and nature; • to prevent the occurrence of emergency situations, the mine will implement as a minimum the mine plan and mitigation measures as included in this EIA and EMPr report; • the mine has an environmental management system in place where all operation identify, report, investigate, address and close out environmental incidents; • as part of its annual budget, the mine will allow a contingency for handling of any risks identified and/or emergency situations; and • where required, the mine will seek input from appropriately qualified people.

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SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY The following documents will be submitted to the DMRE from the start of construction until mine closure: • as noted in Section 28.1, an environmental audit report, prepared by an independent person, will be submitted to the DMRE at intervals as indicated in the environmental authorisation. The purpose of the environmental audit report is to ensure compliance with the conditions of the environmental authorisation and the EMP; and • the financial provision will be updated on an annual basis and submitted to the DMRE.

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UNDERTAKING I, Reinett Mogotshi the Environmental Assessment Practitioner responsible for compiling this EMPr, undertake that: • the information provided herein is correct; • comments and inputs from stakeholders and I&APs have been included and correctly recorded in this report; • inputs and recommendations from the specialist reports have been included where relevant; and • any information provided to I&APs and any responses to comments or inputs made is correct or was correct at that time.

Unsigned draft for public review Signature of EAP Date

Unsigned draft for public review Signature of commissioner of oath Date

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REFERENCES

Airshed. (2019). Atmospheric Impact Report in support of the National Minimum Emission Standard postponement application.

Airshed. (2020). Air Quality Specialist Report for the Proposed Increase of the Flash Dryer Capacity and Associated Feed Circuit Modifications at the Impala Rustenburg Smelter Complex.

Bojanala Platinum District Municipality. Bojanala 2020/2021 Review IDP.

Department of Water and Sanitation. (2011). Catchments of South Africa - quaternary [Data set]. Department of Water and Sanitation. https://doi.org/10.15493/SARVA.DWS.10000003

Earth Science Solutions. (2011). Impala Platinum Mine Pedological And Land Capability Studies Consolidated Project.

Metago. (2007). Environmental Impact Assessment and environmental management programme amendment for the smelter expansion project. Report number I001-05-2.

Metago. (2011). Groundwater study for the reclamation of the Tailings Storage Facility No. 1 & 2, Metago Water Geosciences.

Mucina, L., & Rutherford, M. C. (2006). The Vegetation of South Africa, Lesotho and Swaziland. South African National Biodiversity Institute.

Naidoo, K. (2018). Impala Platinum Mine November 2018 Monthly Dust Deposition Report, Reference No. EN086 38.873 M_IMP, Status: Amended. Johannesburg: SGS.

North West Department: Finance. (2018). Estimates of Provincial Revenue and Expenditure 2018/19.

North West University. (2010). Biodiversity Study of the Impala-Bafokeng Mining Complex.

Parsons, R. (1995). A South African Aquifer System Management Classification: Prepared for Water Research Commission and Department of Water Affairs and Forestry. Issue 95 of WRC report.

Pistorius, J. (2011). A survey and assessment of heritage resources and proposing the implementation of a cultural heritage management program in the impala platinum limited (Implats) mine lease area in the Rustenburg (Bafokeng) district in the north-west province.

Siyazi. (2020). Traffic Impact Assessment: Proposed New Flash Dryer to Be Installed at the Existing Impala Smelter Situated in Rustenburg, North West Province.

SLR. (2012). Environmental Impact Assessment and Environmental Management Programme Consolidation

SRK. (1997). Impala Bafokeng Mining Complex (IBMC) Environmental Management Programme Report. Report number 206741.

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