SECTION 24G ENVIRONMENTAL IMPACT ASSESSMENT REPORT FOR THE MAMATWAN MINE AVAILABLE FOR PUBLIC REVIEW SUBMITTED FOR ENVIRONMENTAL AUTHORISATION IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (ACT 107 OF 1998), AS AMENDED IN RESPECT OF A SECTION 24G RECTIFICATION PROCESS FOR LISTED ACTIVITIES THAT COMMENCED WITHOUT ENVIRONMENTAL AUTHORISATION NAME OF APPLICANT: HOTAZEL MANGANESE MINES (PTY) LTD TEL NO: 053 742 2300 FAX NO: 086 664 8458 POSTAL ADDRESS: PO BOX 61820, MARSHALLTOWN, 2107 PHYSICAL ADDRESS: 1 PEPERBOOM AVENUE, HOTAZEL, 8490 FILE REFERENCE NUMBER SAMRAD: NC00170MR102 SLR Project No.: 720.19136.000002 Report No.: 1 Revision No.: 1 August 2020 South32 SLR Project No.: 720.19136.00002 Section 24G Environmental Impact Assessment Report for Mamatwan Mine August 2020 DOCUMENT INFORMATION Title Section 24G Environmental Impact Assessment Report for the Mamatwan Mine Project Manager Natasha Smyth Project Manager Email [email protected] Author Natasha Smyth Reviewer Rob Hounsome Keywords MMT, Manganese, South32, Section 24G Status Final for review and comment DEA Reference N/A DMR Reference To be provided DWS Reference N/A Report No. 1 SLR Company SLR Consulting (South Africa) (Pty) Ltd REPORT COMPILATION REPORT COMPILED BY: Natasha Smyth REPORT REVIEWED BY: Rob Hounsome ………………………………………………… ………………………………………………… Natasha Smyth Rob Hounsome Environmental Assessment Practitioner Reviewer One REPORT REVIEWED BY: Alex Pheiffer ………………………………………………… Alex Pheiffer Reviewer Two 2020-07-31-S24G-Mamatwan-Final for public review South32 SLR Project No.: 720.19136.00002 Section 24G Environmental Impact Assessment Report for Mamatwan Mine August 2020 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 South32 for part or all of the services it has been appointed by South32 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 South32. 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 South32 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 South32 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. 2020-07-31-S24G-Mamatwan-Final for public review South32 SLR Project No.: 720.19136.00002 Section 24G Environmental Impact Assessment Report for Mamatwan Mine August 2020 EXECUTIVE SUMMARY PROJECT BACKGROUND Hotazel Manganese Mines (Pty) Ltd (HMM) operates the South32 opencast manganese mine known as the Mamatwan Mine (MMT). MMT is located approximately 25km to the south of the town Hotazel in the John Taolo Gaetsewe District Municipality and Joe Morolong Local Municipality of the Northern Cape Province of South Africa. MMT holds the following environmental permits and authorisations: • A Mining right (Reference number: NC 256 MR) issued and approved by the former Department of Minerals and Energy (DME) (currently the Department of Mineral Resources (DMR)) in May 2006; • An Environmental Management Programme Report (EMPr) (Reference number: NC 6/2/2/118) issued and approved by the former DME (currently the DMR) in November 2005; • An amended Atmospheric Emissions Licence (AEL) (Licence number: NC/AEL/JTG/MAM01/2012) issued by the Northern Cape Department of Environment and Nature Conservation (DENC) in March 2020. • An amended Integrated Water Use Licence (IWUL) (License number: 10/D41K/AGJ/1537) issued by the Department of Water and Sanitation (DWS) in January 2012 and amended in 2017; • An Environmental Authorisation (Reference number: NC/KGA/HOT3/07) for bulk fuel storage issued by former Department of Tourism, Environment and Conservation (currently DENC) in July 2007; and • An Environmental Authorisation (Reference number: NC 30/5/1/2/3/2 (252) MR for the merging of the Mamatwan Sinterfontein Waste Rock Dump (WRD) with the Tshipi Eastern WRD from the DMR in January 2020. Certain activities at the MMT commenced without environmental authorisation in terms of the National Environmental Management Act (No. 107 of 1998) (NEMA), as amended, and the National Environmental Management: Waste Act (No. 59 of 2008) (NEM:WA), as amended. These activities include the establishment of the North Eastern (NE) topsoil stockpile and the use of Adams pit for the disposal of general waste (including rubble and used conveyor belts) and the storage of sinter de-dust. Under the NEMA, the unlawful commencement of both NEMA and NEM:WA listed activities may be authorised through an application for rectification made in terms of Section 24G of the NEMA. SLR Consulting (South Africa) (Pty) Ltd (SLR), an independent firm of Environmental Assessment Practitioners (EAP), has been appointed by South32 to manage the Section 24G rectification process. SUMMARY OF AUTHORISATION REQUIREMENTS Environmental authorisation is requested from the DMR for the following activities: • The establishment of the NE topsoil stockpile in terms of NEMA (refer to Section 4.1 for further detail pertaining to the relevant listed activity); • The use of Adams pit for the disposal of general waste (including rubble and used conveyor belts) in terms of NEM:WA (refer to Section 4.1 for further detail pertaining to the relevant listed activity); and • The use of Adams pit for the storage of sinter de-dust in terms of NEMA (refer to Section 4.1 for further detail pertaining to the relevant listed activity). 2020-07-31-S24G-Mamatwan-Final for public review South32 SLR Project No.: 720.19136.00002 Section 24G Environmental Impact Assessment Report for Mamatwan Mine August 2020 It is important to note that the storage of sinter de-dust into Adams pit also requires a WUL in accordance with the National Water Act (No. 36 of 1998) (NWA) in terms of Section 21(g): Disposal of waste in a manner that may detrimentally impact on the environment. This will be managed as part of a separate process with the DWS. This Environmental Impact Assessment Report (EIAR) does not cover occupational health and safety legislation requirements. PURPOSE OF THIS EIAR The EIAR has been compiled and distributed for review and comment as part of a Section 24G rectification process that is being undertaken for the MMT. This EIAR: • Provides a description of the activities that commenced without authorisation and the affected environment; • Summarises the rectification process followed to date; and • Identifies and assesses the key impacts and presents management and mitigation measures to manage/limit impacts arising from the activities. SUMMARY OF THE PUBLIC PARTICIPATION PROCESS The public participation process commenced prior to the submission of the EIAR and will continue throughout the Section 24G rectification process. To date, commenting authorities and Interested and Affected Parties (I&APs) have been given the opportunity to review the Background Information Document (BID), to attend a public meeting and to submit questions and comments to the project team. Due to the COVID-19 Lockdown, the public participation process in support of the proposed project was put on hold on 27 March 2020. On 05 June 2020, the Department of Environment, Forestry and Fisheries (DEFF) issued Government Notice (GN) 650, providing direction on how to proceed with licensing processes and public participation processes. In this, regard, the distribution of the EIAR in support of the proposed project can now be made available for public review as per GN 650. In this regard, the following is noted in GN 650: • Reports may not be made available at any public places or premises closed to the public; and • Hard copies or electronic versions of reports may be made accessible through any of the following non- exhaustive list of methods: websites, Zero Data Portals, community or traditional authorities, Cloud Based Services, provided that all registered I&APs have access to the reports. Taking the above into consideration this EIAR is available for a 30-day calendar day comment period from 04 August 2020 until 07 September 2020 in order to provide I&APs with an opportunity to comment on any aspect of the project and the findings of the Section 24G rectification process. Copies of the full report will be made available on the SLR website (at https://slrconsulting.com/public-documents). 2020-07-31-S24G-Mamatwan-Final for public review South32 SLR Project No.: 720.19136.00002 Section 24G Environmental Impact Assessment Report for Mamatwan Mine August 2020 SLR Consulting (South Africa) (Pty) Ltd Attention: Natasha Smyth PO Box 1596, Cramerview 2060 (if using post please call SLR to notify us of your submission) Tel: (011) 467 0945 Fax: (011) 467 0978 E-mail: [email protected] IMPACTS AND MANAGEMENT ACTIONS This section provides a summary of the assessment of the potential impacts of the project and provides measures to prevent and/or mitigate the impacts. Potential biophysical and socio-economic impacts were identified by SLR, specialists (where relevant) and stakeholders.