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Waterberg Jv Resources (Pty) Ltd DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME SUBMITTED FOR ENVIRONMENTAL AUTHORISATION AND A WASTE MANAGEMENT LICENCE 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 AN APPLICATION IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT (ACT 28 OF 2002) (AS AMENDED) FOR THE PROPOSED WATERBERG PROJECT WATERBERG JV RESOURCES (PTY) LTD LP 30/5/1/2/2 /2/10161MR July 2019 _______________________________________________________________________________ Prepared by: Bateleur Environmental & Monitoring Services Cell: 082 338 6607 PO Box 70706 Fax: 086 619 3120 Die Wilgers E-mail: [email protected] 0041 IMPORTANT NOTICE In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as amended) ("MPRDA"), the Minister must grant a prospecting or mining right if, among others, the mining “will not result in unacceptable pollution, ecological degradation or damage to the environment”. Unless an Environmental Authorization can be granted following the evaluation of an Environmental Impact Assessment and an Environmental Management Programme report in terms of the National Environmental Management Act, Act 107 of 1998) ("NEMA"), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological degradation or damage to the environment. In terms of Regulation 16(3)(b) of the 2014 EIA Regulations , any report submitted as part of an application must be prepared in a format that may be determined by the Competent Authority ("CA") and, in terms of Regulation 17(1)(c), the CA must check whether the application has taken into account any minimum requirements applicable or instructions or guidance provided by the CA to the submission of applications. It is therefore an instruction that the prescribed reports required in terms of applications for an environmental authorisation ("EA") for mining and related activities are submitted in the exact format and provide all the information required in terms of this template. Furthermore, please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the Regulation and will lead to the EA being refused. It is furthermore an instruction that the Environmental Assessment Practitioner ("EAP") must process and interpret his/her research and analysis and use the findings thereof to compile the information required herein. Unprocessed supporting information may be attached as appendices. The EAP must ensure that the information required is placed correctly in the relevant sections of the Report, in the order, and under the provided headings, as set out below, and ensure that the Report is not cluttered with uninterpreted information and that it unambiguously represents the interpretation of the Applicant. 2 OBJECTIVES OF THE ENVIRONMENAL IMPACT ASSESSMENT PROCESS The objective of the Environmental Impact Assessment ("EIA") process is to, through a consultative process – a) determine the policy and legislative context within which the activity is located and document how the proposed activity complies with and responds to the policy and legislative context; b) describe the need and desirability of the proposed activity, including the need and desirability of the activity in the context of the preferred location; c) identify the location of the development footprint within the preferred site based on an impact and risk assessment process, inclusive of cumulative impacts, and a ranking process of all the identified development footprint alternatives focusing on geographical, physical, biological, social, economic, heritage and cultural aspects of the environment; d) determine the – I. nature, significance, consequence, extent, duration and probability of the impacts occurring to inform identified preferred alternatives; and II. degree to which these impacts – can be reversed; may cause irreplaceable loss of resources; and can be avoided, managed or mitigated; e) identify the most ideal location for the activity within the preferred site based on the lowest level of environmental sensitivity identified during the assessment; f) identify, assess, and rank the impacts the activity will impose on the preferred location through the life of the activity; g) identify suitable measures to manage, avoid or mitigate identified impacts; and h) identify residual risks that need to be managed and monitored. 3 EXECUTIVE SUMMARY Background Platinum Group Metals RSA Proprietary Limited ("PTM RSA"), a registered South African company and a subsidiary of Platinum Group Metals Ltd (Canada) ("PTM") was granted nine prospecting rights over various properties located in the Waterberg area in the Limpopo Province, in terms of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) ("MPRDA") by the Department of Mineral Resources ("DMR") for prospecting rights (the "Prospecting Rights"). PTM RSA then subsequently entered into an agreement with Waterberg JV Resources Proprietary Limited ("Waterberg JVCo" or the "Applicant"), PTM, Mnombo Wethu Consultants Proprietary Limited ("Mnombo") and Japan Oil, Gas and Metals National Corporation ("JOGMEC"), in terms of which all the Prospecting Rights held by PTM RSA would be ceded to Waterberg JVCo. The Minister of Mineral Resources (Minerals Minister) duly granted consent in terms of section 11(1) of the MPRDA to transfer the Prospecting Rights held by PTM RSA to Waterberg JVCo. On 16 October 2017 agreements were concluded between Waterberg JVCo, PTM RSA, PTM, Mnombo, JOGMEC and Impala Platinum Holdings Limited ("Implats"), whereby Implats: (i) purchased shares in Waterberg JVCo, representing a 15% interest in the Waterberg Project from PTM RSA and JOGMEC; (ii) acquired an option to increase its stake in Waterberg JVCo to 50.1%, through additional share purchases and earn-in arrangements; and (iii) acquired a right of first refusal to smelt and refine Waterberg Project concentrate. The now ceded Prospecting Rights have been included in the shareholders agreement, executed by the shareholders of Waterberg JVCo on 16 October 2017. Waterberg JVCo intends to undertake mining on the properties held (or previously held) under some of the Prospecting Rights, in particular: LP 30/5/1/1/2/10667PR; LP 30/5/1/1/2/10809 PR; LP 30/5/1/1/2/1265 PR renewed under LP 30/1/12/11013 PR; and LP 30/5/1/1/2/10804 PR, and construct associated infrastructure required for the mining activities (the "Waterberg Project"). PTM RSA will manage the Waterberg Project on behalf of Waterberg JVCo and its shareholders. The Waterberg represents a large-scale platinum group metal ("PTM") resource with an attractive risk profile, given its shallow nature. The Waterberg Project will facilitate fully mechanised production, with the potential to have amongst the lowest operating costs in the PGM sector. The Waterberg Project will be particularly focused on palladium. 4 The area to be mined is situated on Rosamund 357 LR, Disseldorp 369 LR (Disseldorp), Millstream 358 LR, Ketting 368 LR (Ketting), Portion 1 of Goedetrouw 366 LR (Goedetrouw) (once registered)1, Goedetrouw 366, Early Dawn 361 LR (Early Dawn), Old Langsine 360 LR, Langbryde 324 LR, Lomondside 323 LR, within the Northern Limb of the Bushveld Complex in the Limpopo Province (Mine Area). The mining associated surface infrastructure for the Waterberg Project ("Surface Infrastructure") will be limited to only a few properties ("Surface Infrastructure Area"). Portion 1 of Goedetrouw (once registered), Goedetrouw; a portion of Disseldorp and Ketting have been identified as Surface Infrastructure Alternative 1 (as contained in Appendix 1). The surface infrastructure positioned on Ketting, Early Dawn and Disseldorp only is refered to as Surface Infrastructure Alternative 2. The alternative position for the TSF is located on the farm Norma and is refered to as TSF Alternative 2. Surface Infrastructure Alternative 1 and 2 were assessed during the Environmental Impact Assessment ("EIA") Report ("EIAR") and will be presented and considered during the public participation process ("PPP")). It is also proposed that an existing construction camp on Portions 12 of Harriets Wish 393 LR (Harriets Wish) will be expanded onto Portions 10, 13 and 14 Harriets Wish, for use during the construction phase of the Waterberg Project ("Construction Camp Area"). The Construction Camp Area, Mine Area and Surface Infrastructure Area are collectively referred to as the "Project Area". Three mining alternatives were considered. The mining alternative that has been identified as the preferred option at present, being the South Complex with a Portal accessing the T Zone and F South Zone and a Portal accessing the F Central Zone. This complex will be producing (RoM) 4.8 Mtpa until depleted with the North Complex accessing the F North and F Boundary replacing the depleted production. This production rate indicates a Life of Mine of 45 years, the worked out areas remaining open to harvest water inflows for the purpose of water supply to the mine, In addition to this water supply a 6.2 Ml/d extended wellfield will also be utilised for the water demand. ("Preferred Mining Alternative"). If the Preferred Mining Alternative is selected, the Waterberg Project will initially site the underground workings on the farms Ketting for the Tailings
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