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Annexure 6

COMPREHENSIVE ROAD TRANSPORT PLAN IRON ORE MINE

PREPARED BY

PO BOX: D189, GABLES, EZULWENI,

ON BEHALF OF THE LIQUIDATOR, FOR SG IRON ORE MINING PTY LTD

IN VIEW OR RESCUSITATING THE NGWENYA IRON ORE MINE BY

VUKA LILANGA MINERALS PTY LTD PO BOX: N5519, MBABANE, ESWATINI Email: [email protected] URL: www.vukalilanga.com

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Table of Contents

Table of Contents ...... 2 List of Figures ...... 2 List of Tables ...... 2 INTRODUCTION ...... 3 TRANSPORATION PLAN ...... 3 Transport Chain ...... 3 Road Transportation ...... 3 Rail Transportation...... 3 OPERATIONS ...... 4 Distance...... 4 No of trucks for the proposed operations ...... 4 Working hours & other operational issues ...... 5 Road Safety ...... 5 TRANSPORT IMPACT ASSESSMENT & MITIGATION MEASURES ...... 6 DEMERIT POINT SYSTEM ...... 8 ...... 9

List of Figures

Figure 1: Transportation Chain ...... 3 Figure 2: Consultation Letter given to Min of Public Works & Transportation ...... 9

List of Tables

Table 1: Requirement of Trucks Calculation ...... 4 Table 2: Impacts due to transportation and mitigation measures ...... 6 Table 3: Demerit Points for Bad Driving ...... 8

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INTRODUCTION

The Road Transportation and Mitigation plan is developed as a document in consultation with Ministry of Public Works and Transport (Fig 2) and The Royal Eswatini Police (Traffic) (Annex 7) that the proponent will effectively implement and adhere to for the transportation of its product from the mine to Sidvokodvo Rail by trucks and from then by rail to the port. The document outlines the appropriate mitigation measures and serves as a tool for implementation and monitoring purposes.

TRANSPORATION PLAN

Transport Chain

Mine Rail Port Buyer Head Siding Head

Figure 1: Transportation Chain

Road Transportation

Meanwhile the revival of the railway line is proposed to run within 36 months from the start of mining operations as expressed by the Swaziland Railway department, the proponent opts to carry on with the logistics operations from mine to Sidvokodvo Rail by trucks. The product would be transported from mine to Sidvokodvo rail siding by trucks using the MR3 and MR9 highway roads. The distance that will be travelled by the trucks ferrying the product from the mine to Sidvokodvo Rail Siding is 76 km.

Rail Transportation The iron ore shall be ferried from Sidvokodvo by rail to port in . In this context Vuka Lilanga has approached for entering into commercial agreements where the agreements reached to a stage for signing. Eswatini Rail will provide the necessary wagons in

COMPREHENSIVE ROAD TRANSPORT PLAN | Ngwenya Iron Ore Mine 4

coordination with CFM (Mozambique Rail and Ports) and the Matola terminal will be used as discharging point.

The proponent has consulted with Swaziland Railway for exploring possibilities to rehabilitate the rail line from Kadake to as proposed in the Malagwane Commission report. Swaziland Railway line has shown a positive expression of interest provided the mining operations are confirmed with a life span more than 20 years.

OPERATIONS

Distance Distance from mine to railway siding is 76kms making the total distance to be covered by each truck per trip to and fro to be 152 kms.

No of trucks for the proposed operations The proposed operations are planned with a production capacity of 100,000 metric tons per month considering the road carrying capacity anticipated. It is estimated to use 20 trucks in operation and 5 trucks as spare totalling to 25 trucks. The detailed calculations are tabulated as under:

Table 1: Requirement of Trucks Calculation

# Description Units No of Units

INPUTS

1 Tonnage to be handled per annum @ 100,000 tons/month Tons 1,200,000

2 Tonnage to be handled per day in 360 days Tons 3,334

3 Tonnage permissible per truck Tons 34

4 Maximum speed allowed for a truck (Avg speed is 60 kmph) Km/h 70

5 In 24 hr operation maximum number of trips a truck could No 9.6 make. (152 km / 60 kmph = 2.5 hrs)

OPERATION PLAN

1 No of trips required to ferry 3,334 tons per day @ 34 t/truck No 98

2 Maximum trips per truck per day allowed as a policy No 5

3 No of trucks required per day (98/5) No 20

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Working hours & other operational issues As a standard operational procedure and giving top priority to the safety and fatigue of the employee two drivers per truck is mandatory. The drivers can work on long shifts each comprises of 12 hrs of duty. The shift changing hours are during the peak hours of traffic which is 6 am to 8 am and 5 pm to 7 pm. This will ensure the minimum number of trucks on road during the peak hours as during the shift changing time the trucks are mandatorily go for preventive maintenance checks and refuelling.

Road Safety To ensure road safety the following procedures and precautionary measures are envisaged: • Periodical Maintenance - all the trucks at the mine head will go under regular preventive maintenance during the shift changing hours. • The proponent will be supplying diesel to the truck operators which will ensure the quality of fuel and oils used for the truck. In light of above Engen has already provided letter of support to supply fuel to the company. (See Annexure for Letter of Intent from Engen). • The first shift truck drivers will take the truck to the maintenance bay at the end of each shift and the second driver will be collecting the truck from the maintenance bay at the start of his shift. • To minimize the impact on the road traffic, the project proponent proposed a sealed down production of 1.2 million tons in comparison with full scale operations of 2 million tons per annum which is anticipated after rehabilitating the railway line from Kadake to Matsapha (See Annexure for LOI from Eswatini Railway). However, the first-year target of 1.2 million tons could not be achieved due to the refurbishment and recommissioning of the plants. • To ensure road safety by taking precautionary measures to eliminate and minimize risks of accident, the project proponent proposes the following measures in line with recommendations made by the “Report of the Commission of Enquiry to Investigate the Road Accident of the 29Th April 2014 along the MR3 Freeway at Malagwane Hill pursuant to Legal Notice No 66 of 2014 :

o Shall engage the trucks that are equipped with Advanced Breaking Systems. o Proponent expressed their willingness to support Roads Department for the maintenance of the roads if required to the best possible extent as they are Gazetted Public Roads for which proponent is in consultations with the department. o In co-ordination with Traffic department of Eswatini will develop and implement safe operating procedures for the truck operators ferrying its product. o Will ensure the use of GPS Tracking for its fleet monitoring, coupled with RFID technology for time stamping on the waybills with fixed travel time. o To reduce the traffic congestion during the peak hours of traffic (morning & evening) ensure the rescheduling at source points itself. o Ensure the carrying load of each truck as per the statutory permitted axle load. o Ensure the operators are working as per the statutory hours by imposing strict vigilance over the transport operators.

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TRANSPORT IMPACT ASSESSMENT & MITIGATION MEASURES

The environmental and other impacts associated with the transportation activities and their mitigation measures are tabulated as under: Table 2: Impacts due to transportation and mitigation measures

IMPACT ACTIVITY MITIGATION MEASURES

Dust  Dust arising during the  The product is processed by wet process hence the moisture of the product prevents from any arising. transport of ore and spillage  Ensure covering of all trucks with tarpaulin immediately after loading product. of product.  All the tyres of trucks will be washed at the wash bay before entering the highway.

Accidents due  Over speeding  Will ensure that only qualified drivers operate the trucks. to driver’s  Driving under the influence of  All the drivers deployed by the contractors will undergo refresher trainings on road safety and toolbox talk negligence alcohol will be conducted by the safety department.  Reckless driving / Using  Will ensure that Safe Operating Procedures (SOP) will be followed strictly. mobile phone while driving  All drivers would adhere to the maximum permissible speed @70 Km/h.  All the trucks would be fitted with GPS tracking system to monitor their vehicles.  A response unit of the company will be present on the roads, who will be equipped with speed guns to monitor the truck drivers along the route and issue tickets for violation of road laws according to the demerit point system of company.  All the trucks leaving the mine will be time stamped before leaving the mine with the permissible time by which it can reach the rail siding. If the truck reaches earlier than the prescribed time interval the driver will be penalised according the demerit point system.  All the drivers will be checked using breathe analysers before the start and end of their shift. They will also be checked through spontaneous inspections during the cause of their shifts. Drivers found guilty will be penalised according to the demerit point system.

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IMPACT ACTIVITY MITIGATION MEASURES

 No driver will be allowed to use a mobile phone while driving the truck. Any driver found guilty will be penalised according to the demerit point system. Accidents due  Loading more tonnage than  All the trucks will be weighed at the weigh bridge installed at the mine to ensure compliance to to toppling of the permissible limit permissible limit. truck  All the trucks will be given a weight ticket bearing the weight of the load before leaving the mine, which will be authenticated by the truck’s supervisor at the mine. Accidents due  Age of truck  As per company policy and as per recommendations of the “Report of the Commission of Enquiry to to the condition  Condition of truck Investigate the Road Accident of the 29Th April 2014 along the MR3 Freeway at Malagwane Hill pursuant of truck to Legal Notice No 66 of 2014” trucks with age more than 5 years will not be used in the mine operations.  This will ensure that the trucks used are in good condition.  All the trucks will undergo periodical and preventive maintenance. Accidents at  Due to high disc  The disc temperatures of the trucks will be checked before coming down the hill at the Cooling station the Malagwane temperatures of trucks and established by the Royal Eswatini Police on MR3. This will be done through cooperation between the Hill due to the gradient of the hill Royal Eswatini Police and proponent representative.  Trucks with disc temperatures with more than the permissible levels will be allowed to cool down before going down the hill. Accidents and  Spillage of product material  An emergency response unit will be established by the proponent which will monitor and manage such Emergency on the road due to toppling of situations in coordination with the relevant authorities. Situations truck in cases of accidents.

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DEMERIT POINT SYSTEM

A Transport response unit will be established by the company to monitor the road transportation network and the following demerit point system is developed to serve as basis for penalising for violations committed by the truck drivers. The demerit points against the offences is listed in the Table 3 below. Table 3: Demerit Points for Bad Driving

Demerit Offences Committed Points 1. Exceeding Speed limit for the vehicle: a. By 1 to 20 kmph 2 b. By 21 to 30 kmph 3 c. By 31 to 40 kmph 4 2. Disobeying traffic direction of police officer or employee of Authority or security 3 officer engaged in regulating traffic. 3. Failing to give way to oncoming traffic at controlled junction 2 4. Failing to give way at uncontrolled junction 2 5. Failing to give way at junction 2 6. Overtaking another vehicle where prohibited and/or recklessly 3 7. Conveying load not properly secured and or without tarpaulin 4 8. Crossing road divider 2 9. Driving on the shoulder of the highway 3 10. Using tyres with ply or cord carcass exposed 3 11. Driver failing to wear seatbelt 3 12. Obstructing flow of traffic 4 13. Forming up incorrectly when turning left or right 4 14. Failing to give way to ambulance, fire brigade or police vehicle 4 15. Driving against the flow of traffic as indicated by the traffic signs 4 16. Driving without due care or reasonable consideration for other road users 4 17. Failing to conform to traffic light signals 4 18. Careless driving 6 19. Carrying unauthorized passengers 6 20. Reckless or dangerous driving 9 21. Parking abreast of another vehicle 3 22. Parking within a pedestrian crossing 3 23. Stopping on the shoulder or verge of the roadway 3 24. Stopping in a zebra-controlled area 3 25. Driver failing to ensure that every passenger wears a seat belt 3 26. Parking or stopping in a No parking zone 3 27. Use of mobile telephone while driving 12 28. Driving under the influence of alcohol 15

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 Once a driver accrues 15 demerit points in a calendar year, the truck driver will be suspended for two weeks from work.  The maximum permissible demerit points that can be accrued in 12 working months is 24. Once a driver reaches 24 points his/her services from the company will be terminated with immediate effect.  The demerit points will become 0 after every 12 working months and but change in behaviour of drivers will also be assessed.

Figure 2: Consultation Letter given to Min of Public Works & Transportation

COMPREHENSIVE ROAD TRANSPORT PLAN | Ngwenya Iron Ore Mine