DRAFT SCOPING REPORT FOR LISTED ACTIVITIES ASSOCIATED WITH MINING RIGHT: SECTION 102 APPLICATION FOR AMENDMENT OF THE MINING WORK PROGRAM AND CONCURRENT EMP AMENDMENT/UPDATE IN TERMS OF REGULATION 29 OF NEMA

Lower Mines under LOR-D

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

NAME OF APPLICANT: Lower Orange River Diamonds (Pty) Ltd TEL NO: 073 063 0553 (Enviro. Manager: Jamie Ambrosini) 073 255 7915 (PA: Marina in Stellenbosch) EMAIL [email protected] [email protected] POSTAL ADDRESS: P.O Box 31, Stellenbosch PHYSICAL ADDRESS: Block B, 1st floor, De Wagenweg Office Park, Stellentia Street, Stellenbosch, 7600 FILE REFERENCE NUMBER SAMRAD (LOR-D): NC……………………….. EARLIER THG MR REFERENCE NUMBER: NCS-30/5/1/3/3/1(531) MR

September 2020 Report #: 2798/MR-S102/DSR

DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

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IMPORTANT NOTICE In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as amended), 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 Authorisation 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 section 16(3)(b) of the EIA Regulations, 2014, any report submitted as part of an application must be prepared in a format that may be determined by the Competent Authority and in terms of section 17 (1) (c) the competent Authority must check whether the application has taken into account any minimum requirements applicable or instructions or guidance provided by the competent authority to the submission of applications.

It is therefore an instruction that: the prescribed reports required in respect of applications for an environmental authorisation for listed activities triggered by an application for a right or permit are submitted in the exact format of, 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 Environmental Authorisation being refused.

It is furthermore an instruction that: The Environmental Assessment Practitioner 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 un-interpreted information and that it unambiguously represents the interpretation of the applicant.

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Table of Contents 0 PREFACE to the Amendment/Update Lower Orange River Mine EMP ...... 12 1 DETAILS OF THE APPLICANT ...... 15 2 ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) ...... 15 3 PROJECT DESCRIPTION ...... 15 4 SCOPE OF OVERALL ACTIVITIES ...... 18 4.1 Overall Mining Right area perspective ...... 18 4.1.1 Geological background informing mining ...... 18 4.2 Earlier and continued uses ...... 26 4.2.1 Infrastructure: Existing, demolish/rehabilitate or continued use of each ...... 28 4.2.2 Mining: overview of mined to date and planned mining ...... 42 4.3 Methodologies and facilities ...... 42 4.3.1 The Mining and Ore processing cycle: ...... 42 4.3.2 Rehabilitation methodology (refer rehabilitation methods and costings in Annexure C) 45 4.3.3 Other methodologies ...... 49 4.4 Planned mining (the LOR-D Mine Plan) ...... 49 4.4.1 Mine planning on JV geographical area allocation basis...... 49 4.4.2 Rehabilitation liability in the context of JV contracts with LOR-D/Plateaux diamonds on the basis of allocated geographic areas ...... 51 4.4.3 Provisional Overall Mine Plan refer Figure 9 ...... 51 4.4.4 Provisional detail planning per JV Geographic areas and general plant layout ...... 53 4.5 Agriculture as a rehabilitation method and future economic base with existing water use allocation and an integral part of the Post Mining Use ...... 56 4.6 Post Mining Land Use Plan ...... 56 5 LISTED AND SPECIFIED ACTIVITIES (TOWARDS TABLE) ...... 59 6 Description of activities to be undertaken ...... 64 7 Policy and legislative context ...... 64 8 Need and desirability (N&D)of the proposed activities ...... 64 8.1 Cumulative impact assessment ...... 66 9 Period for which the environmental authorisation is required ...... 66 10 Description of the process followed to reach the proposed preferred site ...... 66 11 Details of all alternatives considered...... 66 11.1 Option of not implementing the activity...... 67 12 Details of the Public Participation Process Followed ...... 67 13 The Environmental attributes associated with the site: BASELINE ENVIRONMENT ...... 77 Type of environment affected by the proposed activity ...... 77 13.1 Climate ...... 78

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13.1.1 Regional climate ...... 78 13.1.2 Precipitation ...... 78 13.1.3 Rainfall intensity ...... 78 13.1.4 Temperature ...... 79 13.1.5 Wind ...... 79 13.1.6 Evaporation ...... 79 13.1.7 Incidence of Extreme Weather ...... 80 13.2 Geology ...... 80 13.3 Topography ...... 80 13.4 Soils ...... 83 13.4.1 Irrigability / Fertility of Soils ...... 87 13.4.2 Erodability ...... 87 13.4.3 Preservation/Reconstitution of soils suitable for commercial irrigation agriculture ... 87 13.5 Natural Vegetation ...... 89 13.5.1 Regional vegetation ...... 89 13.5.2 The botanical focus of the 2020 update ...... 93 13.6 Animal life ...... 99 13.6.1 Amphibians and Reptiles...... 99 13.6.2 Conclusion on Animal Life ...... 102 13.7 Surface water ...... 103 13.7.1 Surface water characteristics ...... 103 13.7.2 Surface Water Quality ...... 106 13.7.3 Drainage Density ...... 107 13.7.4 Minimising the risk of post mining silt discharge into the Orange River ...... 107 13.7.5 Consideration of the existing water license ...... 111 13.8 Groundwater ...... 111 13.9 Air Quality ...... 112 13.10 Noise ...... 112 13.11 Sites of Archaeological and cultural interest ...... 113 13.11.1 Specialist reports ...... 113 13.11.2 Archaeological sites ...... 113 13.11.3 Elements of Archaeological interest ...... 116 13.11.4 Damage to sites between 2001 and 2020 ...... 117 13.12 Sensitive Landscapes ...... 117 13.13 Visual Aspects ...... 120 13.14 Land Capability ...... 124 13.15 Land Use ...... 124

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13.16 Regional Socio-economic Structure ...... 125 13.16.1 Regional socio economic context of the lease area is shown in Figure 2 and the table below to reflect the following: ...... 125 13.16.2 Economic Activities of the Region ...... 126 13.16.3 Unemployment ...... 126 13.16.4 Housing ...... 126 13.16.5 Social Infrastructure (see photos BT2 and RO7) ...... 126 13.16.6 Water supply (Domestic) ...... 126 13.16.7 Power Supply ...... 128 14 Overall site environmental features ...... 129 14.1 Description of infrastructure and specific environmental features on the site ...... 129 14.2 Environmental and current land use map ...... 129 15 Impacts identified...... 129 16 Methodology used in determining the significance of environmental impacts ...... 151 17 The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected...... 152 18 The possible mitigation measures that could be applied and the level of risk...... 152 19 The outcome of the site selection Matrix. Final Site Layout Plan ...... 153 20 Motivation where no alternative sites were considered ...... 153 21 Statement motivating the preferred site ...... 153 22 Plan of study for the Environmental Impact Assessment process ...... 153 22.1 Description of alternatives to be considered including the option of not going ahead with the activity ...... 153 22.2 Description of the aspects to be assessed as part of the environmental impact assessment process ...... 154 22.3 Description of aspects to be assessed by specialists ...... 158 22.4 Proposed method of assessing the environmental aspects including the proposed method of assessing alternatives ...... 158 22.5 The proposed method of assessing duration and significance ...... 158 22.6 The stages at which the competent authority will be consulted ...... 159 22.7 Particulars of the public participation process with regard to the Impact Assessment process that will be conducted ...... 159 22.7.1 Steps to be taken to notify interested and affected parties ...... 159 22.7.2 Details of the engagement process to be followed...... 159 22.7.3 Description of the information to be provided to Interested and Affected Parties. .. 160 22.8 Description of the tasks that will be undertaken during the environmental impact assessment (EIA) process...... 160 22.9 Measures to avoid, reverse, mitigate, or manage identified impacts and to determine the extent of the residual risks that need to be managed and monitored ...... 160 23 Other Information required by the competent Authority ...... 168 6 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

23.1 Compliance with the provisions of sections 24(4)(a) & (b) read with section 24(3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998). The EIA report must include the:- 168 23.1.1 Impact on the socio-economic conditions of any directly affected person...... 168 23.1.2 Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act...... 168 24 Other matters required in terms of sections 24(4)(a) and (b) of the Act...... 169 25 UNDERTAKING REGARDING CORRECTNESS OF INFORMATION ...... 169 26 UNDERTAKING REGARDING LEVEL OF AGREEMENT ...... 169

List of Figures (2020) Figure 1: Locality Plan ...... 16 Figure 2: Regulation 2 (2) Sketch Plan ...... 17 Figure 3: Geology Plan ...... 19 Figure 4: Geological and Historical Mining Informants to Overall Mine Planning...... 25 Figure 5: Baken Town ...... 29 Figure 6: Reuning Town ...... 32 Figure 7: Main existing roads serving the mining area ...... 35 Figure 8: Overall JV Geographic Area Identification/Allocation Feb 2020 ...... 50 Figure 9: Provisional Overall Mine Plan (Early 2020) (for detail JV Mine Plans refer Annexure F Figures JVMP 1 to 11) ...... 52 Figure 10: Post Mining Land Use...... 58 Figure 11: Vegetation classification of Mucina and Rutherford (2012) with GPS track and established JV Plants superimposed ...... 90 Figure 12: CBA Classification map ...... 93

List of Figures from the 2015 approved EMP contained as Figures A-x Figure A-3: Mining Lease, Regional Topography, Drainage and Electrical grid..…(Para 13.3a) Figure A-5: Geology, soils, topography, drainage and Archaeology…………(Para 13.11.2) Figure A-6: Geology, Soils, Topography, Drainage and Archaeology (Baken-)….(Para 13.4)

List of Diagrams Diagram 0: Sketch plans of the mining areas …………………………………….……………………………………………14 Diagram 1: Proto/Meso Terrace Occurrence ...... 20 Diagram 2: Schematic distribution of Eskom supply ...... 39 Diagram 3a: Plant Layout ...... 44 Diagram 3b: Plant Layout (no Pan) ...... 44 Diagram 4: Pro-forma detailed mine plan for a typical JV Geographic Area example for Nxodap ...... 53 Diagram 5: Regional Context ...... 57 Diagram 6: Lateral distinction in environmental attribute descriptions ...... 77 Diagram 7: Windroses and monthly temperature and rainfall presentation ...... 80 Diagram 8: Irrigation Erven on Swartwater Lower Terrace ...... 88 Diagram 9: Meso terrace limitations e.g Xharries Terrace Bloeddrif ...... 96 Diagram 10: Baken Perimeter Dump Channel Diversion to avoid dump-toe erosion and Orange River siltation ...... 109 Diagram 11: Typical cross-section where proto gravel horse-shoe channel is present ...... 111

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List of Photos Photo 1: Baken Proto Mega trench ...... 22 Photo 2: Typical Meso terrace with prospecting excavation in foreground Xarries North ...... 22 Photo 3: Prospecting Trench through the erosion remnant of the Jakkalsberg East Meso terrace .... 22 Photo 4: Prospecting trench through the erosion remnant of one of the southern Aace Meso terraces ...... 22 Photo 5: Swartwater coarse tailings dumps ...... 24 Photo 6: Baken central coarse tailings dumps ...... 24 Photo 7: Bloeddrif coarse tailings dump ...... 24 Photo 8: Reuning coarse tailings dumps ...... 24 Photo 9: Aace coarse tailings dumps ...... 24 Photo 10a: Lower Orange River mine office block with clinic, restaurant and hall ...... 30 Photo 10b: Employee Hostels ...... 30 Photo 10c: Baken Private shop, workshops and filling station ...... 30 Photo 10e: Typical Baken House ...... 30 Photo 10d: Contractor Hostel camp ...... 30 Photo 11a: Sendelingsdrift international border Pont ...... 33 Photo 11b: Ex THG office block used by border-post State Departments...... 33 Photo 11c: Ex THG club now used as Richtersveld National Park visitor reception and offices ...... 33 Photo 11d: National Parks Board nursery and camp sites ...... 33 Photo 11e: National Parks Board chalet complex ...... 33 Photo 11f: Numerous National Parks Board Built Houses in southern Reuning Town ...... 33 Photo 11g: Typical Reuning Mine House ...... 33 Photo 11h: Reuning hostel in town ...... 33 Photo 12: Baken Potable water purification ...... 36 Photo 13: Reuning Potable water purification ...... 37 Photo 14: Baken Magazine ...... 42 Photo 15:In-pit mobile screening plant, screening oversize as waste and loading haul trucks with Ore sized gravel fraction for feed into the JVs Pan Plant ...... 44 Photo 16:One of the JV twin Pan Plants seen at Xharries North ...... 44 Photo 17: Bourevestnik Final Recovery container fed with pan plant concentrate ...... 44 Photo 18: Magnificent unspoiled scenery ...... 46 Photo 19: Coast tailings dump mimicking a natural " Pebble Deflation Surface" showing germination of in-blown-seed ...... 47 Photo 20: The stoney desert environment ...... 48 Photo 21: Pebble deflation surface of the Meso-terraces (adjacent to a Meso Terrace prospecting trench) ...... 48 Photo 22: Re-used and upgraded THG facilities at Nxodap (old plant removed) ...... 55 Photo 23: Intake hopper and sand plant ...... 55 Photo 24: Bourevestnik Final Recovery (blue) and Pan Plants ...... 55 Photo 25: Proposed sump area in old excavation floor for tailings backfill ...... 55 Photo 26: Petroglyphs at the Annis river road side dermacating the edge of the Annis River Orange River riaprian vegetation zone ...... 91 Photo 27: Mature riparian vegetation zone with Salix Mucronata; Road to Nxodap ...... 91 Photo 28: Black Ebony (Euclea pseudbenus) at Baken Picnic area copper loading cliff ...... 92 Photo 29: Black Ebony and Shepard’s Trees (Boscia albitrunca) on Hennies Terrace ...... 92 Photo 30: Typical Meso Terrace seen at Xharries North ...... 96 Photo 31: Remnants of 1974 silt bank ...... 105

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Photo 32: Baken excavation perimeter berm preventing stormwater entering excavation during mining. Berm to be removed to permit free flow of natural silt laden stormwater into the dished excavation backfill to serve as silt trap in post mining ...... 108 Photo 33: Directing of BCP slimes to Baken Deep-channel backfill areas ...... 110 Photo 34: Previous Jakkelsberg slimes dams possibly subject to 1:50 or 1:100 flood erosion of its walls. Coarse tailings dump to right for armouring of wall by bund protection (refer Diagram below) ...... 110 Photo 35: Magnificent unspoiled scenery seen from the main access road to Reuning ...... 118 Photo 36: The stoney desert environment seen from Jakkalsberg ...... 118 Photo 37: Spectacular river scenery between Jakkalsberg and Nxodap ...... 119 Photo 38: Spectacular northward views along river from Hennies Terrace ...... 119 Photo 39: Spectacular northward views of the distant Namibian mountains from Balcony of the Reuning Club (SANSParks office) ...... 119 Photo 40: Baken remaining deep prospecting trench ...... 120 Photo 41: View of the Baken Central Plant not visible despite size ...... 120 Photo 42: Rounded overburden dumps along the Alexander Bay – road ...... 121 Photo 43: Mehl-South gate public visitor road to Reuning FRP ...... 121 Photo 44: Scenic Hennies Terrace ...... 122 Photo 45: Flat topped gravel terrace deposits ...... 122 Photo 46: Rounded or jiggered skyline backdrop to mining operations ...... 123 Photo 47: Natural Cobble deflation surface Baken lower terrace ...... 123 Photo 48: Powerline impact on main tourism route into the Park ...... 124

List of Annexures NOTE: In the annexures attached which are largely earlier reporting under THG which must be reconsidered and reviewed, the Annexure A, B, ………. Are SPC annexure numbers for 2020 EMP report but the numbering in each Annexure is the original paragraph numbering and annexure numbering used in the source documents copied into this 2020 set of annexures.

Annexure A: CV and Declaration of EAP Annexure B: Chronological history of the EMP documentation of LOR Mine Annexure C: Rehabilitation methodologies Annexure D: Water discussion with Figure W-1 Annexure D1: Copy of 2017 Water License (No.: 10/D82L/ABCGIJ/5161) Annexure D3: Orange River Water Quality lab results from 2001 and 2003 Annexure D-4: Analysis of perched groundwater from Baken Palaeo channel excavation Annexure E: Solid Waste Management E-1: Existing licenced Domestic Waste Disposal Sites at Baken and Reuning (to be retained post-mining). E-2: Proposed Asbestos Waste Disposal (Burial) Site for LOR-D LOR operations rehabilitation asbestos waste generation. E-3: Proposed Burial Sites for Builders Rubble. Annexure F: Detailed mine plans per JV area (Figures JVMP 1-11) Annexure G: Processing plants past present and future Annexure H1: Stream channel diversions Annexure H2: E-TEK surface water investigation Annexure J: Sample of questionnaire entitled Table of JV Activities/Facilities per Geographic area Annexure K: Copy of correspondence sent in I&AP process Annexure L: Copies of correspondence received in I&AP process Annexure M: Induction training manual Annexure N: Hydrocarbon management protocol Annexure O: List of plant species and certain findings on the regional botany by Jurgens. Annexure P: Factors in reviewing the 1:100yr floodline Annexure Q1: A Phase One Archaeological Assessment (Pg 1 to 47) 9 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Annexure Q2: Follow up report on Archaeological excavations on the Orange River floodplain between Jakkalsberg and Sendelingsdrift Annexure R: Plan Record of Land Uses and Mine Plans from 2009 EMP Annexure S: Specialist study by Soil and Irrigation directorate of Department of Agriculture Technical Services 1979: NGBReport 912/143/79 (full report awaited at 1 Sept 2020)

List of Abbreviations ADT Articulated Dump Trucks EMP Environmental Management Program EIA Environmental Impact Assessment EAR Environmental Audit Report EAP Environmental Assessment Practitioner I&APs Interested and Affected Parties JV Joint Venture JVMP Joint Venture Mine Plan LOR Lower Orange River LOR-D Lower Orange River Diamonds (Pty) Ltd MWP Mining Work Program NC Ngl Natural Ground Level NPB National Parks Board OR Orange River SPC Site Plan Consulting THG Transhex Group ROM Run of Mine

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OBJECTIVES OF THE SCOPING PROCESS The objective of the scoping process is to, through a consultative process— a) identify the relevant policies and legislation relevant to the activity; b) motivate 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 and confirm the preferred activity and technology alternatives through an impact and risk assessment and ranking process; d) identify and confirm the preferred site, through a detailed site selection process, which includes an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all the identified alternatives focusing on the geographical, physical, biological, social, economic, and cultural aspects of the environment; e) identify the key issues to be addressed in the assessment phase; (f) agree on the level of assessment to be undertaken, including the methodology to be applied, the expertise required as well as the extent of further consultation to be undertaken to determine the impacts and risks the activity will impose on the preferred site through the life of the activity, including the nature, significance, consequence, extent, duration and probability of the impacts to inform the location of the development footprint within the preferred site; and f) Identify suitable measures to avoid, manage, or mitigate identified impacts and to determine the extent of the residual risks that need to be managed and monitored

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0 PREFACE to the Amendment/Update Lower Orange River Mine EMP Lower Orange River Diamonds (LOR-D) having been ceded the Mining Right by Trans Hex Group (THG) is now the Holder of the Right in coordination with its operational company Plateaux Diamonds (Pty) Ltd who engages with numerous Joint Venture (JV) Companies who conduct the mining operations of the Right.

Accordingly, the Mining Right has the same area and definition of Rights as previously held by Trans Hex Group (THG).

The change of ownership with new company structure and the following fundamental changes at LOR Mine require an Amendment/Update of the EMP:  A general shift of mining emphasis from Proto to Meso terraces,  An emphasis on reprocessing mine residue dumps (coarse and fine tailings of THG); and  Amongst others a new approach to processing plants from existing large central fixed Dense Medium Separation (DMS) ferrosilicon plants to dispersed in-field pan-type or direct recovery Bourevestnik (Diagram 3) semi-mobile processing plants to match the redefined target reserve distribution and the management structure of LOR-D/Plateaux Diamonds (Pty) Ltd with Joint Venture (JV) partners (not a central THG operation).

Accordingly, during December 2019, LOR-D accepted the quotation and job schedule submitted and appointed Site Plan Consulting (SPC) to conduct an EMP update/revision of the Lower Orange River Mine for LOR-Diamonds (Pty) Ltd.

Given the variations across the vast area, the nature of ore deposits, variation in grades, environmental settings and processing options, a pragmatic approach (refer para 4.3.3 a)) is taken to such large alluvial diamond mine EMPs on the Orange River and the West Coast.

This EMP Amendment/Update is now initiated through LOR-D/Plateaux Diamonds and Joint Venture Partners in: i. Formally redefining the target reserves (sizes and distribution). ii. Defining the new management structure through Joint Venture Partners and their individual “geographic areas” of operation/reserve targets within the LOR-D Mining Right area. iii. Mine Plans of each JV in consultation with LOR-D’s technical staff (Mine Engineer, Geologist and Surveyor) developing a Mine Plan within each respective Geographic Area. iv. Defining the nature of each JV’s processing plants and the management of process water, tailings from such plants operational rehabilitation and mainly mobile logistical facilities required in such plant areas. v. Updating the LOR Mining Work Program (MWP) within the above considerations (under separate cover). vi. Definition of the decommissioning of remaining main THG plants and their plant area rehabilitation requirements.

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vii. Applying the 2015 approved EMP and in this transition period:  seeking inclusion of the pending 28 February 2018 addendum of THG LOR EMP update/Amendments of elements such as:  Definition of closure objectives.  Decommissioning and post mining use of slimes dams.  Post mining use of the urban mining towns of Reuning and Baken and;  Considering planning and operations in review of the guidelines and principles contained in the THG Stage II Final Towards Closure Process Report SPC # 2582 Final Stage II Report 13 Feb 2018 which was a document which considered the LOR Mine future as a whole in THG context but contains may fundamental considerations for LOR-D. viii. Liaison National Parks Board (NPB). ix. Introducing the concept by which existing mine water availability can progressively be set aside for agriculture, planned towards being a significant post-mining land use, economic base, employer and a base for retention of the town functions through eventually using the current mining water for commercial agriculture on a large-scale as evidenced elsewhere along the Orange River. This Section 102 EMP Amendement/Update serves to develop a new EMP encompassing all the known base-line informants, spatial determinants of the Mining Right area and the changes required in management thereof within the new LOR-D framework. (As background, the chronological history of the EMP documents is contained in Annexure B).

PLEASE STATE TYPE OF AUTHORISATIONS BEING APPLIED FOR.

Mark with APPLICATION TYPE APPLICABLE FEE an X where applicable NEMA S&EIR application on its own R10 000.00 NEMA BAR application on its own R 2 000.00 NEMWA S&EIR application on its own R10 000.00 NEMWA BAR application on its own R 2 000.00 NEMA S&EIR application combined with NEMWA S&EIR application R 15 000.00 X NEMA BAR application combined with NEMWA BAR application R 3 000.00 NEMA S&EIR application combined with NEMWA BAR application R 11 000.00

Firstly, the reader’s attention is drawn to the fact the 2009 and 2015 Approved EMPs were contained in 3 text volumes split between the:  Northern Reuning Mine  Central Bloeddrif Mine, and the  Southern Baken Mine. In this 2020 EMP, the documentation is no longer split on such 3 way administrative basis.

Notwithstanding that the document is not split between the 3 sub-mine areas, the plans below (Diagram 0) are retained as they reflect very useful references to local areas names which will be used throughout the EMP. 13 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Diagram 0: Sketch plans of the mining areas

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1 DETAILS OF THE APPLICANT Project applicant: Lower Orange River Diamonds (Pty) Ltd Registration no (if any): 2006/023/721/07 Trading name (if any): LOR Diamonds Responsible Person, Director: Chris Kimber (e.g. Director, CEO, etc).: Contact person: At Baken Mine: Johan van Rooyen (PA: Carly Hugo: 076 435 7981) Physical address: Block B, 1st floor, De Wagenweg Office Park, Stellentia Street, Stellenbosch, 7600 Postal address: P.O Box 31, Stellenbosch Postal code: 7600 Cell 073 255 7915 (PA: Marina) Telephone:Stellenbosch Fax E-mail: GM: [email protected]

2 ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

EAP: Site Plan Consulting Contact Person: Stephen van der Westhuizen and Siphumelelo Mbali Company: Site Plan Consulting Physical address: Shop 5, Goede Hoop Shopping Centre, Broadway Blvd, Strand Postal address: PO Box 28, Strand Postal code: 7139 Cell 082 554 8163 Telephone: 021 854 4260 Fax 021 854 4321 E-mail: [email protected] Cell: 062 920 2525

3 PROJECT DESCRIPTION

Farm Name: Farm Richterveld No. 11 Rem. and Ptn of Farm 18 described by the Mineral Lease Area Application area (Ha) 41 343.4340 ha Magisterial district: RD (T8521/1979CTN.) Distance and direction from nearest town: Some 15km west of Kuboes Town 21 digit Surveyor General Code for each Farm 11 Rem.: C05300000000001100000 farm portion: Locality map Refer Figure 1 Description of the overall activity. (Indicate Mining Right, Mining Permit, Section 102 Application in terms of MPRDA: Prospecting right, Bulk Sampling, Production Amendment of Mining Work Program and existing Right, Exploration Right, Reconnaisance permit, Technical co-operation permit, Additional listed EMP activity)

See Figure 1 Locality Plan and Figure 2: Regulation 2 (2) Sketch Plan overleaf

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Figure 1: Locality Plan

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Figure 2: Regulation 2 (2) Sketch Plan

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4 SCOPE OF OVERALL ACTIVITIES

4.1 Overall Mining Right area perspective The Mining Right area of LOR reflects mining over the past 50 years which included initial prospecting and small scale mining by others and subsequent increase to very extensive mining by THG together with extensive infrastructure systems and the two mine towns of Baken and Reuning. Additionally, the non-mining proclaimed town of Sanddrift exists near Baken within the Mining Right area.

Furthermore, in the north, the Mining Right area is now located within the subsequently proclaimed Ai-Ais Richtersveld Transfrontier Park and the mining town of Reuning accommodates significant housing, tourist accomodation facilities, offices of the Richtersveld National Park administration and of the Sendelingsdrift pont international border post, customs and police offices.

4.1.1 Geological background informing mining This geological description is given as background to the new LOR-D, Plateaux Diamonds and JV management and staff and I&APs, the Mine Plan and Mining Work Program (MWP) and focuses on the reader gaining an understanding of what controls the origin and distribution of diamonds in the gravels of LOR.

The overriding factors include the following: i. Alluvial nature of the deposits’ minor relationship to bedrock. Considering the fact that the diamonds relate closer to geomorphological conditions at the time of deposition in terms of the high flow nature of the paleo Orange River with significant erosional capabilities and interspersed deposition during the earlier Proto deposition cycle and a less aggressive erosional character in the second (Meso) wave of deposition, paleo geomorphology is the overriding factor.

ii. 2 eras of deposition namely:  Proto era (20 million years ago)  Meso era (4 million years ago) While the geological lithology (types of rocks and structurers) are shown in Figure 3 Geology Plan (overleaf), the overriding control over diamond deposition, distribution and grade, is a factor of the river flow characteristics, erosion and deposition with a clear distinction between the Proto and Meso eras at the time and their channels and terraces.

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Figure 3: Geology Plan

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The Proto terraces (channels) shown in blue in the inset plan Diagram 1 below are the remnants of the extremely large rapid flowing early Orange River which cut a deep channel (up to 60m) while meandering around erosion resistant rock types with broad meanders. The diagram below shows the remnants of such meanders occurring on the RSA (southern side) of the current Orange River channel.

Diagram 1: Proto/Meso Terrace Occurrence

The Meso terraces shown in yellow by comparison which formed only 4 million years ago were deposited in such later river course which was much straighter than that of the proto era and had largely established the current Orange River course over such 16 million year period.

In terms of deposition conditions and their relationship with diamond grades, it is important to distinguish:

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 The Proto deposits as largely being a main channel eroded up to 60m deep and characterised by variable floor levels, rapids, waterfalls with plunge pools in well-defined channel directions compared to;  The Meso deposits by distinction, formed in slower flowing meandering braided stream channels in broad river courses. Given such braided/meandering nature, grades do not follow a single main channel but rather various individual channels of the braided system with less continuity in the grade being mined at any time. This braided channel complexity also therefore significantly complicates prospecting often resulting in an approach to conduct monitoring daily yield during mining as the most reliable method of prospecting (directing the mining advance on a daily/weekly basis).

Of significance is that most of the Proto deposits have been mined to date from the large; Baken mega trench, the Xheis area, the B1 and B2 Bloeddrif Loops, and the vast Reuning Central Area and smaller remnants of Proto terraces on the higher slopes of Xharries North, Nxodap, Jakkalsberg, Mehl and Aace.

By comparison seen in yellow in the diagram above, the Meso terraces occur as regular re-occurring broad terraces to the immediate east of the Orange River channel where the alluvial River-Terrace gravels occur as described in the published geological sheet highlighted in green in Figure 3 Geology Plan only marginally set back from the current Orange River channel which bank consists of recent alluvial sands and has no diamond grade. In the individual JV Mine Plans Figures JVMP 1-JVMP 11 as contained in Annexure F, the target alluvial terraces are readily identifiable from most Google EarthTM images.

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Photo 1: Baken Proto Mega trench

Photo 2: Typical Meso terrace with prospecting excavation in foreground Xarries North

Photo 4: Prospecting trench through the erosion remnant of one of the southern Aace Meso terraces

Photo 3: Prospecting Trench through the erosion remnant of the Jakkalsberg East Meso terrace

The extent of the Meso terraces is shown in individual detail in Figures in the various JV Mine Plans JVMP1-JVMP11 in Annexure F and in Figure 9 Overall Mine Plan. With respect to bedrock, the only relevance it has in mining is in the consideration of the nature of its surface on which the basal diamondiferous gravels now occur. Such bedrock surface presents the following considerations: 22 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

i. Erosional form of the river bed at time of deposition either as:  Potholes and plunge pools concentrating diamond deposition; or  Saw toothed inclined layered rock presenting traps for diamond capture; and ii. The weathered nature of the present weathered bedrock determining the depth though limited to less than 1m to which deposited diamonds could, after millions of years, have penetrated the soft texture surface or cracks and crevices of the bedrock and thus determining the depth to which the basal alluvial layer with the upper basement rock below the contact must be removed to achieve maximum diamond recovery. One further geological feature affecting alluvial floor treatment is the presence of either ferrugenisation or calcretisation of the basal gravel horizon which hard pedocrete layer, where it occurs, is often well mineralised and requires ripping/drilling and blasting and crushing of such layer to release its diamonds. In light of the above and in the clear distinction between alluvial terraces/channels and basement rocks, Figure 3 Geology Plan only draws the distinction between:  Recent to Tertiary alluvials and  Basement rocks: Only with further distinction between granites and the other basement rock types in order that the miner can relate basement rock characteristics found at the bottom of alluvial excavations to the relevant rock type expected.

Geological and historical mining informants to overall mine planning (ref Figure 4) Refer Geological and historical mining inputs to Overall Mine Planning as per Figure 4 Below. Within the above background, Figure 4 reveals the types of deposits and existing coarse tailings dumps which are available for targeting by JV Mine operators to include:

23 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Photo 5: Swartwater coarse tailings dumps

Photo 6: Baken central coarse tailings dumps

Photo 7: Bloeddrif coarse tailings dump

Photo 9: Aace coarse tailings dumps

Photo 8: Reuning coarse tailings dumps

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Figure 4: Geological and Historical Mining Informants to Overall Mine Planning

25 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

4.2 Earlier and continued uses Given the value of the plans prepared for the Volume V EMP of April 2009, such GIS generated plans with Google Earthtm background are retained for reference in Annexure R as Record of Land Uses and Mine Plans from 2009 EMP. As a record of the THG plants and slimes dams and their status of demolition or reuse of these in the context of the 2020 change in mining and processing, see Figure 4a below: Record of earlier THG Processing Plants at Cession.

THG plant considerations in the LOR-D Overall Mine Plan In line with the change in Corporate Structure (in para 2 hereafter) to cut overheads and production costs with emphasis on devolution of corporate management to JVs Ore (diamond gravel) processing under the LOR-D through JVs changes from THG’s Dense Medium Separation (DMS) by ferrosilicon floatation in large DMS plants to cheaper, less capital intensive and readily managed Pan and direct recovery Bourevestnik Plants which are lighter, smaller and semi-mobile.

These LOR-D JV plants allow them to be located within each JV’s Geographical area in proximity to the pits, reducing haul cost and presenting the opportunity for direct deposition of tailings in existing or new excavations reducing the cost of ADT haul and of coarse and fine tailings dump rehabilitation.

Accordingly, Figure 4a Record of earlier THG processing plants and LOR perspective identifies the THG plants which are: i. Old THG plants demolished by THG with only minor remnants remaining. ii. Large ferrosilicon DMS plants decommissioned and partly demolished some of which retaining the hopper intake end for possible new Pan Plant location. iii. Selected plants being retained to serve LOR-D as final recovery plants: . Baken Central final recovery end. . Xheis recovery plant already converted with a Bourevestnik Diamond Recovery installation. iv. The recently built THG Suidhek processing Plant of which the structural components are being retained in the new JV Plant. Given the suitability of the continued (re-use) of access roads to plants, engineering services and logistical buildings at such past sites, these past sites present localities for consideration during new LOR-D plant siting such as has occurred in the siting of the LOR-D Reuning final recovery installation at the old Reuning final recovery plant and at the Xheis ex-THG final recovery plant conversion to the new LOR-D Bourevestnik final recovery installation.

26 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Figure 4a: Record of earlier THG Processing Plants at Cession

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4.2.1 Infrastructure: Existing, demolish/rehabilitate or continued use of each

a) The towns of Reuning and Baken Both unregistered towns served as the mining towns for Transhex group and were developed entirely by and at the cost of THG and have been ceded to LOR-D and currently continue to serve as before. Baken Town (see Figure 5 overleaf);  Provides accomodation in houses and hostels for the employees of LOR-D and of the JVs with additional accomodation available in Contractor Hostels.  Baken town also accommodates the main mine offices with clinic and mine hall.  The small commercial centre accommodates the Baken general dealer shop, the private filling station and a number of service workshops for employees and visitors in car and tyre repairs etc.  Sports and recreation facilities of cricket, tennis, rugby, mini-golf and swimming pool.  Market garden.

28 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Figure 5: Baken Town

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The following photos illustrate some of the facilities of Baken Town:

Photo 10a: Lower Orange River mine office block with clinic, restaurant and hall

Photo 10b: Employee Hostels

Photo 10d: Contractor Hostel camp

Photo 10c: Baken Private shop, workshops and filling station

Photo 10e: Typical Baken House

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Reuning Town (see Figure 6 overleaf):  Provides accomodation in houses and hostels for the employees of LOR-D and of the JVs with additional accomodation available in the northern Contractor Hostels.  Accommodates houses, certain built by and others rented by National Parks Board (NPB).  Reuning town also accommodates the various offices now occupied primarily by the police, customs, Parks Board serving the international border crossing of the pont and visitor administration for the AI-AIS Richtersveld Transfrontier Park.  Offices of LOR-D.  Provides nursery, caravan park, chalet complex all built by National Parks Board.  The small commercial centre has a private shop, and filling station for visitors.  Sports and recreation facilities of swimming pool and children’s park with play furniture.  Additionally, Reuning has a large light industrial service centre with numerous workshops and stores as well as a central diesel tank and wash- bay.

31 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Figure 6: Reuning Town

32 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

The following photos illustrate some of the facilities of Reuning Town:

Photo 11a: Sendelingsdrift international border Pont Photo 11b: Ex THG office block used by border-post State Departments

Photo 11d: National Parks Board nursery and camp sites

Photo 11c: Ex THG club now used as Richtersveld National Park visitor reception and offices

Photo 11f: Numerous National Parks Board Built Houses in southern Reuning Town Photo 11e: National Parks Board chalet complex

Photo 11g: Typical Reuning Mine House

Photo 11h: Reuning hostel in town

33 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

b) Roads As shown in Figure 7, the further mining requires LOR-D to continue to use the district public roads:  (DR3246/DR 3247) between Alexander Bay and Kuboes  The public road to Reuning between the turn-off onto DR3246 past the Glory hole and on to Reuning where it gives public access to the international border crossing of the Sendelingsdrift pont to Namibia and the main access to the 4x4 routes of the park east of Reuning. As such these two routes are major routes in the Transfrontier park context and especially giving access to the Richtersveld national park component.  The Sanddrif/Baken access road. Accordingly, LOR-D will maintain involvement of the mining company in the maintenance of these public roads. Given that the LOR-D mine plan identifies all mined areas to date to be further mined at various levels, existing access roads require retention but within the mine planning of each JV Geographic Area require rationalisation especially of the multitude of lower order tracks and roads. Such rationalisation of roads is dealt with at each JV Geographic area Mine Plan level.

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Figure 7: Main existing roads serving the mining area

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c) Potable water supply Given that at Baken the mine potable water supply purification works also provides water to Sanddrif town while at Reuning the water supply to Reuning town also includes potable water for the non-mining components of national park housing, administration, camping site and chalet complex as well as other State Department occupied offices, the retention and proper maintenance and operation of the potable water treatment river pumping stations, treatment plants and supply networks must be retained and will require further retention even in post mining. i. Baken As seen in Photo 12 below, the well-developed processing plant and storage reservoirs are located on the hill behind the Baken mine security entrance facility with sufficient elevation for gravity feed. The pumping point from the river is located in Baken Town.

Photo 12: Baken Potable water purification

ii. Kuboes Within the town area of Baken an Orange River bank pump installation serves the raw water pumping line for potable water to Kuboes town on which line the purification works with green tanks. As seen in photo 12a below exist adjacent the Baken/Sandrift main access road. The works also house the booster pump station pumping the potable water to Kuboes reservoir at the town.

Photo 12a: Kuboes pipeline purification and booster pump site 36 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

iii. Reuning While a more rudimentary installation than that of Baken, the purification works with supply tanks is located along the inclined access road to the old Reuning Central Plant at suitable elevation for gravity supply as seen in photo 13 below.

Photo 13: Reuning Potable water purification

iv. Other Given that each of the JV plants with their logistical facilities of offices, stores and small workshops are the personnel centres per JV and are being equipped with personnel amenities and restroom containers/ski cabins. Each have limited potable water supply requirements which are met by small tank supply of potable water from Baken or Reuning towns on a daily or weekly basis and most have chemical toilets.

d) Process water (for detail refer Annexure D) Transhex Group in its last years of full production had established process water pumping points along the Orange River at:  Aace  Reuning (and point for Potable water)  South gate  Jakkalsberg  Nxodap  Bloeddrif  Gariep  Kuboes town pump station on Orange River in Baken with purification and booster pump outside town on pipeline to Kuboes  (Baken Town potable water)  Baken (process water)  Baken PK See Figure W-1 overleaf from Annexure D.

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Figure W-1 from Annexure D 38 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Consumption in 2009 THG use was 3 734 431m3/annum.

Water permits under THG provided for the extraction of 5 328 000 kl/year with an additional application at the time for a further 986 000 kl/year for South Gate.

Given that the JV companies are still adapting final plat set-ups during initial processing and deciding the future between the various existing pan plants and optional direct recovery Bourevestnik plants (Refer Diagrams 3a and 3b) and with the companies having or currently installing water meters with LOR-D and complete prescribed daily water use records, it will still be a few months before an LOR-D JV water balance table and diagram can be prepared but initial indication using these plants does indicate that process water consumption under the new LOR-D system will not exceed the current the license provision.

This report in its paras 4.5 and 4.6 following scoping finalisation will then finally consider irrigated commercial agriculture to eventually use the current mining water for commercial agriculture on a large-scale as evidenced elsewhere along the Orange River. e) Electrical supply The diagram below shows the post 2009 Eskom grid supply which now needs to be complemented by the new LOR-D JV 22kV lines to each JV plant once each of the JVs have finalised their Eskom line supply requirement vs possible long term reliance on diesel Gensets. An updated GIS drawing will be prepared by LOR-D survey department when sufficient finality is achieved and incorporated into the EMP update process.

Diagram 2: Historical 2009 schematic distribution of Eskom supply

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f) Domestic/General Waste disposal systems and registered sites It is noted that there are 4 registered General Waste sites serving the Mining Right area as shown and described below. Site Service area Existing Permits: No. Name Baken outside (Buite) (Xheis) site Baken town and Sanddrif with vast Baken 16/2/7/D820/C3/Z1/P414 airspace and cover material Class: G:C:B available

Baken inside (Binne) (Xheis) site Baken security area including Baken Mine General Waste Baken plant, workshops and disposal site personnel amenities for NC/NAM/RICHT/BAK/06/2012 uncontaminated waste Class: B (G:M:B) Baken Inside

Reuning Sandelingsdrift general Reuning Town including non-THG Reuning B33/2/450/16/S/P172 waste site users and uncontaminated Class: G:C:B workshop waste

Bloeddrif General waste site The disposal and temporal storage Bloeddrif Mine Waste Disposal Granted 30 October 2014 of general waste. Site: NC/NAM/RICHT/BLO/07/2012 Class: B (G:M:B) No Photo

40 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

g) Requirement for burial sites for builders rubble in demolition Given that numerous large Transhex plants, now redundant, are in the process of demolition and now and in future other plants will require burial of builders rubble from such demolitions. Consequently, in 2017 as part of a towards closure documentation for THG, the principles applicable to such builders rubble buriel sites were developed and are contained in Annexure E3 hereto which was developed with the experience gained in developing a waste model for Alexkor to manage extensive plant and building demolitions. As per Annexure E3, it deals with: 1. Demolition waste stream split 2. Basis of site provision and 3. Site Plan and photo illustration required for each builders rubble burial site at the time. h) Asbestos management within the concept of licensing an Asbestos waste disposal site The matter of asbestos waste disposal is further dealt with in Annexure E2 which motivates and describes the selection and development of a proposed asbestos landfill site on the demolished Swartwater plant site for consideration and comment by the respective authorities and I&APs seeking buy-in to the proposal whereupon detail design can be considered.

Given the enormity of the cost of transporting and disposing of waste asbestos (mainly asbestos-cement roofing “Everite Big 6” profile and cladding and prefabricated house wall panels) to Vissershok site in Cape Town, it is proposed that a central asbestos disposal (burial) site together with a management system which could be established and managed under a designated body at Baken to serve the LOR demolitions and surrounding mines and towns in meeting their asbestos disposal requirement and obviating the high cost of transport to Vissershok in Cape Town. To this end of establishing a private site for a project, Site Plan Consulting has investigated the methods adopted in Australia for establishing “Remote Asbestos Disposal sites” given their cost efficiency and functionality yet posing no threat of the site to surroundings in the long term and eliminating the extreme procedure and specifications currently applying in to the licensing of asbestos waste disposal sites further to the granting of asbestos disposal permits to other remote mines in the Northern Cape (NC). By providing a sand cover with a low percentage cement added, a completely stable and sealed structure of the backfill can be achieved with no threat of release of asbestos fibres into the atmosphere. Regarding groundwater, the asbestos fibres will pose no threat to any groundwater in the context of Baken and hence no lining of the burial site base will be required. A full BID (Basic Information Document) will be prepared for distribution to initiate the application for authorisation.

Annexure E2 further describes the project concept under the following headings: 1. Background motivation for an LOR-D site as opposed to transport to Vissershok disposal in Cape Town 1.1 Need 41 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

1.2 Cost of transport to licensed sites 1.3 The risk imposed by local disposal 2. Fundamental landfill design considerations for LOR site 2.1 Choice of site 2.2 Proposed diagrammatic site design for Swartwater plant site choice 3. Management structure 4. Way forward

i) Explosive magazines Baken, Bloeddrif, and Reuning (or detonator boxes)

Photo 14: Baken Magazine

4.2.2 Mining: overview of mined to date and planned mining As the core of continued uses is that of continued mining, paragraphs 4.3 and 4.4 deal with shifts in emphasis between THG mining to date and the focus of further mining under LOR-D.

4.3 Methodologies and facilities

4.3.1 The Mining and Ore processing cycle: In alluvial mining on large scale as will be conducted in the Meso terraces, the mining cycle for the chosen area selected as the pit area with its designated plant is as follows: i. “Topsoil” (the upper layer of 300mm of sand and gravel) is dozed to either intermediate berms or perimeter berms for later reuse to cover backfilled excavation. ii. “Overburden” (any non-mineralised horizon in the Meso terrace profile) is then stripped from the 1st phase (strip) area and either temporarily stockpiled (as a temporary overburden temporary stockpile near or adjacent to the excavation) or preferably directly loaded, hauled and tipped into a mined excavation floor as backfill (on a broad “strip mining” basis). iii. Once a slightly elevated diamond bearing gravel horizon or the final basal mineralised layer is reached, such diamondiferous (Ore) gravel horizon is excavated and loaded by excavator into Articulated Dump Trucks (ADTs) and transported to the plant intake or sent to the plant by conveyor if close. Optionally, depending on particle size distribution of the gravel, the excavated gravel will be directly loaded by excavator into the Hopper of an Infield Screening 42 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Plant which screens out oversize pebble normally +32mm diameter while depositing such oversize directly onto a strip of mined floor area as backfill. The Infield Screening Plant deposits the -32mm “ore material” into an ADT or into a conveyor hopper for conveyor transport to plant intake. iv. At the plant, the Run of Mine (ROM) gravels are dumped by the ADT or conveyor into the intake hopper of the plant which generally consists of:  A sand plant sometimes a Union Screen at which the gravel is washed and wet screened or dry screened to remove the -1.5mm sand fraction which screened fraction is fed by conveyor to join the main coarse waste conveyor as backfill to the pit either directly by conveyor or by waste return ADT.  The ore-grade fraction passes by conveyor from the sand plant to the: o Pans of the pan plant (Diagram 3a) from which a diamond concentrate is bled by screw conveyor and conveyor to the pan plant’s concentrate bin or o In the case of a non-pan direct recovery Bourevestnik plant as seen in Diagram 3b, the ore grade passes through a washing plant (drum washer to the screening plant for splitting the flow into 3 sizes in individual bins from where the concentrate is individual delivered to the containerised Bourevestnik diamond recovery (high concentrate) plant which discharges the high concentrate to boxes for their security transport to one of the final recovery plants for diamond recovery.  The non-concentrate material from the pans is collected by conveyors onto conveyors as porrel tailings either directly by conveyor or channel as waste to backfilling mined excavation. The waste material non-pan direct recovery plant is similarly either conveyed or transported by ADT to the excavation as backfill.  The concentrate of pans is discharged from the concentrate bin into either concentrate transfer containers on trucks for delivery of the concentrate to the final recovery plant or alternatively if the JV plant also has a Bourevestnik final recovery plant, such Bourevestnik leg receives the concentrate directly by enclosed conveyor, and the Bourevestnik plant processes the concentrate yielding the final concentrate in sealed boxes for transfer to one of the LOR final recovery plants while depositing small amounts of final recovery tailings for backfill in an excavation. As the plant layouts overleaf do vary from JV to JV and may in cases totally exclude the pan plant component as in Diagram 3b, where in-pit screened gravels are simply washed and sized into 3 sizes to be fed separately into the Bourevestnik plant for diamond sorting.

Fundamentally, there is no major distinction between the mining cycles of Meso and Proto terraces under LOR-D.

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Diagram 3b: Plant Layout (no Pan) Diagram 3a: Plant Layout

Photo 16:One of the JV twin Pan Plants seen at Xharries North Photo 15:In-pit mobile screening plant, screening oversize as waste and loading Photo 17: Bourevestnik Final Recovery container fed with haul trucks with Ore sized gravel fraction for feed into the JVs Pan Plant pan plant concentrate

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4.3.2 Rehabilitation methodology (refer rehabilitation methods and costings in Annexure C) a) Pragmatic approach to rehabilitation as established in EMPs Over the past 20 years, in developing rehabilitation programmes and plans for the alluvial diamond mines of the Orange River and the West-Coast in determining the level of rehabilitation to be strived for, consensus has been reached to date with the authorities that a pragmatic approach to rehabilitation is appropriate. Such appropriate level relates to a combination of the following considerations also applicable to the LOR:  Given the extent and the intrusive nature of physical disturbances on the topography by a century of West Coast alluvial diamond mining, the history and legacy of diamond mining on the Orange River and the West Coast are now an integral part of the greater Richtersveld Transfrontier area and consequently rehabilitation should concentrate on removing unnecessary blight but not attempt to totally remove the footprint nor all profiles which reflect on the mining history as in international examples of the open cast iron ore mines of Sweden where these have been preserved and play a significant positive role in tourism as does gold panning tourism in southern New Zealand.  In keeping with the MPRDA intention of rehabilitation namely that it be cost- effective, this principle of cost efficiency is applied to dealing with rehabilitation methods where given either considerations of isolation of the area concerned, starkness of the surrounding environment or the extremely high risk of failure of intervention (in this case topsoiling and grass seeding or the removal of sub-surface reinforced concrete are financially unjustified such spending could rather be committed to the socio-economic upliftment of the area). Accordingly, as an example, removing reinforced concrete footings and floors at or below ground levels is not advocated but they are rather specified to be retained and covered with coarse tailings to facilitate the area’s appearance and natural function as “pebble deflation surfaces” (stony desert surfaces) which are an integral feature of the lower Orange River/Namib area as seen in Photo 20 and 21 hereafter.

It is emphasised that in this EMP, rehabilitation is considered an integral part of mining process and schedule. Consequently, within a JV Geographical area rehabilitation of each mining block is conducted to a target of 70% completion prior to moving the mine pit to a new mine block (merely to permit on-going direct backfill during the overlap periods of initiation and final phase of a mine block).

b) General considerations It is the prescription of this EMP’s minimising dump creation and the cost saving intent of each JV to conduct direct return of coarse and fine tailings to their origin pit as direct backfill in order to maximise concurrent rehabilitation with mining. Accordingly, the gravel processing plant locality must facilitate the most optimal ore gravel delivery to the plant and delivery of coarse and fine tailings from the plant back to its proximate pit. As such, it is preferred that two or three mine blocks be identified with a central processing plant in order to continuously balance overburden stripping with ore gravel delivery to plant

45 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020 and return of overburden and coarse and fine tailings in the operational rehabilitation program concurrent with mining.

c) Meso/Proto distinctions in rehabilitation The Meso terrace mining which is the bulk of future mining of LOR-D, generally presents low to moderate overburden depth where direct backfill of overburden and tailings, if properly planned can achieve a backfilled excavation level of not more than a few meters below ngl on level terraces and easily achieved rehabilitation profile where terraces present as elevated ridges and narrow terraces such as at Aace.

The remaining mining of Proto terraces/channels is largely being undertaken in the remnant very broad channel floors where Proto terraces have already been mined to depth with limited required overburden remaining and therefore often presenting a very similar mining scenario to that of virgin Meso terraces. Of significance is that the rehabilitation of such proto terrace mining does not require rehabilitation backfill to at or near the original proto terrace/channel ground levels with such reduced level rehabilitated proto channel acting as a large interceptor of surface drainage channels draining toward the Orange River and as such serving as silt retention “ponds”/traps during any episodic rainfall episode refer para 13.7.4 under drainage baseline environmental management.

d) Rehabilitation exclusions in the desert climate (topsoils and vegetation) The overall environmental perspective is reflected by the following statements regarding consideration of the pre-mining environmental status, rehabilitation level contemplated and the principle of pragmatic approach (ref para 4.3.3a).

Photo 18: Magnificent unspoiled scenery

While forming part of the Richtersveld National Park and wilderness area with magnificent unspoiled scenery as per Photo 18, the history and legacy of diamond mining on the Orange River is now an integral part of the greater Richtersveld of both the Namibian and South African banks of the River. In light of the enormity of disturbances along the lower Orange River on both banks, rehabilitation should concentrate on removing blight from the landscape, making it safe and making it non-polluting in post-closure within the context of its barren surroundings in terms of erodibility of soils, desert climate and the futility of attempting revegetation or topsoiling normally associated with rehabilitation: 46 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

I. Given the diamond mining legacy, it is appropriate in the same way as the Kimberley Big-hole and the open cast Iron ore mines of Sweden having been preserved as part of the history of mining as proclaimed heritage sites as valuable contributors to the tourist economy. In the LOR case, a diamond mining tourist route to be considered in the Post-mining Land Use Plan in paragraph 4.6 and Figure 10 hereafter refers. II. The desert environment of the LOR eliminates the role of re-topsoiling and revegetation both of which would make no contribution despite high costs and high failure rate of attempts. In this regard, Mucina and Rutherford (2012) vegetation map as described later in para 13.5 Natural Vegetation classifies the entire area where mining disturbances have occurred and are further contemplated as Lower Western Gariep Lowland Desert and Western Gariep Hills Desert with the narrow river bank vegetation largely undisturbed in the 1:100yr floodline as Lower Gariep Alluvial Vegetation. Within this context of desert vegetation and sand storms, and the research conducted by SPC and THG in determining any role which the mobile sands forming the “surface topsoil” could play in the consideration of revegetation which revealed in respect of coarse tailings dumps that revegetation and re-topsoiling would best be achieved by employing the principles embodied in Pebble Deflation Surfaces:

 Leaving existing surfaces of coarse tailings dumps or creating coarse tailings surfaces by tipping and spreading of coarse tailings material for such pebble deflation surface to:  Provide a cool and increased moisture habitat on the underside of the upper coarse tailings pebbles where mosses are found to develop in such moist condensate micro environment as an initial biome to foster the germination of in-blown seeds as natural revegetation (refer photo 19 hereafter).

Photo 19: Coarse tailings dump mimicking a natural " Pebble Deflation Surface" showing germination of in-blown-seed

 Provide a sand trap during the high incidence of sand movement firstly to avoid mobile dune formation and secondly to become

47 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

part of the subsurface moist voids in assisting with root development during windblown seed germination. Accordingly, it is suggested that this phenomenon of Pebble Deflation Surface so apparent on meso terraces and coarse tailings dumps be proposed as a suitable rehabilitation action on otherwise barren especially plant and building demolished surfaces through the spreading of the coarse tailings as an artificial; creation of pebble deflation surfaces.

Photo 20: The stoney desert environment

III. Within the desert environment, the most successful rehabilitation method relies on the facilitation of achieving deflation surfaces through the use of pebble and coarse tailings cover(mimicking a natural stony desert appearance) (in fact exactly what is seen on the surface of many Meso-terraces of the LOR in Photo 21 below).

Photo 21: Pebble deflation surface of the Meso-terraces (adjacent to a Meso Terrace prospecting trench) IV. That the incidence of naturally occurring dust storms and the naturally high ambient dust levels mitigate the use of wind-speed reduction shade cloth netting which would otherwise be applied where wind-blown sand movement either threatens adjacent vegetation through smothering or abrasion, or would be an integral part of 48 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

managing re-topsoiled and revegetated areas (as is the case in coastal diamond mining where revegetation is a prime factor). V. Plant demolition costs must be offset by sale of plant and scrap to avoid the generation of large scrap yards. No burial of waste steel is permitted.

4.3.3 Other methodologies

Do if needed.

4.4 Planned mining (the LOR-D Mine Plan)

4.4.1 Mine planning on JV geographical area allocation basis. Within the above context of corporate structure with mining by JVs, the geographic area allocations under JVs engaged to date are shown in Figure 8 (overleaf) Overall JV (Contractor) Geographic Area Allocations Feb 2020 together with the established plants shown by green dots with respective JVs name.

The reader will note for instance, that the Baken Central geographic area in the south accommodates numerous JVs and their respective plants within the context that they have defined sub-areas of operation and their own processing plants.

Notwithstanding the Geographic Area definitions as shown in Figure 8 below, the reader must note that the area definition of Geographic Areas can be modified on ad-hoc basis subject to amongst others a change in expected resource grades. Despite such possible changes in JV engagement in the various geographic areas, the mining methods, environmental restrictions of riparian vegetation zone, bedrock hill toes interfaces and the principles of environmental rehabilitation will not change but rehabilitation liability of the JV must be amended/updated.

49 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Figure 8: Overall JV Geographic Area Identification/Allocation Feb 2020 50 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

4.4.2 Rehabilitation liability in the context of JV contracts with LOR-D/Plateaux diamonds on the basis of allocated geographic areas LOR-D as the Holder of the Right remains the legal person ultimately responsible for rehabilitation of the Lower Orange River mine.

Furthermore, the individual JVs through their JV contracts with Plateaux Diamonds must commit contractually to conduct rehabilitation of all environmental disturbances caused by them within their defined JV area. Such JV contracts must therefore also define each JVs assumed liability for any pre- contract disturbance inherited from THG activities which in 2017 were costed at R133 745 535.41 incl. VAT within the JV geographic area and where appropriate define such disturbances which will not be the responsibility of the JV but remain the liability of LOR-D/Plateaux. In instances where the JV either fails to rehabilitate its own disturbances or in the case of inherited THG disturbances excluded from the JVs liability by its contract with Plateaux, such rehabilitation liability will revert to LOR-D in terms of the MPRDA

LOR-D as the person responsible for rehabilitation must therefore ensure that:  The JV contracts cover the rehabilitation costs of all work undertaken by the JV through rehabilitation insurance in favour of LOR-D to cover any shortfalls which will revert to LOR-D  LOR-D must maintain a rehabilitation fund covering any shortfalls arising from JV rehabilitation inadequacies and THG rehabilitation liabilities which have not been covered by the total of JV contractual liabilities.

4.4.3 Provisional Overall Mine Plan refer Figure 9 Within the context of detail planning within Geographic Areas (Figure 8) being a function of each JV, the Provisional Overall Mine Plan Figure 9 hereafter shows the following: a) In respect of JV Geographic areas (Figure 8);  The geographic area boundaries  The initial (current) JV processing plant localities b) In respect of LOR-D overall planning/facilities (Figure 9):  Final Recovery Plants  Proto terrace mining  Meso terrace mining potential  Main workshop and stores complexes  General (domestic) waste disposal sites (registered)  Towns (Baken and Reuning)  Potable water purification works  Existing main roads which give adequate access to all JV Plant Installations and Geographic Areas for Mining.  (The existing electrical network and substations serving mining with 22kV extensions requiring further minor 22kV extensions during semi- mobile processing plant relocation to be added once established).

51 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Figure 9: Provisional Overall Mine Plan (Early 2020) (for detail JV Mine Plans refer Annexure F Figures JVMP 1 to 11)

52 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

4.4.4 Provisional detail planning per JV Geographic areas and general plant layout Pro forma detail mine plan and general plant layout for a typical JV Geographical Area (with Nxodap JV JVMP6 as example in Diagram 4 of the collective Figures JVMPs 1 to 11 in Annexure F) As each JV is responsible with assistance from technical personnel from LOR-D to prepare their own JV Mine Plans (JVMPs) and given that the JV’s are re-evaluating existing THG Prospecting data and will be responsible for expanding this data to a comprehensive prospecting plan in accordance with which each JV area can be mined while in the meantime each JV has based its current mining short term planning on the yields of existing pit development/extensions in its Geographical Area.

Diagram 4: Pro-forma detailed mine plan for a typical JV Geographic Area example for Nxodap

53 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Regarding other activities/facilities required per JV, the following elements are shown in Diagram 4 being draft Nxodap JVMP 6 above and photos below: i. Continued use of the established THG access road from the North to the new plant. ii. Erection of a new security office/boom gate iii. In the earlier logistics area of THG the following facilities are being revived on earlier footprints:  Basic workshop and spares store to service Nxodap recovery and mobile plant.  Bunded diesel tanks to 23000/l each  Staff restroom/ablutions iv. Ore processing plant erected and consisting of the following shown in respect of photos below and to diagrammatic plant layout principles below. v. Each JV processing plant is supported by in-pit screening plants which screen Ore grade sizes to delivery trucks while depositing over-and undersize materials directly back to the pit. vi. The processing plant at Nxodap consists of the following semi-mobile elements as seen in the photos overleaf:  Intake hopper fed by dump trucks  Feeder bin to sand screen (union screen)  Conveyors of selected screened materials +1.5mm To -32 mm to the pan plants equipped with 2x18 foot pans from which: o pan tailings and waste sand are directly sent by conveyor to the adjacent old excavation as backfill. o Disposal of used Puddle from the pans is also directed to the backfill pit where water recovery is conducted in the sump. It is noted that as the pans use a “closed puddle system”, such puddle is of very low volume.  Screw conveyors extract the concentrate from the pans onto a concentrate conveyor to an enclosed concentrate bin. The concentrate is then conveyed by enclosed conveyor to the containerised Bourevestnik from which final concentrate is contained in concentrate boxes for diamond recovery at the Reuning Final recovery plant.

As the plant layouts do vary from JV to JV and may in cases totally exclude the pan plant component as in Diagram 3b where in pit screened gravels are simply washed and sized into 3 sizes to be fed separately into the Bourevestnik plant for diamond concentration.

vii. Coarse tailings backfill in an old excavation below plant level to allow gravity deposition of tailings as backfill. viii. Puddle deposition by chute to the puddle pond on the old excavation floor where shallow water recovery sump is provided for siltation to yield clear water for reuse. ix. Process water extraction pumping point on the Orange River Bank where Transhex previously housed its pump.

54 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

x. The 1:100 yr floodline as shown defines the limit of all activities other than that of the pumping point. xi. Continued mining occurs at the various terrace levels by advancing the existing pit faces generally eastward as seen in the draft JVMP6.

Photo 23: Intake hopper and sand plant

Photo 22: Re-used and upgraded THG facilities at Nxodap (old plant removed)

Photo 24: Bourevestnik Final Recovery (blue) and Pan Plants

Photo 25: Proposed sump area in old excavation floor for tailings backfill

In the establishment of new pan plants or relocation of existing pan plants, the following site preparation activities must take place: • Prepare a sketch plan of the plant layout and show connections for receiving materials from excavation and return of waste as backfill to excavation.  Select a preferably previously disturbed site or assess the sensitivity of the site i.t.o vegetation, archaeology (graves, petroglyphs or tools) • In preparation of the site, remove topsoil to topsoil berm • Establish equipment and logistical facilities (containers) as per activity items • Establish access routes and haul roads • Establish bunded diesel tank  Establish process water dam and tanks

In respect of environmental indicators within the Geographic area:  Respect the 1:100 yr floodline,  Respect the no-go riparian vegetation zone  Respect the paleo terrace/hill toe interface  Identify and demarcate no-go petroglyph areas

55 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

 Respect findings of the botanical assessment identifying plants requiring either rescue transplant to Parks Board gardens or applications for Protected Species removal.

4.5 Agriculture as a rehabilitation method and future economic base with existing water use allocation and an integral part of the Post Mining Use While under THG management, the only agriculture considered in the Mining Right area was limited to:  Small horticultural gardens especially in the town of Baken; and  The identified community agricultural plots for irrigation crops seen in Diagram 8 on Swartwater Lower Terrace in para 13.4.3.  During 2017 in the process of compilation of the towards Closure Planning for the LOR the agricultural use of the low level fine tailings dams for agriculture projects was considered noting the unique opportunities offered by the freshwater generated fine tailings ponds and the fact that a single lift solar powered pump could provide water from the Orange River to these low level fine tailings ponds, both of which offered opportunity for especially post mining use. Then however with Cession to LOR-D the opportunity was recognised to expand the consideration of agriculture to include: Commercial irrigation farming on the vast suitable soils found in the Meso terraces but also the outer lying areas of the Mining Right and even further beyond the southern and south eastern fringes to include thousands of hectares where irrigated agriculture could take place on the same basis as that which has existed for many years at the Alexkor Beauvallon and other farms where water supply could be made available from the reduction of mining water consumption from the river (currently held processing water rights). The choice of crop is being considered within the restrictions placed by:  Isolation from markets  Perishability of the product  Lesson learned in previous farmng attempts along the Orange River; and within the successes achieved in recent years at similarly isolated agricultural projects including Aussenkehr table grape production in Namibia near LOR-D, Kotzeshoop/, the Central Orange River, Kakamas to Prieska, date production at , the huge international demand for dates and the classic example presented by Orania in nut production.

This EMP update will strive to determine an extent of such post-mining commercial irrigation agriculture prior to its finalisation of an updated Figure 10 Post Mining Land Use.

4.6 Post Mining Land Use Plan Refer November 2016 with 2017 update of Figure 10: Post-Mining Land Use Plan overleaf which was discussed in all I&AP processes.

56 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

The growth in eco-and adventure-tourism in recent years reinforces the important role of the Reuning/Sendelingsdrift Pont and the role of Reuning in administration and support of the greater Lower Orange Transfrontier Conservation Initiative shown in Diagram 5 below.

Diagram 5: Regional Context

The content of Figure 10: Post-mining Land Use Plan of the approved EMP updated to March 2017 however remained largely the same in respect of:  Tourism routes, except for the emphasis on the Sendelingsdrif Pont river crossing.  Proposed Diamond Mining Visitor Route through retention of selected existing roads, scenic viewpoints and mining elements of tourism value with experiential exposure to panning in scratch patches and old plant exhibitions.  Informative Geosites.  Extension of river rafting routes.  Possible river rafting landing point(s) and shore based facilities subsequent to removal of diamond security restrictions.  Overnight accommodation facilities (ex-mine facilities) in Reuning and Bloeddrif through conversion of facilities to tourist accommodation, and in Baken (i.e. campsite, mine club facility). The only added but significant consideration is that of incorporating large-scale commercial irrigation agriculture into the further mine planning, commencing during operational rehabilitation and the closure process and post mining land use.

57 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Figure 10: Post Mining Land Use

58 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

5 LISTED AND SPECIFIED ACTIVITIES (TOWARDS TABLE)

LISTING LISTED WASTE Aerial extent of NOTICE NAME OF ACTIVITY ACTIVITY MANAGEMENT Activity (Ha or (GNR 983, GNR 984 2 (Mark with AUTHORISATION m ) or GNR 985 (as an X) (Mark with an X ) amended in 2017)) Section 102 Application: EMP Update/revision over GNR 984 Activity # approved Mining Right area 41343.4340ha EMP 41343. 4340 ha X1 17 approved area.

1. ESTABLISHMENT/CONTINUED USE ACTIVITIES As this EMP Update/Revision is initiated by a Cession of the Right to a new company and must accommodate the new companies corporate structure, mining process and rationalisation of facilities and processing plants with new locations, the following activities/facilities must be put in place to reduce/eliminate impacts as discussed above 1.1. Continued maintenance and use of Baken

and Reuning Towns 1.2. Demarcation of Joint Venture (JV) Geographic areas within which each JV will proceed with continued mining in its area and the required temporary logistical

support structures (Office, stores, personnel amnesties and minor workshop containers/ski cabins, plant and bunded fuel tanks). 1.3. Access road is already in place and approved GNR 985: X in terms of earlier EMP. Activity # 4 1.4. All main haul roads and on-site roads are GNR 985: already in place but is included as a listed X Activity # 4 activity in any event. 1.5. Main offices and admin buildings are already

in place 1.6. Main workshop are already in place 1.7. Central Bunded Fuel Tanks are already in GNR985: place at Baken BCP (400kl), Bloeddrif (80kl) X Activity #10 and Reuning Industrial (320kl). 1.8. Points 1.3 and 1.4 include personnel amenities to septic tank and then French drain 1.9. Airstrip (1.2km long) in place on old Baken GNR 985: X Central Access road Activity # 7 1.10. Mining Areas: Further use and new areas in

terms of para 4 and figure 4

1 Section 102 application is not specifically listed as a Listed Activity but this activity is noted and consequently such listed activity has been included 59 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

LISTING LISTED WASTE Aerial extent of NOTICE NAME OF ACTIVITY ACTIVITY MANAGEMENT Activity (Ha or (GNR 983, GNR 984 2 (Mark with AUTHORISATION m ) or GNR 985 (as an X) (Mark with an X ) amended in 2017)) 1.11. Processing plant: LOR-D have established mobile pan processing plants and final recovery plants (Bourevestnik plants) per JV Geographic area (15 Plants at April 2020). These plants generally replace all previous GNR984: X THG large DMS plants which are either Activity # 17 demolished or in an advance stage of demolition at this stage of establishment. Refer Annexure G, past, present and planned processing plants. 1.12. Establishment of bunded diesel tanks generally of less than 20m3 capacity per tank in JV Geographical Areas where required. 1.13. Continued use of existing licensed domestic x and industrial waste sites. 1.14. Continued use and maintenance of existing

potable water plants at Baken and Reuning 1.15. Continuous use of existing process water extraction points and re-establishment of the Water Licence

pumping points at others as per Annexure D STATUS (Water with Fig W-1) 1.16. Continued use and maintenance of electrical

supply 1.17. Asbestos management Annexure E-2. 1.18. Builders rubble burial sites Annexure E-3 2. OPERATIONAL PHASE ACTIVITIES The exact footprint of mining in alluvial diamond bearing gravels is impossible to accurately pre-determine. Future Mining area at this stage is based on the target mining areas identified through earlier prospecting by THG and interpreted by LOR-D and such prospecting will remain a continued process within the mine plans informing regular update. Mining Cycle The mining cycle of a mine block (few hectare over a channel reserve) consists of a cycle of the following activities. 2.1. Demarcation of mine block on aerial image with GIS/GPS definition.

2.2. Topsoil removal to perimeter topsoil GNR 984: stockpiles/berms Activity # 152 X GNR 985: Activity # 123 2.3. Clearing of overburden as dump for later GNR983: X backfill to previously mined area Activity # 194

2 This is included purely to acknowledge the fact that the site is located in a formally protected area/ National Park. 3 The virgin surface of land will be disturbed within a protected area (CBA), by virtue of location within National Park and this listed activity has been included as a cautionary inclusion. 4 The listed activity has an exclusion that applies in the case of a Mining Permit and not a Mining Right. It appears that not mentioning the Mining Right is an omission from the listed activity, but the activity is listed here just in case. It is possible that small drainage channels may be impacted by future mining. 60 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

LISTING LISTED WASTE Aerial extent of NOTICE NAME OF ACTIVITY ACTIVITY MANAGEMENT Activity (Ha or (GNR 983, GNR 984 2 (Mark with AUTHORISATION m ) or GNR 985 (as an X) (Mark with an X ) amended in 2017)) 2.4. In pit screening of ore defined gravel GNR984: material and all +32mm retained in pit as Activity # 17 backfill 2.5. Loading and hauling of in pit screened or

directly loaded ore grade to plant 2.6. Plant processing of ore grade gravels yielding GNR984: concentrate for diamond recovery and Activity # 17

coarse and fine tailings GNR983: Activity # 12 2.7. Return of tailings to excavation as

operational backfill 2.8. Temporary ponding of process water from Will be backfilled X plant 2.9. Backfilling of excavations 2.10. Covering of backfilled excavations with

previously stockpiled topsoil 2.11. Periodic establishment of in field screening GNR984: plants and their continued relocation as X Activity # 17 mining progresses. 2.12. Periodic establishment of processing pan GNR984: plants or re-establishment of existing pan X Activity # 17 plants 2.13. Establishment of a final recovery GNR984: X Bourevestnik plant adjacent to a pan plant Activity # 17 2.14. Use of water for processing of material at Water License

plant granted5. Other OPERATIONAL ACTIVITIES 2.15. Use of small JV workshops 2.16. Use of wash bay (if contemplated) 2.17. Use of central Refuelling supply at Baken,

Bloeddrif and Reuning 2.18. Use of small bunded tanks at each JV plant 2.19. Use of access/delivery roads to and in each

JV Geographic area 2.20. Water Use: Water License in place. Will

require additional Amendment 2.21. Initiate agricultural projects 3. OPERATIONAL NON – MINING REHABILITATION

ACTIVITIES 3.1. Maintain access/delivery road on site 3.2. Waste management including use of existing domestic waste sites, proposed asbestos X waste disposal (waste burial site) and builders rubble site. Ref Annexure E. 3.3. Enforce no-go area access

Attention is drawn to a specialist report in Annexure H dealing with stream channel diversions as contained in Annexure H. 5 Water License is granted see Annexure D1. 61 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

LISTING LISTED WASTE Aerial extent of NOTICE NAME OF ACTIVITY ACTIVITY MANAGEMENT Activity (Ha or (GNR 983, GNR 984 2 (Mark with AUTHORISATION m ) or GNR 985 (as an X) (Mark with an X ) amended in 2017)) 3.4. Hydrocarbon Management: Decontaminate

floors and service aprons when required 3.5. Agricultural projects 4. DECOMMISSIONING PHASE ACTIVITIES GNR983: X Activity # 22 4.1. Identify all facilities and activities for retention within the post Mining Land Use context 4.2. Finalise transfer of town facilities,

administration and liabilities 4.3. Foster agricultural projects 4.4. Complete backfilling of excavations with nearby material (when available) and cover with topsoil 4.5. Shape excavation edges to 1:3 slope and

topsoil 4.6. Shape any remaining dumps as per EMP specification and cover with topsoil if available 4.7. Demolish all unrequired structures 4.8. Remove all process plants and steel

structures 4.9. Remove all protruding foundations and

footings 4.10. Remove all pipelines and cables 4.11. Remove diesel tanks, bunds, rehabilitate

footprint & decontaminate 4.12. Rip / scarify logistical facilities/areas and footprints and apply pebble deflation surfaces where appropriate. 4.13. Retain access roads for future use 5. AFTERCARE PERIOD 5.1. Remove alien vegetation (if applicable) 5.2. Conduct final performance assessment 5.3. Lodge closure Application 5.4. DMR Grant Closure Application

The listed activities which are/were triggered are as follows: GNR 327: Activity #12: The development of— (i) dams or weirs, where the dam or weir, including infrastructure and water surface area, exceeds 100 square metres; or (ii) infrastructure or structures with a physical footprint of 100 square metres or more; where such development occurs— (a) within a watercourse; (b) in front of a development setback; or (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse; — Excluding…………. GNR 327: Activity #19:

62 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

The infilling or depositing of any material of more than 10 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 10 cubic metres from a watercourse.

GNR 327: Activity #22: The decommissioning of any activity requiring – (i) a closure certificate in terms of section 43 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002); or (ii) a prospecting right, mining right, mining permit, production right or exploration right, where the throughput of the activity has reduced by 90% or more over a period of 5 years excluding where the competent authority has in writing agreed that such reduction in throughput does not constitute closure; but excluding the decommissioning of an activity relating to the secondary processing of a – (a) mineral resource, including the smelting, beneficiation, reduction, refining, calcining or gasification of the mineral resource; or (b) petroleum resource, including the refining of gas, beneficiation, oil or petroleum products; – in which case activity 31 in this Notice applies.

GNR 325: Activity #15: The clearance of an area of 20 hectares or more of indigenous vegetation, excluding where such clearance of indigenous vegetation is required for— (i) the undertaking of a linear activity; or (ii) maintenance purposes undertaken in accordance with a maintenance management plan

GNR 325: Activity #17: Any activity including the operation of that activity which requires a mining right as contemplated in section 22 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002), including— (a) associated infrastructure, structures and earthworks, directly related to the extraction of a mineral resource; or (b) the primary processing of a mineral resource including winning, extraction, classifying, concentrating, crushing, screening or washing; but excluding the secondary processing of a mineral resource, including the smelting, beneficiation, reduction, refining, calcining or gasification of the mineral resource in which case activity 6 in this Notice applies.

GNR 324: Activity #4: The development of a road wider than 4 metres with a reserve less than 13,5 metres. (Northern Cape) i. In an estuary; ii. Outside urban areas: (aa) A protected area identified in terms of NEMPAA, excluding disturbed areas; (bb) National Protected Area Expansion Strategy Focus areas; (cc) Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 ofthe Act and as adopted by the competent authority; (dd) Sites or areas identified in terms of an international convention; (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; (ff) Core areas in biosphere reserves; (gg) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core areas of a biosphere reserve, excluding disturbed areas; or (hh) Areas seawards of the development setback line or within 1 kilometre from the high-water mark of the sea if no such development setback line is determined;

GNR 324: Activity #7: The development of aircraft landing strips and runways 1,4 kilometres and shorter. (Northern Cape). i. All areas outside urban areas;

GNR 324: Activity #10 The development and related operation of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 30 but not exceeding 80 cubic metres. (Northern Cape).

GNR 324: Activity #12:

63 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan i. Within any critically endangered or endangered ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004; ii. Within critical biodiversity areas identified in bioregional plans; iii. Within the littoral active zone or 100 metres inland from high water mark of the sea or an estuary, whichever distance is the greater, excluding where such removal will occur behind the development setback line on erven in urban areas; or iv. On land, where, at the time of the coming into effect of this Notice or thereafter such land was zoned open space, conservation or had an equivalent zoning. 6 Description of activities to be undertaken Refer paras 4 and 5 above.

7 Policy and legislative context

APPLICABLE LEGISLATION AND GUIDELINES REFERENCE HOW DOES THIS DEVELOPMENT USED TO COMPILE THE REPORT WHERE APPLIED COMPLY WITH AND RESPOND TO THE POLICY / LEGISLATIVE National Environmental Management Entire document including CEnvironmentalONTEXT Authorization from Act public participation DMR as competent authority Mineral and Petroleum Resources Template for Scoping DMR application and process Development Act Report Municipality’s SDF Need & Desirability (Para 9) End Use informant 13.7 and Annexures D and National Water Act (inter alia S21) Water Use Licence D1 Heritage Resources Act (S38) 23.1.2 Need and Desirability (Para EMF End Use Informant 8) EIA Guideline and Information Need and Desirability (Para Guideline for information utilized in Document Series’ “Guideline on Need 8) this document and Desirability EIA Guideline 5 Assessing alternatives Cumulative Impact Guideline for information utilized in and impacts Assessment (Para 8.1) this document The backfill of processed material does not require Waste Licence. NEM:WA EMP BUT new fine tailings dams/dumps and coarse waste rock dumps do.

8 Need and desirability (N&D)of the proposed activities (Motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location).

This EIA-EMP Update/Amendment purely serves the new owner of the Ceded Mining Right to undertake the further mining of diamonds within the long established Mining Mineral Lease Area both within the Mineral Legislation requiring optimal utilisation of the mineral reserve and the fact that this Orange River deposit holds some of the best Gem Quality Diamonds of the world. 64 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Furthermore, it is noted that the Mining Right Ceded from THG to LOR-D provides for mining under the existing approved Mining Right until year 2038.

In light of the above history and status of existing and planned mining and its legal framework, Need and Desirability of continued mining of the LOR reserve is sufficiently established not requiring standard motivation of N&D.

Consequently this paragraph 8 deals only with updating of the existing EMP in respect of reflecting on: i. MSDF (surrounding regional land-use planning). The most relevant of the Municipal Planning Frameworks was found to be the “Richtersveld Rural Spatial Development Plan 2010”. As in its para 18.6.1 in dealing with “Mining” it:  Acknowledges that the “Richtersveld economy relies strongly on the mining sector”.  While it is true that the mining sector will be exhausted in future, it is not true that this will happen in the next 15 years (2025) as the current diamond mining planning has a 30 year horizon and prospecting for other minerals such as Zinc are current while aluminium rich minerals such as silliminite offer further potential following prospecting and the O’ Copper District still holds unmined reserves. Accordingly, the 2008 Namakwa District Profile reports “that there is still a range of unexploited minerals that will sustain the mining industry in years to come”.  The IDP goes further in recognising “the need to exploit mariculture, agriculture and mining” while the Namakwa District Local Economic Development Strategy (2009) correctly pointed to the need of Richtersveld municipality to focus on mariculture and specialised farming along the Orange River.  In essence therefore as an overview the Rural Spatial Development Framework/Land Development Plan identifies the opportunities for Richtersveld to: o “Exploit the tourism of the Richtersveld AIS-AIS Transfrontier Park, Agriculture and Mining potential”. The Richtersveld municipal annual report 2018 did reflect that “the largest contributing sector to the GDPR within the Richtersveld Municipality in 2018 was mining and quarrying at 34.2%”. The current draft Richtersveld Municipal IDP 2019-20 does reflect that mining, agriculture and tourism are still important contributing factors in the Richtersveld.

ii. The Post Mining Land Use Plan as shown in Figure 10 and discussed in para 4.6 and specifically mine management during contemplated planned mining within the context of the Ai-Ais Richtersveld Transfrontier Park is to be considered further than what was contemplated in the approved EMP of 2015.

In light of the above, this 2020 LOR EMP Amendment/Update takes cognisance of the 65 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

objectives of assessing the opportunity for down-scaled mining over the remaining life of mine (at this stage 30 years) to integrate agriculture and tourism into its “towards closure planning” while emphasising the need to maximise the resource utilisation and ensuring maintenance of roads, potable water supply and other infrastructure which would have a role in the post mining period.

8.1 Cumulative impact assessment The individual and cumulative impacts have already informed the EMPs of LOR Mine under THG updates and revisions, and environmental management prescriptions are in place and again being reviewed and updated in the matters of individual baseline assessments of vegetation, topsoil, dust, hydrocarbon impact of soil and water and the EMP control prescriptions. Accordingly, within the concept of cumulative impact, the further mining of the LOR Mine focuses on minimising post activity disturbance through operational rehabilitation application in the core elements of excavations with immediate operational backfill and the use of semi-mobile plants.

Regarding the geographic scope of the assessment, the total areas over which mining will take place does not differ significantly from areas disturbed to date by mining and in the case of proto terraces by extensive prospecting by THG and such limit at the overall scale will now be governed in this update by No-Go areas at overall mining right area level and in JV Geographical Areas to protect natural scenic area and landscapes at the higher level and details including amongst others, Orange River riparian edge and artefact protection areas at a detail level.

9 Period for which the environmental authorisation is required This 2020 EMP Update is supported by the current 2020 Mining Work Program (MWP) Update which relies on a remaining mining life of 30 years from 2020.

10 Description of the process followed to reach the proposed preferred site NB!! – This section is not about the impact assessment itself; It is about the determination of the specific site layout having taken into consideration (1) the comparison of the originally proposed site plan, the comparison of that plan with the plan of environmental features and current land uses, the issues raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout as a result.

The utilisation of active areas within current Mining Right area has been established over more than 40 years of mining and prospecting to date and hence this is not relevant further than the prescription of No-Go areas dictated by analyses of baseline studies in paras 13.11 Archaeology, 13.5 Natural Vegetation and 13.3 visual of the montane backdrop and of the Orange River riparian zone and then later in the respective EIA-EMP prescriptions of this current LOR EMP Update/Amendment.

11 Details of all alternatives considered. Within the above context at overall level, an overall no-Go alternative is clearly not a choice in terms of employment opportunities, regional economic considerations or prescription legislated optimisation of resources.

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At detail level, the options between permanent plants and mobile plants and in the preferred requirements for applying a strip mining preference with continuous excavation backfill as opposed to creating large fine tailings ponds (slimes dams) an course tailing dumps have been considered and will be applied through this EMP update.

11.1 Option of not implementing the activity. Not applicable within the above context.

12 Details of the Public Participation Process Followed Describe the process undertaken to consult interested and affected parties including public meetings and one on one consultation. NB the affected parties must be specifically consulted regardless of whether or not they attended public meetings. (Information to be provided to affected parties must include sufficient detail of the intended operation to enable them to assess what impact the activities will have on them or on the use of their land.

a) Covid-19 accomodation in the I&AP process Following engagement of the DMR regional offices, the DMR now provides for 30 day extension in the Public Participation Process and Impact Assessment Process. The process of public participation shall now be governed by agreement being reached between the Competent Authority and the Applicant on a Public Participation Plan within which a 30 day extension can be accommodated if required within the applicant’s circumstances.

b) Public Participation Plan Accordingly, at this draft Scoping Stage the Public Participation Plan for the LOR Scoping phase and subsequent EIA-EMP phase I&AP phase is structured as follows:

1 The landowner As the Mining Lease area defined in Regulation 2(2) Sketch Plan (Figure 2) encompasses for the largest part Farm Richtersveld 11 Rem with the extreme northern areas of Aace and Swartpoort being located on farm 18 Remainder as part of the Richtersveld, for the purposes of I&AP engagement land ownership is considered hereafter as follows: i. In respect of the small portion of Farm 18 Rem (the farm encompassing the Richtersveld National Park) the owner is defined herein as Department of Public Works which in this case is administered by SANParks. This Draft Scoping Report will therefore be distributed for comment via email to SANParks and a meeting with SANParks is to be scheduled in the I&AP period with copy to the Department of Public Works to discuss both the land under Farm 18 Rem including Aace and Swartpoort as well as the SANParks facilities in Reuning Town together with the management of Mining in parallel with tourism as the Richtersveld national part and AI-Ais

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Transfrontier park traffic passes through this portion of the Mining Right area via the main road and the pont. ii. Deeds registered ownership as Farm Richtersveld no 11 Rem under title deed T8521/1979CTN is the Community of Richtersveld. For participatory purposes includes the Richtersveld Sida Hub Community Property Association (CPA) (Sanddrift, Kuboes, , and ) communities with whom meetings will be arranged for discussion in the I&AP process. Discussions will involve the future of the Community Irrigation Areas along the Swartwater Lower Terrace and Bloeddrif airstrip terrace within the context of agricultural use of the lower laying fine tailings ponds in Swartwater and Bloeddrif and the larger context of future commercial irrigation farming on especially mined out Meso terraces.

2 Surrounding Landowners It must be noted that other than the boundary farm along the river to the south of Baken which is in private ownership and will be involved in the I&AP process, surrounding landowners are so distant that they will not be impacted by the proposed development but the Oena Mine owners African Star Minerals (Pty) Ltd and the National Parks Boards would also participate as surrounding owners representing both the Richtersveld National Park and the Ai/Ais- Richtersveld Transfrontier Park.

3 Local Authorities: Draft Scoping Report will be sent to the local authority either by courier or registered mail. i. Richtersveld Local Municipality ii. Namakwa District Municipality iii. Municipal Councillors:  Ward 1- Cllr Willem Links  Ward 2: Cllr Anna Bock Such distribution of documents will be followed up with meetings with municipalities in and Springbok respectively.

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4 State Departments and parastatals: Draft Scoping Report will be sent to the state and parastatal departments and NGOs either by hand delivery, courier or registered mail: i. Department of Environment and Nature Conservation : Northern Cape (Kimberley) ii. Department of Environment and Nature Conservation : Northern Cape (Springbok) iii. Dept. of Agriculture Forestry and Fisheries (Namakwa District in Springbok) iv. Department of Public Works (Kimberley) v. Department of Water and Sanitation (Upington): Lower Orange Water Management Area vi. SAHRIS to be engaged via a Scoping Report upload.

5 Broad public notified in 3 ways: i. By way of newspaper advert in local newspaper (Die Plattelander) ii. By way of A2 size posters placed at project entrance and the Sanddrift, Kuboes, Lekkersing, Eksteensfontein, Port Nolloth and Alexander Bay Public Library and Municipal office Community notices boards with documents at each library for perusal. iii. Through notification of and discussion with the local councillors of Wards 1 and 2.

6 Public meetings As South Africa is under Covid-19 limitations with meetings/gathering of more than 50 people not permitted, conventional public meetings will be held with general communities but with attendance figure limited to 50 persons. Meetings will be held at the community halls of Sanddrift, Kuboes, Lekkersing, and Eksteensfontein.

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7 Authority meetings Meeting with the following authorities will be held during which Site Plan Consulting will conduct a PowerPoint presentation of the Scoping Report followed by discussion of items raised.

Such authorities meeting will include:  DWS in Upington  Richtersveld Municipality in Port Nolloth and Namakwa District Municipality in Springbok  DENC and Dept. of Agriculture Forestry and Fisheries in Springbok

8 Future public participation will then consist of the following i. Receipt of all comments in respect of the draft Scoping Report. ii. Compilation of final Scoping report and lodging to DMR iii. Late comments will be considered on merit and submitted to the DMR iv. Finalization of a draft EIA-EMP including: a. Specialist studies. b. Comments in respect of the draft scoping report v. Distribution of draft EIA-EMP to registered I&AP’s as well as all State Departments and NGOs listed above for 30 day commenting period. vi. If comments received on draft EIAEMP make material changes to EMP, then redistribution of 2nd draft version of the EIA-EMP will take place. vii. Lodging of Final EMP to DMR with all comments and changes made as required for approval.

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Table 12b): Public participation plan Interested and Affected Parties: Section in this Date List the names of persons consulted in this EAPs response to issues as mandated by report where the Comments Issues raised column, and Mark with an X where those who the applicant issues / responses Received must be consulted were in fact consulted. were incorporated. AFFECTED PARTIES Landowner/s Farm 11 Rem. Richtersveld Sida !Hub Community Property Association: Representing Sanddrift, Kuboes, Lekkersing,

Eksteensfontein and Alexander bay Secretary: Annemarie de Wet Tel: 063 894 0794 [email protected] Farm 18 Rem Department of Public Works Administered by SANParks – see below Lawful occupier/s of the land |Ai-|Ais/Richtersveld Transfrontier Park. Park Manager: Mr Brent Whittington. Email: email [email protected] Tel: 027 831 1506 (Reception) Surrounding Landowners

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Interested and Affected Parties: Section in this Date List the names of persons consulted in this EAPs response to issues as mandated by report where the Comments Issues raised column, and Mark with an X where those who the applicant issues / responses Received must be consulted were in fact consulted. were incorporated. Oena Diamond Mine owners African Star Minerals (Pty) Ltd Name: Theodor Boshoff Email: [email protected] Cell: 072 437 0524 No 205 A/B, 2nd Floor, Smokey Mountain Office Park, Route N4 Business Park, C/O Nelson Mandela Ave. & Paul Sauer St. Witbank National Parks Boards

See above under Landowner Municipality. The mine is located in Wards 1 and 2 of the Richtersveld Local Municipality Municipal Councillor: Ward 1 Mr Willie Links: 072 263 7928 email [email protected] Municipal Councillor: Ward 2 Name: Anna Bock

Email: [email protected] Cell: 060 788 3874 Municipality: Richtersveld Municipal Manager (Acting) Mr Sydney Adams email [email protected] Cc [email protected] Tel: 027 851 1111

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Interested and Affected Parties: Section in this Date List the names of persons consulted in this EAPs response to issues as mandated by report where the Comments Issues raised column, and Mark with an X where those who the applicant issues / responses Received must be consulted were in fact consulted. were incorporated. Municipality: Infrastructure Branch: (Environmental): John Komanisi email Tel: 027 851 1111 Email: [email protected] Namakwa District Municipality: Private Bag x20, Springbok Municipal Manager Email and Chris Fortuin Registered Email: [email protected] Mail Tel: 027 712 8000

Organs of state (Responsible for infrastructure that may be affected Roads Department, Eskom, Telkom etc.) Eskom Through LOR Pieter Coetzee 082 498 9450

Rolani [email protected] Cell: 072 117 9439 Communities email Dept. Land Affairs Commission On Restitution Of Land Rights: Regional Land Claims Commission: Northern Cape. email Tel: (053) 807 5700 [email protected]

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Interested and Affected Parties: Section in this Date List the names of persons consulted in this EAPs response to issues as mandated by report where the Comments Issues raised column, and Mark with an X where those who the applicant issues / responses Received must be consulted were in fact consulted. were incorporated. Traditional Leaders None State Departments / NGO’s Department of Environment and Nature Conservation : Northern Cape Private Bag X6120, Kimberley, 8301 Reg Mail Tel 053 807 7300 Head of Department Department of Environment and Nature Conservation : (Springbok) Private Bag X16 Springbok 8240 Tel 053 807 7300 Reg Mail Peter Cloete Email: [email protected]

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Interested and Affected Parties: Section in this Date List the names of persons consulted in this EAPs response to issues as mandated by report where the Comments Issues raised column, and Mark with an X where those who the applicant issues / responses Received must be consulted were in fact consulted. were incorporated. Department of Water and Sanitation: (Upington). Lower Orange Water Management Area Private Bag X5912, Upington, 8800 082 883 9549 Mr Steven Shibambu: Assistant Director: Reg Mail Email: [email protected] Shaun Cloete: Envi. Officer Email: [email protected] Cell: 083 033 3642 Alexis Hengani Tel: 054 338 5800 Email: [email protected] Dept. of Agriculture Forestry and Fisheries(Springbok): 2 Hospital Street, P.O Box 18 Springbok, 8240 Reg. mail. District Manager Mr Darren Engelbrecht E: [email protected] Tel: 027 712 1315

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Interested and Affected Parties: Section in this Date List the names of persons consulted in this EAPs response to issues as mandated by report where the Comments Issues raised column, and Mark with an X where those who the applicant issues / responses Received must be consulted were in fact consulted. were incorporated. Department of Public Works (Kimberley) Ruwayda Baulackay Reg Mail Private Bag X5002, Kimberley, 8300 and email Tel: 053 838 5202 Cell: 083 459 7602 Email: [email protected] OTHER AFFECTED PARTIES SAHRA/HNC Lodgement on Heritage electronic

lodging system: SAHRIS

INTERESTED PARTIES

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13 The Environmental attributes associated with the site: BASELINE ENVIRONMENT

Type of environment affected by the proposed activity In this 2020 EMP, the documentation is no longer split on a 3 way administrative basis as was done in the 2009 EMP Update with Baken, Bloeddrif and Reuning in their own documents respectively but now in 2020 the emphasis is placed on the biophysical lateral distinction between: i. Orange River bank, ii. slightly elevated Alluvial terraces with occasional alluvial filled paleo horse-shoe bends as at Bloeddrif and Baken and iii. the elevated rocky hills/montane area as reflected in the diagrammatic sketch below, given that lateral distinction is very consistent, immediately recognised in the field and aerial images and that each such category has very distinct differences within each environmental attribute (soil types, vegetation types and sensitivities to disturbance etc).

Diagram 6: Lateral distinction in environmental attribute descriptions

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13.1 Climate

13.1.1 Regional climate The lease area is located in the Arid West Coast Climatic Region of Southern Africa (Transitional Desert of the Orange River Trough; Köppen Code) and has more in common with the adjacent climate of the southern Namib Desert of Namibia than with the higher lying Richtersveld or of the Orange River mouth at Alexander Bay which are cooled by altitude and sea temperature respectively. This unique climate of the lower Orange River is determined by: • very low rainfall <50mm/year; • only occasional penetration of coastal fog this far inland; • frost free winters given low altitude; • strong south-westerly winds; and • very high temperatures and uncomfortable working conditions.

In the absence of local weather statistics, the climatic conditions are described from a combination of Vioolsdrift (100km upstream) and Alexander Bay (60km downstream) statistics.

13.1.2 Precipitation The monthly rainfall distribution for Vioolsdrift is shown on page 15 to yield an average of 40.8mm/year (over the period of 1993 to 2000). This compares well to the average of Alexander Bay which measured 46mm over the period of 1951 to 1987 (WB40). The average rainfall of Rosh Pinah 20km north of Reuning is 54mm. With respect to seasonality, the precipitation generally occurs in the months of March to June for Alexander Bay and May to August for Rosh Pinah.

13.1.3 Rainfall intensity Rain either occurs as light winter rain from the west associated with an extensive low pressure cell over the South Western Cape or as very occasional thunder storms in the months of March/April. Hail seldom occurs. The highest monthly precipitation recorded for Alexander Bay is 46mm while the highest 24 hour rainfall is 39mm. In Vioolsdrift the highest daily rainfall over 1993 – 2000 is recorded as 51.8mm with other daily peaks seldom exceeding 20mm. Given the general permeability of the sandy soil of the southern lease area, surface run-off is very limited in these areas and restricted to a limited number of well defined run-off channels.

Given the bare rock exposure of the catchment areas of the Bloeddrif and Baken, areas with steep topography, concentrated run-off does occasionally cause wash-aways of sandy soils in the stream channels in this area despite the general low intensity of rainfall. Stormwater management: • downstream of bare rock areas; and • along defined run-off channels, must be provided for in mine planning.

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13.1.4 Temperature As the lease area is not cooled by the proximity of the sea as in Alexander Bay, the temperature regime of the lease areas is reflected by statistics of Vioolsdrift which reveals the following monthly averages: • daily temperature for the summer months of December, January and February of between 27 and 30ºC. • daily maximum temperature for December, January and February exceed 35ºC between 14h00 and 17h00 hours. • daily minimum temperature seldom falls below 6ºC at 06h00 in June.

13.1.5 Wind The wind regime is seen as a combination of Port Nolloth winds as reflected by the wind roses for Port Nolloth and Keetmanshoop, overleaf and the raw wind statistics for Vioolsdrift as depicted overleaf. The assessment revealed that for Port Nolloth south winds predominate with frequency of 23% and a speed of 5m/per second for the summer months in winter a high percentage calms (36%) is experienced with low wind speeds and wind direction generally from the E and ENE. The figures for Vioolsdrift compare directly with a dominance of >30% in the S, SSW and SW sectors in summer with southerly wind speeds also generally >5m/s and an easterly wind domination in the winter months of March – September.

13.1.6 Evaporation The mean monthly evaporation “A-Pan” is best reflected by a combination of Okiep and Keetmanshoop statistics measured over a period of 4 years (WB28 page 226,227) giving an average monthly evaporation of 298mm/month or 3576mm/year.

The implications of the above temperature/rainfall/evaporation scenario for rehabilitation are as follows: • unless irrigated for their entire life, trees, shrubs or grasses (which are not endemic) will not survive as landscape or rehabilitation measures and should not be considered. • natural reseeding offers the only method of stabilisation/revegetation of denuded areas. • high evaporation will cause accelerated water loss from shallow tailings dams and increase salinity of the recycled process water from such dams. • high wind speeds will cause wind erosion of sharp edges of cuttings and dumps as evidenced on the Port Nolloth – Alexander Bay road if such cuttings are not partially armoured with coarse rock which can form a deflation surface.

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Diagram 7: Windroses and monthly temperature and rainfall presentation

13.1.7 Incidence of Extreme Weather • Extremely high maximum daily temperatures are significant in the Orange River Valley (up to 50°C on occasion). • No frost occurs. • Hail occurs on rare occasions only. • While wind speeds are sufficiently high to cause dust storms on a regular basis they are generally not high enough to cause any structural damage to buildings.

13.2 Geology As the geology of the Mining Right area insofar as it determines the distribution of the diamond reserve and consequently the distribution and nature of Mining, the reader is referred para 4.1.1 reflecting the full “Geological Backgrounding Informing Mining” as depicted in Figure 4.

13.3 Topography a) Topographic description with reference to Figure A-3 In keeping with Diagram 6 above and Figure A-3, the regional topography is a direct reflection of the resilience of underlying geological strata which strike NW-SE with the result that the main mountain ranges also form NW-SE ridges other than the granitic South Ploegberg and its low lying surroundings which is the result of the Ploegberg being deep weather residual granite as far west as the Baken Central Plant and north to the Wondergat (Cornellskop).

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Figure A-3: Mining Lease, Regional Topography, Drainage and Electrical Grid (Map at A3 page size)

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From the high Vandersterrberg ridge (1363m) which runs northward from the Ploegberg to the Numeesberg and extending north to the Orange River at Swartpoort, these mountains form the N-S watershed between the western (study area) and eastern Richtersveld catchments.

Within the western slope (basin) of the Orange River the following hills break the slope into well defined basins or form topographic features along the river. These include from south to north the following: (i) Koeskop with its radio mast between the Koeskop Horseshoe and Xheis satellite mining areas. (ii) Bloeddrif black dolerite hills. (iii) Nxodap Ridge. (iv) Jackalsberg Ridge (v) Vyf Susters Ridge to the east and parallel to the main road to Reuning. (vi) Mehlberg and associated higher by ground east of Reuning

b) Visual Aspect of Topography To the visitor of the western Richtersveld, i.e. the road user from Alexander Bay to Kuboes or past to Cornellsberg to the National Park gate or even via Reuning offices to collect a gate entrance to the Park, the catchment basins as defined in a) above, combined with the deeply incised river and the local hills along the river result largely in hiding most mining areas from public view apart from: (i) the now rounded overburden dumps of Baken south along the public Kuboes Road; (ii) while the large Baken Central Plant was visible from the public road system such plant is now largely demolished and will have no residual impact; (iii) the last 3 kilometres of road into Reuning from Southgate where the road runs between production plants of South Gate plant and Reuning Final Recovery Plant and prospecting trenches; and (iv) The main Richtersveld Park Access road from Reuning town around the overburden dumps and the vast Reuning Central mined excavation has had mining impact on such road traffic vastly reduced by the shaping/rounding of the overburden dumps on the inner curve of this road. The road however does pass the current LOR-D JV plant of Reuning Central in its current position at road level. with the result that no mining activities are visible from the main public (tourist) roads nor from any of the internal roads of the Park.

With respect to visual exposure to the Oranjemund – Rosh Pinah road, these mining areas pose a significant impact during operations but as mining is also taking place on the Namibian bank adjacent to the newly surfaced road, the diamond mining must be seen as part of the tourist experience for the duration of mining on both the South African and Namibian Side. c) Drainage of the Lease Area (as it relates to topography at regional scale) The drainage varies between:  a dendritic pattern in the south on the deep weathered granite slopes in deep soils as far NW as the Koeskop – Wondergat area. 82 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

 a similar dendritic pattern or no drainage pattern at all existing on the terraces themselves given their permeability,  the remainder of the lease area and in fact the remainder of the catchment basin is characterised by well-defined run-off channels which are generally soil filled but often eroded to bed rock. The channels are episodic bringing very fast run-off from bare rock outcrops on the hills and mountain slopes. The catchments and the main channels and their local catchments being defined by the NW trending hill ridges described in para. a) above. Refer Figure A-3 above.

Four main drainage channels and the respective catchments are therefore identified from south to north as follows: (i) the Springklip channel which rises in western Ploegberg and flows between the proposed Terrace 1 and 2 satellite mining areas. (ii) the “Kaais River” which rises behind Koeskop and runs along the main internal Baken mine road before flowing past the Baken town entrance between the recreation club and the residential area. (iii) The Annis River (largest of all the drainage channels) rises high in the Vandersterrberg, flows past Kuboes town, just north of the Cornellsberg (Wondergat and follows the road to Bloeddrif Mining area, not interfering with any satellite mining areas). (iv) The Bloubos “River” which rises in the Vandersterrberg around the National Park entrance and flows down the sand filled valley (fluss) criss crossing the road with occasional wash-aways to finally crossing the South Gate Satellite Mining Area. In addition, cognisance must be taken of local similar episodic drainage channels which cross mining areas especially in the planning of tailings ponds, waste dumps, permanent structures and provision of drainage channels to avoid erosion of roads at channel crossings through provision of piped culverts with wing-walls.

13.4 Soils Refer Figure A-6: Geology, Soils, Topography, Drainage and Archaeology hereafter.

The technical information provided in this section of the report was obtained from a specialist study undertaken by Soil and Irrigation Directorate of the Department of Agricultural Technical Services, 1979 (NGB Report 912/143/79)

With reference to Diagram 6 Lateral distinction in environmental attribute descriptions, soils classification and distribution concurs with the Diagram 6 lateral classification in para 13 introduction.

The overarching pattern which emerges is that the soils in the lease area are scarce in the elevated rocky hills montane area, mostly shallow and stoney with a low clay content. This is the result of the intense incision of the Orange River into this landscape over the past 20 to 3 million years leaving mainly rock and localised screes other than weathered granite soils in the deeper weathered granite north western portion of the Kuboes Pluton between Koeskop and Cornellskop. All other soils are river terrace gravels,

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flood silts or Aeolian (windblown) sands being the young meso terraces along the Orange River as described under geology in para 4.1.1.

Almost all mining activity takes place in alluvial gravels and sands in relative close proximity to the river and is restricted to alluvial deposits of the Meso terraces and 3 paleo alluvial filled horse shoe bends of older Proto age where local diamond gravels occur at high elevation distant from the river on the top or middle slopes of the elevated rocky hill areas. Future anticipated mining under LOR-D will primarily be focused mainly at the young Meso terraces between the river and the toe of rocky hill area and accordingly there should be no further impact on the elevated rocky hill area.

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Figure A-6: Geology, Soils, Topography, Drainage and Archaeology (Baken-Sanddrif)

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In addition to rocky areas a total of 8 soil types which group into 6 categories are listed as follows: (i) Dundee This soil form is the dominant (Du) form of the flood-plain of the Orange River. 3 phases of Dundee are identified: • DuA – layers of fine sand interbedded with silt. No stones or gravel depth >150mm (0-6% clay). • DuB – layers of medium to coarse sand depth >1500mm. • DuC – layer of medium to fine sand but with much gravel in profile >1500mm (6- 15% clay).

DuA - immediately adjacent to the river, stratified and fine, formed by high flood episodes and forms the agricultural component of river bank farms.

DuB – this coarse sand phase is found mainly in the tributaries and flood-plains of their episodic run-off channels as well as in the alluvial fans of the mountains. They can contain a good percentage of gravel and stones.

DuC – higher lying terrace gravels with an unlikely lime or gypsum content under an older deposition than A and B, C is also characterised by surface deflation pebble scatter.

(ii) Alluvial Gravels (Terrace Soils) (T) Typical diamond gravels where the coarse pebble / gravel fraction is 70 – 90% and clay content is 6 – 15%.

(iii) Aeolian Sands, include: a) Huttons Characteristically occurs in higher lying alluvial fans of the ridges and mountains but also includes the red Aeolian (Kalahari) sands. b) Fernwood Grey to light brown deep Aeolian sands >600mm without any stones or gravel. c) Clovelly Yellow Aeolian origin soils against river and lower mountain slopes. (iv) Glenrosa Paardeberg series, mainly granitic soils with 0 – 6% clay, and coarse sand in the A horizon and no lime in the B horizon. Topsoil of the Ploegberg – Kuboes – Baken East plains.

(v) Colluvial Gravels On mountain slopes where the angular stone fragments >70%.

(vi) Mispah Mainly MS10 or proper Mispah (non calcareous) with or orthic A horizon of <300mm directly on hard rock. Topsoil of all the rocky areas of the lease area.

(vii) Rocky Areas 86 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Where base rock is exposed over more than 80% of the area.

(viii) Windblown Dunes on river terraces (mobile dunes).

13.4.1 Irrigability / Fertility of Soils Only Hutton, Clovelly, Dundee and Fernwood soils are potentially irrigable but so are the terrace gravels. Soils must also be >300mm to classify as irrigable and have a gradient of less than 6%. Given the low rainfall, the soils have no dry-land cropping potential.

13.4.2 Erodability Given their low clay content (sandy / silty nature of all the soils) they are mostly highly erodable when subject to concentrated run-off. As they are generally highly permeable, the low rainfall intensity, yields them as having low erodability under level conditions where rainfall is not concentrated. Where however, higher lying rocky areas, despite low intensity rainfall, generate rapid surface run-off in episodic drainage channels, erosion of these sand filled channels does occur.

13.4.3 Preservation/Reconstitution of soils suitable for commercial irrigation agriculture As the specialist soils study identified primarily the Dundee (DuA) soil form which is:  Found immediately adjacent to the river,  Stratified and fine,  Having a 0-6% clay content,  And formed by high flood episodes, forming the agricultural component of the river banks farms, THG had identified 10 irrigation erven adjacent to the river bank in the Swartwater meso terrace/river bank area southwest extremity of Baken Mine on the identified DuA soils.

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Diagram 8: Irrigation Erven on Swartwater Lower Terrace

This soil form occurs within regular flood episode areas of the river bank, and differs only slightly from the DuB and DuC soils of the remaining large meso terraces identified for LOR- D mining. Within the consideration of the future mining of the extensive meso terraces by strip mining process with backfill to predetermined profiles, it is within the ability of rehabilitation prescription to enable all meso terrace rehabilitated excavation areas to be suitable for post mining irrigation agriculture both in terms of surface pebble content and clay content as the return of the fine tailings from the pan plants can be selectively returned to the strip mining backfill where post backfill scarification can blend the final backfill horizon to the best suitable soil profile for post mining irrigation agriculture on large extents of meso terraces to be mined (to the extreme of high pebble content not being adverse to grape production as the vineyards of the Western Cape Breede River and Hex river valleys are classic similar variable to high pebble content soils).

Within the above, profiling the backfill of excavations and after retopsoiling such areas, such backfilled excavations and other scarified and retopsoiled disturbance areas occurring over vast areas of meso terraces can yield sort after agricultural soil profiles.

This concept in excavation backfill on meso terraces underlies the option for achieving vast post mining irrigation agriculture on the meso terrace areas by redirecting current water allocation for mining to agriculture in the transition between mining and post mining use of the land as economic base and employer in the long term.

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13.5 Natural Vegetation

13.5.1 Regional vegetation a) Informed the existing EMP of 2009 The 2009 EMP was informed by a Report on Soil Conditions, Vegetation and Wild-Life of the Baken/Reuning Mining Concession Area, Richtersveld; by Nic Geldenhuys and Associates; December 2000.

Such report was based on the work done by Prof. Norbert Jürgens of the Hamburg University of Germany, and who is generally acknowledged as a leading expert on the vegetation of the northern desert areas, including Namaqualand, Richtersveld and the Namib, and has been researching the area since the 1980’s.

As the 2020 EMP Amendment/Update now focuses on the Meso terraces with little to no impact on the hard rock hills, the focus on vegetation shift from the regional elements largely contained in the Jurgens report with the Jurgens list of plant species contained in Annexure O to this update together with a brief referral to the main finding of such Botanical Assessment.

b) Later regional botanical informant to the 2020 update The baseline assessment includes:

i. Reference to Mucina and Rutherford (2012) As per Figure 11 below Mucina and Rutherford (2012) identifies four vegetation types with their main characteristics Code and Name of Conserv. Protected Remaining Conserv. Protection Group & Biome veg. type target % % status status Bioregion Dn 4: Western 28% 0% 97% Least Not Southern Desert Gariep Low land threatened protected Namib Desert Desert Aza 3: Lower 31% 5.8% 50.3% Endangered Poorly Alluvial Azonal Gariep alluvial protected vegetation vegetation vegetation Dn 5: Western 28% 10.9% 99.1% Least Poorly Southern Desert Gariep hills Desert threatened Protection Namib Desert Dg 1: Noms 34% 100% 99.8% Least Well Gariep Desert Desert Mountain Desert threatened protected

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Figure 11: Vegetation classification of Mucina and Rutherford (2012) with GPS track and established JV Plants superimposed

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Mucina and Rutherford, and SPC notes the following respect of the classified areas: In Dn 4, Parts of the Annisvlakte on loamy sandy soils (weathered granites) are now degraded to poor and the unit has suffered considerable damge from diamond mining (the Baken proto deep channel). In AZa 3, Mucina does not accurately distinguish between the riparian zone which is a narrow band of dense mature “forest” vegetation ocuring on the Orange River bank within the flood zone of the Orange River as shown in Figures JVMP1 to 11 in Annexure F which zone was reported on well in a specialist report by James Mackenzie to African Star Minerals (Oena) in May 2019. SPC notes that the variation in this forest type treed vegetation is best seen in:

Photo 26: Petroglyphs at the Annis river road side dermacating the edge of the Annis River Orange River riaprian vegetation zone

The Reuning National Parks Board chalets complex and its opposite bank revealing mature Salix mucronata (Wild willow)

Photo 27: Mature riparian vegetation zone with Salix Mucronata; Road to Nxodap 91 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

The Jakkalsberg river pump station and old slimes dam which protrudes into the riparian zone The Baken picnic area south of the town where black Ebony (Euclea pseudbenus) occur readily Photo 28 and the route between Hennies terrace and Nxodap with numerous mature Black Ebony trees and in the drier areas Boscia albitrunca (Shepards tree) Photo 29.

Photo 28: Black Ebony (Euclea pseudbenus) at Baken Picnic area copper loading cliff

Photo 29: Black Ebony and Shepard’s Trees (Boscia albitrunca) on Hennies Terrace

Given the importance of preseving this riparian zone, SPC mapping from Google EarthTM shows the varying width and vegetation density of the riparian zone along the most predominant river banks which are mapped as a no-go zone.

ii. Extract from Northern Cape CBA classification Figure 12 shows the CBA classification of the Mining Right area ranged as follows from highest to lowest:  Blue- Protected Area. To some degree reflecting the most northerly area of the Mining Right area being the area within the Richtersveld National Park which now overlaps with the established Mining Right area but nonetheless serves as an environmental informant in the mine planning and post mining rehabilitation.  Green- Critical Biodiversity Area 1 and Yellow Critical Biodiversity Area 2: While the classification of the riparian zone along the river as a CBA 1 can be defined and justified, the distinction between the remainder of Area 1 and Area 2 cannot be 92 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

appreciated and accordingly all areas with the mining Right area are simply considered as potentially environmentally sensitive areas and treated with due respect within the context of avoiding disturbances in the first instance and conducting disturbances and their rehabilitation appropriately in the Scoping and coming EIA-EMP phase of mine planning environmental assessment level.  The two Ecological support areas are noted.

Figure 12: CBA Classification map

13.5.2 The botanical focus of the 2020 update Within the context of Para 0 Preface to the 2020 amendment update for LOR, and notably the fact that further mining will now focus on the large Meso terraces which to date have only been prospected by THG while non Meso terrace mining will largely focus on already disturbed proto terraces and reprocessing of mine dumps which activities will have no botanical impact. Accordingly in the draft scoping process, SPC has sought to identify vegetation sensitivities of the Meso terrace targets:  their interfaces with the Orange River (riparian vegetation zone,  interfaces with the hard rock hillslope toes,  the Meso terraces themselves with their scant vegetation wherein attention is now drawn to the identification of especially threatened and protected species and the way forward in dealing with these within the context of mining area definition.

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a) Riparian vegetation zone Riaprian zone vegetation though compromised by agricultural area demacations in the Swartwater area of Baken (Diagram 8 in para 13.4.3) should otherwise be protected by dermacation as no-go areas and that where of neccesity pump stations are required on the bank, the planning thereof should give special attention to the management of the riparian zone vegetation that could be affected if it cannot be totally avoided (re use of the old Swartwater and Nxodap pump stations as prefered options to meet future pumping requirements from the river). Accordingly, the riparian vegetation zone has been determined by SPC Google Earth image interpretation and demarcated in GIS as printed as a No-Go zone in each of the JVMP plans 1-11 as contained in Annexure F.

b) hardrock hillslope toes

The further mining of LOR will not impact to any significant extent on the eleveted/rocky hill montane areas which include the Dn 5 Western Gariep Hills desert inland of the alluvial plains nor the Noms Monuntain desert area where disturbance by the ealier Aace eleveted proto terrace mining was completed many years ago. Accordingly, as the vast hinterland of hardrock hills with no alluvial diamonds is not targeted for any mining and must simply be avoided from unnecesary damage by road pipeline and electrical network infrastructure, the focus of 2020 in relation to hardrock hills is on: the interface between Meso terraces to be mined and the toe of the hills. In considering interface the baseline assessments of both botanical sensitivity identifying of the Aizoaceae and Mesembryanthemaceae which can occur on the lower slopes of the hills and the extensive archaeologically important petroglyphs occuring on these lower dolomite slopes, as a precautionary measure, the scoping report has identified the interface between the meso terraces and the toe of the lower hill slopes to be declared No-go zones in the EMP Update to protect both the vegetation and the artefacts from any disturbance importantly inclusive of:  mining  dumping; and  infrastructure especially roads Refer Diagram 9 hereafter illustrating the meso terrace limitations Xharries Terrace Bloeddrif examples as will be prepared on all JVMP 1-11 in the EMP process.

c) Botanical Limitations on Meso Terraces themselves Following initial engagement of LOR with SANParks, the SANParks memo of 4 August 2020 setting out SANParks and SANBI initiatives in establishing Sandelingsdrift as a botanical garden, both LOR-D and SPC have initiated discussions with SANParks’ Brent Whittington with a view to coordinating the assessment of the vegetation of the Meso terrace surface which to the laymen who would not recognise the relavance of sparse grasses and sedges would appear as of no botanical significance yet in fact botanically supporting several threatened and protected species requiring Permits for their removal, transplant, translocation through search and rescue. 94 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Accordingly, the EMP Update process will be engaging further with SANParks who have specialists au fait with the Meso terrace vegetation who, together with LOR-D environmental personnel could conduct a GIS record of the distribution of specimens of such threatened and protected species as the baseline record on which to develop proposals. Of significance is the timeous identification and basic description of the SANParks SANBI Thematical Gardens program in Sendelingsdrift which identifies preliminary areas (and in LOR-D perspective many further areas) which can accommodate rescued plants from the meso terraces to be disturbed by mining through transplant in the Sendelingsdrift Botanical Garden.

d) Overall limitation of Meso terraces In light of the above and as shown in Diagram 9 below, the following limitations relate to meso terrace environments:  Limiting disturbance to outside the 1:100yr floodline (No-Go zone),  Limiting disturbance to outside the riparian zone (No-Go zone)  Terminating any Meso terrace disturbance before the slope rise in the toe adjacent elevated rocky hills (montane area) to protect both botany and archaeology (Petroglyphs)  Recordal and assessment of the distribution of threatened and protected species and their transplant rescue from the terrace itself where mining is indicated.  Treating the intermidiate area with extreme caution as any of the above factors could extend locally into such intermidiate area.

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Diagram 9: Meso terrace limitations e.g Xharries Terrace Bloeddrif

Photo 30: Typical Meso Terrace seen at Xharries North

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The consideration of mining the Meso terraces is further affected by the fact that overburden and non diamondiferrous horizons are relatively shallow, permitting excavations to take place on a deep strip mining basis which combined with the use of semi-mobile small processing plants allowing plant location in close proximity to mining excavations and use of in-pit screening plants to retain oversize in the excavation from the outset, the total management of the pit allows for operational rehabilitation as the pit mining progresses. Within such strip mining process with the backfill materials derived from: o In pit screened oversize o Union screen type sand removal at the plant intake for return to the pit and o Manageable coarse and fine tailings waste return to the pit from the pan plant, the pit backfill sediment profile can largely mimic the pre-mining profile returning the original “topsoil horizon” as the final upper layer suitable for natural grass and sedges re-establishment post mining or irrigated agriculture on these rehabilitated meso terraces.

e) Phenomenon of “pebble deflation surfaces” Within this desert climate, the futility of attempting revegetation or topsoiling normally associated with rehabilitation is considered within the following context:  The desert environment of the LOR eliminates the role of re-topsoiling and revegetation both of which would make no contribution despite high costs of attempts.  Within the desert environment, the most successful rehabilitation method relies on the facilitation of achieving deflation surfaces through the use of pebble and coarse tailings cover(mimicking a natural stony desert appearance) (in fact exactly what is seen on the surface of many Meso-terraces of the LOR) (refer again photo 4).  The incidence of naturally occurring dust storms and the naturally high ambient dust levels mitigate the use of wind-speed reduction shade cloth netting which would otherwise be applied where wind-blown sand movement either threatens adjacent vegetation through smothering or abrasion, or would be an integral part of managing re-topsoiled and revegetated areas (as is the case in coastal diamond mining where revegetation is a prime factor).  As achieving the post mining land use through well directed rehabilitation to closure is a central Objective of LOR Closure as discussed within the context of the post mining land use plan as shown in Figure 10 and extensive irrigation agriculture to be considered in these reshaped post mining meso terraces, it is fundamental that the future compilers of Annual Rehabilitation Plans familiarise themselves with the considerations underlying and proposals of the Post Mining Land Use Plan in terms of both the general perspective and the details of the area in which the rehabilitation is being planned as the outcome of the control intended to be applied to operational excavation backfill and pit closure retopsoiling from stockpiled topsoil.  Especially where mobile wind-blown sands pose a threat to post mining stability of any previously disturbed area including these rehabilitated terraces, creation of a 97 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

“pebble deflation surface” by spreading a pebble layer (from future pit screening or the vast existing THG coarse tailings dumps) to mimic natural “pebble deflation surface” as seen in photo 4 below typical of the Aace area meso terraces is advocated.

Photo 4 (repeat): Phospecting trench through the erosion remnant of one of the southern Aace meso terraces showing intense pebble deflation surface. Such post mining pebble deflation surfaces provide a soil micro climate with cool pebble condensation on their under surface providing sufficient night-time moisture to support lichen development as the first stage in then supporting wind blown seed germination during any moist period as is seen in the natural revegetation occurring in a coarse overburden dump along the Richterveld park access road north of the Baken Central pit area (photo 19 below). Also, in relation to plant area rehabilitation, this principle of covering the surface of ripped previously hardened areasm or retained concrete floors, with a layer of coarse tailings will mimic such a pebble deflation surface in which its role will be to trap in- blown sand as fine fraction together with in-blown seed which in the coarser pebble profile will provide a cooler and condensate generation soil environment for natural grassing following favourable rain episodes.

Photo 19: Coarse tailings dump mimicking a natural "pebble deflation surface" showing germination of in-blown seed

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13.6 Animal life The information provided in this section of the report was obtained to inform the approved EMP from a specialist study undertaken by Soil and Irrigation directorate of the Department of Agricultural Technical services 1979 (NGB Report 912/143/79).

13.6.1 Amphibians and Reptiles

a) Amphibians In general, due to the location of their habitats such as springs, streams, and temporary pools outside the main river course, most of these species will not be affected by mining along the Orange River which has the added benefit of the 2020 1:100 year floodline and riparian zone mining setback. The species under consideration include the common river frog Africana angolensi, the Cape river frog Africana fuscigula, and the Clicking stream frog Stongylopus grayi which occur along the main course of the Orange River.

b) Reptiles The confirmed reptile species for the Richtersveld comprises two tortoises, 38 lizards and 20 snakes. Of these, 10 are endemic to Namaqualand, with two of these endemic to the Richtersveld specifically. One lizard species, Lawrence’s girdled lizard Cordylus lawrenci, is listed as a red data species in the “restricted” category. (i) Tortoises The three tortoise species recorded from the Richtersveld area are the Speckled Padloper Homopus signatus signatus, the angulate tortoise Chersine angulata, and the Namaqualand tent tortoise Psammobates tentorius trimeni. All have a wide range along the western and southern coastal regions of Southern Africa, and the Richtersveld forms the northern most limit of their range with only a few sighting. They therefore occur in such low numbers and mining activities along the Orange River cannot be considered as posing a threat to these species.

(ii) Lizards Of the 38 lizard species occurring in the Richtersveld area, geckos are by far the most diverse group, comprising of 17 species. Most of the lizard species have extensive ranges in Southern Africa and on a species level, these will not be negatively affected by mining activities along the Orange River. However, at least seven lizard species occurring in the general area, have restricted ranges and mining activities could potentially impact negatively on them. This is off-set, however, by their restricted habitat types, being mostly mountainous areas and boulder-strewn areas away from the Orange River, and therefore make it extremely unlikely that these species will be influenced by the mining activities in the concession area. One can also probably safely conclude that the diamond-bearing gravel terraces along the Orange River are not seen as a particularly sensitive habitat and mining of these terraces will have limited impact on local herpetofauna.

Despite this, it should also be considered that the following three lizard species are in some way or another closely associated with the Orange River and may therefore be

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impacted on by mining activities along the river. Care should therefore be taken to avoid physical intrusion into the river area:  The rough-scaled gecko Pachudactylus rugosus has only been recorded from Sendelingsdrift where it is often associated with trees and most often found under bark. More records are likely from riverine vegetation along the Orange River and will now be protected in the no-go riparian zone.  The tree skink Mabuya spilogaster is restricted to regions along the Orange River supporting riverine trees. It has been recorded at Sendelingsdrift and Bloeddrif, but also has an extensive range in Southern Africa.  There are reliable reports of the presence of the water leguaan Varanus nilotocus along the Orange River in areas where vegetation approaches the banks. Mining activities are seen as potentially disruptive to leguaans as it affects chiefly the riparian corridors occupied by these large lizards. This species was previously listed as a red data species, but is considered out of danger in the latest listings and will now be protected in the no-go riparian zone.

(iii) Snakes Twenty species of snakes have been recorded in the Richtersveld area with a further five species possibly also occurring in the area. Of these, a single record for the twin- striped shovel-snout Prosymna bivittata exists from Kuboes. It’s presence in the Trans Hex mining area has not been confirmed. A similar situation probably exists in the case of the spotted skaapsteker Psammophylax rhombeatus, an isolated population having been reported from the Richtersveld, on the Vandersterrberg and associated western mountains receiving advective fog. In summary, of the 25 species of snakes potentially occurring in the Richtersveld, 21 have extensive ranges in Southern Africa and mining activities along the lower Orange River will not have any significant effect on these species at the species level. The four more restricted species area confined to areas outside of the mining area and it would appear that these would not be affected by mining activities in the Trans Hex area. Although most snakes are fairly mobile, a few of the more common species may be associated with sandy areas along the Orange River. Heavy traffic in these and other areas may be the cause of snake mortalities and could be minimised if the number of roads in the mining area are restricted.

c) Birds Approximately 200 bird species are known from the Richtersveld National Park, but the Richtersveld area in general is not noted for high avian endemicity except for small radiation of Certhilauda larks. Three terrestrial species potentially occurring in the Richtersveld are listed as red data species. The Martial eagle Plemeatus bellicosus and the Kori bustard Ardeotis kor were identified as of conservation concern in South Africa and were listed as vulnerable (Brooke 1984). If present in the mining lease area, it will be in such low numbers that mining activities cannot possibly have any direct influence on these species. The Red lark Certhilauda burra is also considered of conservation concern. It is endemic to the Northern Cape province, but its presence in the Richtersveld has not yet been confirmed. 100 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

The high number of bird species recorded in the area is to a great extent due to the riparian corridor provided by the Orange River. At least 60 – 70 species are closely associated with the Orange river and its riverine vegetation and do not occur in the adjacent dry terrestrial habitats. Accordingly, the riparian no go zone under this 2020 update will provide protection for these riverine vegetation species. The close proximity to the sea and the Orange River mouth wetlands also allows for a number of marginal occurrences.

Approximately 130 species occur in dry terrestrial habitats away from the river and in most of these species the overall number of individuals is likely to be very low. The species have been recorded in the Richtersveld area, all have extensive ranges in Southern Africa and mining activities along the lower Orange River will not have any species-levels impact. Due to the high number of birds associated with the river, local impact may be extensive. The riparian zone is therefore considered as sensitive habitat and is protected as a new no-go riparian zone.

d) Mammals The total number of mammal species potentially occurring in the Richtersveld is 47. Of these, Hartmann’s Mountain Zebra favours the more mountainous northern and eastern areas of the Richtersveld. A very small population (<10 individuals) of Brown hyena also occurs in the Richtersveld and a population near Oranjemund seems to survive without difficulty despite the high level of human activity. No record of golden moles and molerats exist for the Richtersveld, but some of the species may potentially occur along the sandy habitats along the Orange River. At least ten bat species potentially occur in the area and some may be associated with the riparian vegetation of the Orange River.

At least four other mammal species are closely associated with riparian zone of the Orange River:  The vervet monkey, Cercopithecus aethiops, in South Africa mainly an eastern form, occurs along the Orange River form the east to the west wherever the riverine woodland is sufficiently developed to provide fruit-bearing trees and cover (Skinner & Smithers 1990).  The black-tailed tree rat, Thallomys ngricauda, is associated with Acacia woodland and has its main distribution in Botswana and the eastern half of Namibia. Its range, however, extends into South Africa along a narrow zone partly formed by the riparian woodland vegetation of the Orange River (Skinner & Smithers 1999). It is an arboreal species, living in hollow trunks and branches or under the loose bark of trees.  The Cape clawless otter, Aonyx capensis, is predominantly aquatic. Through its range, it occurs in rivers, lakes, swamps and dams and moves freely up the tributaries of rivers into small streams. If they wander from water, they invariably return to it, as it is an essential requirement. Its diet consists of fish, frogs and crabs.  Throughout this range, the water mongoose, Atilax paludinosus, occurs in the vicinity of rivers, streams and dams where there is adjacent cover of reed beds 101 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

or dense stands of semi-aquatic grasses. It is an opportunistic feeder and will eat anything from small rodents, birds, frogs and fish to insects and fruit.

Although all four species have extensive ranges elsewhere in Southern Africa, mining activities along the Orange River may have considerable local impact on these species because of the restricted nature of their habitat and will be protected within the no- go riparian zone.

All species potentially occurring in the Richtersveld area and therefore in the Trans Hex mining concession area have a high mobility, are not endangered and mining activities along the Orange River area will have no species level impact on any of these species. Sensitive habitats in the mining lease area would include the riparian zone of the Orange River and accordingly this Scoping report already identifies it as a no go area for mining. e) Insects As no night time field work is contemplated by LOR-D, nocturnal insects, bats and bird life is not expected to be impacted by the day-time mining program as currently considered.

13.6.2 Conclusion on Animal Life • Two frog and two lizard species are endemic to the Richtersveld, while six frog and eight reptile species are endemic to Namaqualand. There are no endemic birds or mammals in the area. • Mining activities along the lower Orange River, from Swartpoort in the north to Baken in the south, does not pose a direct threat to any vertebrate species. The majority of species occurring in the area, have extensive ranges in Southern Africa. Those with more restricted ranges, occur in the more mountainous south- eastern parts of the Richtersveld in the Richtersveld national park, far from the mining areas along the Orange River. • The riparian zone of the Orange River supports a number of amphibian, lizard, bird and mammal species that are restricted to the riverine vegetation. Although none of these species are endangered, they form part of a very sensitive ecosystem. • The diamond bearing gravel terraces along the Orange River, which serve as the primary activity site of current mining operations, support few vertebrate species, if any. The few lizard species that may occur on these terraces, have extensive ranges and also occur in a variety of other habitats.

Definition of the no go riparian zone is therefore fundamental to protecting both vegetation and animal life in this zone under this EMP for LOR-D.

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13.7 Surface water

13.7.1 Surface water characteristics As described in para 13.3c and Figure A-3 (in para 13.3 a) the mining lease drains directly via 5 main episodic channels into the Orange River over a length of 55km of the Orange River with the lowest such discharge point being the Springklip channel which enters the Orange River some 20km upstream of the Orange River Estuary (an earlier proclaimed Ramsar Site).

As such, mines in the LOR are the custodians of the river bank stability and to a large extent responsible for managing the discharges into the River over the 55km frontage and accordingly protection of a riparian zone no go area and the 1:100yr floodline is to be respected.

13.7.1.1 Catchment Figure A-3 shows the main catchments and the respective channels in km² as follows and how the various elements of the mine relate to these:

Major mining satellite areas (excavations) which impact on such drainage channels: • Bloubos River on Suidhek at Reuning. • Springklip River on Terrace 1 and 2 Satellite areas. • Baken channels on Swartwater and Koeskop Satellite. • Drainage channels flowing through the town of Baken. Main Catchment Main Episodic River / Catchment Area in No. Channel km² A Bloubos River 120 B Annis / Orab River 450 C Springklip Channel 120 D Baken Mine Channels 43 E Karis River(Kaais River) 30

13.7.1.2 MAR (Mean Annual Run-off) Concerning the MARs of the episodic rivers, their odd rainfall pattern, poor statistics, dry sand substrate and major sponge capacity of the sand filled run-off channels, render the application of formula in attempting an MAR calculation of the mining area futile.

The other option of taking a cautionary approach to and avoiding stream channel interference wherever possible is chosen instead. Where channel interference/crossing is absolutely necessary, it is proposed to assess the required channel width and depth for the cross sectional size of the previous storm channel incision into the river bed sands upstream or downstream of the interference point and provide for an equivalent episode. Never place stockpiles temporary or permanently across such episodic channels. To never place tailings heaps dry nor wet across such channels.

Where mining of necessity crosses or has crossed such channel such as at Koeskop East and Swartwater, to provide for accommodation of a flood occurrence into these

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excavations. (As such flood occurrence will never exceed the temporary holding capacity of these large excavations, no danger of downstream Orange River siltation from this situation will arise). If the necessity to pump such flood water from the excavations should arise, the water quality must first be tested and approval obtained from the Department of Water Affairs and Forestry to conduct such pumping or alternatively to pump such water into the process via the slimes dams as settling ponds.

13.7.1.3 Normal Dry Flow None of the episodic rivers by definition show normal dry weather flow while the nominal flow rate of the Orange River is recorded as 53m³/second at time of the Hattingh reporting of (2001) 1:100 yr flood determination. Subsequent to such determination, further dams have been built on the Orange River and the fish river, reverse pumping on the Vaal River has been reduced and extensive irrigation pumping downstream of Priska is now occurring with very noticeable low flow this past year at the Rosh Pinah cause-way.

13.7.1.4 Flood Peaks a) Statistics used in determining the floodline elevation at various points in the Mining Right area For the Orange River the maximum discharge is recorded as 8300m³/s at Vioolsdrift, (1974) some 4000m³/s short of the calculated 1:100 year flood. Refer Appendix C report on the results of a 1:100 year flood level survey along the Orange River in the Mine Lease area of Trans Hex mining Ltd in the Richtersveld; J Hattingh; February 2001. The results of this study shows a 1:100 year flood level at the following heights above MSC (i.e. contour elevation) for the respective stations at which mining activities occur.

The MAR of the lower Orange River is given as 9344 mil m³ while its peak flood flow for 1974 flood at Vioolsdrift was set at 8300m³/second. Locality Stage Height Swartpoort 26.1 52.2 Confined valley Reuning 20.4 44.8 Semi-confined valley Suid Hek 19.0 39.2 Wide Floodplain Nxodap 19.2 38.9 Semi-confined valley Xarries N 18.0 31.7 Wide Floodplain Bloeddrif 17.5 27.9 Wide Floodplain Sanddrif 17.4 27.8 Wide Floodplain Baken 17.2 27.6 Wide Floodplain Swartwater 17.1 27.5 Wide Floodplain Source: J Hattingh 2001 Such assessment informed the 1:100 yr floodline now shown in the individual JVMP Figures JVMP 1 to 11 in Annexure F.

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Photo 31: Remnants of 1974 silt bank

b) 2020 considerations in now reviewing the basis of the Hattingh determined floodline in 2001 In this 2020 review of inputs to mine planning and environmental management, there may be merits in reconsidering the floodline against the following facts contained in:  Table from Zawada et al. 1996 reflecting flood flows from 1925 to 1988

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 a table in Annexure P: “Factors in reviewing 1:100 year floodline” which include: (i) The 4 dams built on the Vaal/Fish/Orange River catchment post 1974 and a 5th planned dam for 2024 representing a 46% increase in dam capacity on the 3 river systems since 1974 which was the peak flood considered in this EIA update process. Orange/Vaal/Fish River dam history capacity impact on flood flow reduction Built Dam name Capacity (mil. m³) Post 1974 Capacity (mil. m³) 1974 flood is 7 799m³/s

1962 Hardap Dam (fish river NAM) 420 1969 Gariep (Verwoed) dam 5340 1970 Bloemhof dam (Vaal River) 1269 1972 Naute Dam ( Fish River NAM) 69

1973 Welbedacht dam (Caledon Riv) 10.3 1977 VanderKloof (PK Le Roux) dam 3236 3236 2005 Mohale Dam (Lesotho OR) 7.5 7.5 2009 Katse Dam (Lesotho OR) 1950 1950 2018 Neckartal Dam (Fish River NAM) 880 880 Total large dams 13181.8 6073.5

Planned 2024 /Pella Dam 2800 2800 (ii) Large scale direct pumping over the past 25 years in the summer peak run-off season to irrigation downstream of Prieska.

c) Overview of LOR-D water As the scoping analysis to date has considered the current Water License ceded by Transhex to LOR-D as contained in Annexure D “Water Discussion with Figure W-1” and now raises the question of the floodline based on very historical maximum flow rate, it is proposed that as part of the remaining scoping process, DWS Upington is engaged with LOR-D as a specialist input in discussion of water inclusive of the matter of post mining potential for redirecting water now dedicated to mining, to community and commercial agriculture during the towards closure operational rehabilitation period and post mining land use agricultural development.

13.7.1.5 No river diversion is envisaged Only a single new pumping point to supply the small Swartpoort mining area in the extreme north is considered a River Diversion in terms of the Act and accordingly an application will be made for such diversion, while the volume to be pumped at that point will be part of the current License allocation in respect of Reuning (refer Annexure D: Water discussion with Figure W-1) table of Authorised water use i.t.o 20 (a).

13.7.2 Surface Water Quality Recent samples taken from the Orange River at Beauvallon 10 km downstream of the lease area under low flow conditions show the TSS and chemical results as contained in Annexure D-3. As it is recorded that the Orange River carries a 60,4 x 10° ton silt load annually into the sea*1, siltation contribution by the mining activities which are 106 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

well recessed from the river bank will not make any significant impact on such load provided that injudicious practices such as the following are avoided: • location of dumps or fine tailings ponds in run-off channels such as at Nxodap. • failure of tailings pond walls. Given that the Orange River Estuary (RAMSAR) exists only 30km downstream, no unnecessary siltation nor chemical contamination of the river can be tolerated.

In terms of the National Water Act, 1998 (Act 36 of 1998) Regulations as Gazetted on 4 June 1999 Vol. 408 No. 20119, the mine management’s attention is drawn to the restriction relating to locality of facilities near streams, restriction on the use of pollutants near streams, protection of water resources, especially relating to purification of leachate, avoidance of relocation of channels, achieving maximum recycling, and the need for a permit for any discharge into the river.

13.7.3 Drainage Density Refer table in Figure A-3.

[*1. Bremmet et al 1990 sedimentological aspects of the 1988 Orange River Floods. Transactions of the Royal Society of South Africa; 47: 274 – 294 and WRC Report No. TT62/93].

Further refer specialist Surface Water Investigation by E-Tek in Annexure H2 and stream flow diversion consideration in Annexure H1.

13.7.4 Minimising the risk of post mining silt discharge into the Orange River The Orange River Estuary classification as a RAMSAR site emphasises the need to maintain or improve the stability of the estuary. As reduced flooding intensity by dam building and water extraction from the River and tributaries has reduced silt flushing from the estuary, the rehabilitation of the mining disturbances must ensure that long-term silt discharge is minimised in respect of both direct runoff from mine silt sources and silt loading of natural drainage channels passing through or immediately adjacent to mining disturbances.

This topic on stormwater management in closure was further informed by consideration of the 14 September 2014 specialist Surface Water Investigation Report including proposals for drainage channel and stream diversion compiled by: E-TEK Consulting Engineers (as contained in Annexure H-2) to inform the EMP and is now being further integrated with mine rehabilitation considerations.

Regarding silt impact minimisation, the following two elements of stormwater/silt management must be considered in all future Rehabilitation Planning:

a) Cut-off of silt laden episodic stormwater discharge by established channels and excavation areas. The episodic drainage channels of the greater Mining Right area and its hinterland, naturally (irrespective of mining) carry high silt loads during intense (though very seldom) high flow episodes. In order to ensure that such silt load of the Orange River now compounded by silt derived from the mining

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excavations and overburden dumps is not increased, the following four rehabilitation measures are advocated: (i) All excavations are to be rehabilitated by making them internally draining by either restricting backfill to slightly below original ground level or by providing silt/stormwater cut-off channels leading to depressions retained in the excavation or backfill area as silt traps. (ii) Where long linear mining trenches such as the Baken and Bloeddrif trenches have intersected a number of natural drainage channels, any mine berms placed to prevent such channels draining into the excavation as per Photo 5 below are to be removed allowing such silt laden episodic flow of these channels to enter the silt trap provided by the reduced level of channel backfill and not proceed to flow into the Orange River.

Photo 32: Baken excavation perimeter berm preventing stormwater entering excavation during mining. Berm to be removed to permit free flow of natural silt laden stormwater into the dished excavation backfill to serve as silt trap in post mining

(iii) Where a drainage channel can pose the risk of future meandering locally undercutting the toe of adjacent dumps leading to increased long-term silt discharge into the Orange River, as for instance where the Xheis channel approaches Baken Town, the toe of the dump shall be provided with Gabion basket erosion protection walls over short distances to deflect such meandered flow away from the dump and avoid additional silt load (as advocated as generic method in the specialist stormwater report to the approved EMP). (iv) Where the possibility exists, to slightly divert high silt load drainage channels into an excavation which can act as a stormwater detention pond and silt trap, such local diversion should be implemented as per the example below. b) The Baken perimeter dump stormwater management implementation plan: The following example of the intended rehabilitation measures for stormwater management where natural storm water channels having been intersected by large overburden dumps, (now rounded) pose the threat of significant dump-toe undercutting and significant silt discharge over the long-term to the Orange River.

As shown in Diagram 10 below, the stormwater management entails the following further silt risk and silt discharge to the Orange River reduction measures:

I. The upper (largest eastern channel) is to be diverted around the eastern-end of the long rounded overburden dumps in order that the natural silt laden water of the

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channel can discharge into the Baken excavation (stormwater detention pond/slit trap) and significantly reduce the flow from the dendritic stormwater channels to be managed by the diversion channel between the road and the dumps. II. A diversion channel be dug parallel to the public road to capture the smaller dendritic stormwater channels, avoiding any risk of under-cutting the toe of the rounded dumps. III. Aligning such channels’ discharge into the local depression formed by the western ridge and the yet unrounded dumps to its north. Such depression will serve as stormwater retention pond and silt trap with significant capacity. This is a typical example of the stream diversions provided for in the E-TEK specialist report to the approved EMP.

Diagram 10: Baken Perimeter Dump Channel Diversion to avoid dump-toe erosion and Orange River siltation

c) Regarding slimes dams as long-term silt sources, the following measures are identified to reduce silt discharge risk to the Orange River: o Discontinue the enlargement of existing or creating of new slimes dams and redirect all future slimes into excavations as at Baken in the photo 33 below

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Photo 33: Directing of BCP slimes to Baken Deep-channel backfill areas

o Provide cut-off channels on the upper slopes above relevant slimes dams such as Baken to ensure that no sheet flow erodes such dams or causes their wall over-topping in the long term o To shape dried slimes dam walls to suitable angles and armour these and slimes dam surfaces with coarse tailings to increase their long term stability. (This armouring of the dam surfaces is to consider an option for the retention of certain slimes dam through reed- bed encouragement in the short term to introduce fibrous vegetation (reed, root/rhizomes) to increase slimes dams surface stability and possibly present them in the medium term for irrigated agricultural production where such dams are located at low levels above the Orange River water source). Fortunately, as all processing used fresh water (with no residual chemical content nor salt from sea water processing as at coastal mines), numerous slimes dams present a good salt-free hydroponic medium for irrigation in close proximity to the OR. o To give further consideration to the coarse tailings protection of the low lying slimes dam of Jakkalsberg (photo below) which could possibly be subjected to erosion under very high flood. As per Photo 34 below, the adjacent coarse tailings dump offers the opportunity for use in the discontinued dam’s wall protection.

Photo 34: Previous Jakkelsberg slimes dams possibly subject to 1:50 or 1:100 flood erosion of its walls. Coarse tailings dump to right for armouring of wall by bund protection (refer Diagram below)

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Diagram showing proposed armouring

13.7.5 Consideration of the existing water license Refer Annexure D Water Discussion with Figure W-1 and Annexure D1- Copy of 2017 Water License no: 10/D82L/ABCGIJ/5161.

13.8 Groundwater a) Depth of Water Table No boreholes on the mine penetrate the bedrock, nor is any groundwater used on the mine. The only groundwater table relevant to this exercise is that of locally perched water table on the palaeo bedrock surface as observed in certain mining areas of depths varying from a meso terrace ±10m to the Baken Deep Channel 70m below ngl.

As shown in the geological cross section Diagram 11 below, these palaeo channels do not always connect to the present Orange River channel nor drain into it and consequently often represent very separate localised groundwater basins.

Diagram 11: Typical cross-section where proto gravel horse-shoe channel is present

Water chemistry in these basins has been found to be extremely variable (between fresh and highly saline). The chemical analysis given in Annexure D-4: “Analysis of perched groundwater from Baken Palaeo channel excavation” of water taken from a Baken Mega Trench shows salinity but given the restricted volumes of such water,

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none of the sumps require pumping from the excavation and therefore the water quality of these minor perched water bodies has no relevance.

During mining the water is temporarily pumped to a coffer dam within the excavation floor to provide for sweeping of the dry sump floor.

b) There are no springs in the lease area. c) No use is current made of Groundwater in the lease area but the license provides for pumping of seepage of groundwater into excavations. However, a borehole does exist in Bloeddrif which is not operational and its registration status requires to be determined. d) The area falls within the Groundwater zone “A” which does not permit extraction of groundwater. e) No river diversions are contemplated.

13.9 Air Quality While the volume of overburden dumped by mining activities at any time exceeds the limit of the Atmospheric Pollutant Prevention Act, 1965(Act 45 of 1965) which limits dumps to 20 000m³, the site falls within the south Namib Desert characterised by mobile dune sands with naturally occurring dust storms thereby largely reducing implications for mining in this regard.

While fall-out dust is observed as being low on days of normal wind strength, dust storm conditions often occur in the mining area as in the surrounding area under high wind speed conditions.

As no chemicals are used and no combustion processes are used, there is no smoke nor chemical discharge into the atmosphere other than minor smoke from the burning of domestic waste at the domestic waste disposal sites of Baken and Reuning. (Both burning sites are approved by the Department of Environmental, Cultural Affairs and Sport, refer para 4.2.1 f).

13.10 Noise The only noise in the area is mine generated noise emanating from: • excavation equipment. • vehicle movement on haul roads. • plant. • other vehicle noise. As the production areas are isolated from any surrounding uses, public roads and mine residents of Baken and Reuning and as such noise levels from on-site observations do not exceed normal residential noise levels of 55dB in the mining towns noise is not a significant.

In light of the above no dust or noise monitoring is conducted/contemplated given the dispersed nature of activities and their isolation. No levels of noise which exceed

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SABS standards for residential areas have been noted by Site Plan personnel in the town of Reuning, Baken and Sanddrif. In respect of plant noise to which personnel are subject in the work place, such noise will continue to be monitored in terms of the Mine Health and Safety Act and appropriate noise attenuation measures and PPE prescribed.

13.11 Sites of Archaeological and cultural interest

13.11.1 Specialist reports As THG at the time was aware of the vast distribution of petroglyphs and grave sites, during 1997 Trans Hex Mining appointed The Archaeological Contracts Office to conduct a study of the area and report on the archaeology of the lease area. The findings of the Phase One and follow up study as presented in a Report entitled: A Phase One Archaeological Assessment of Heritage Resources in the Trans Hex Diamond Concession; Richtersveld; dated June 1999, referred to as Appendix B with a detail follow up report (electronically presented) for Jakkalsberg in October 2001 informed the 2009 EMP. Accordingly, the site localities were captured in what is now Figure A-5 together with the table of archaeological sites (overleaf).

13.11.2 Archaeological sites The distribution of archaeological sites by site ID number is shown in Figure A-5 while the code used per site links it to the numbered site particulars in the table 13.11.2 following the plan. As Figure A-5 only shows one example of the detail insert plans and only two illustrative photographs from the specialist report, the reader is further referred to the two specialist reports (Annexures Q1 and Q2 hereto). (Given the enormity of the scoping report and its Annexures, only the pertinent Pages 1 to 47 of the Phase One report are included while its Appendixes discussing legal elements are not included but available on request). For photos of petroglyphs refer specialist report in Annexure Q1 and Figure A-5 (overleaf).

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Figure A-5: Geology, soils, topography, drainage and Archaeology

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Table 13.11.1: Table of Archaeological sites

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13.11.3 Elements of Archaeological interest While the artefact scatters date between <2000 and >2000 years before present only BLD 34A is dated as old as <10 000 years placing the artefacts all in the Late Stone Age in fact Holocene Period (last 10 000 years) with one presenting site 34A classified as Middle Stone Age.

The following extract from the Phase One report is of interest in this regard:

During most of the Holocene (last 10 000 years) southern Africa was inhabited by small groups of San hunter-foragers who were highly mobile. They hunted with bows and arrows, snared small animals and, where groups lived close to the shore, gathered shellfish and other marine resources, a habit which resulted in the use of the terms “Strandlopers”. They used digging sticks, often weighted with bored stones, to find a variety of subterranean vegetable foods, particularly iridaceous bulbs.

Having prodigious knowledge of the environment and the resources around them, their cultural repertoire included a complex belief system, aspects of which are represented in many rock paintings and engraving sites in the northern and western Cape. Many paintings and engravings are understood as being closely linked with shamanistic ritual or belief (Lewis – Williams 1981).

The occurrence of sheep and pottery remains in archaeological sites dating to the last 2000 years and younger points to the appearance at that period of a new economy and way of life based on pastoralism. It seems most likely that groups of people, probably the ancestors of the Khoekhoen of colonial times adopted pastoralism, in this case with herds of fat-tailed sheep and later cattle (Smith 1987, Sealy and Yates 1994).

With the advent of pastoralism, or soon afterwards, ceramic technology was introduced. While some San groups appear to have co-existed with pastoralists, it has been suggested that hunter-foragers were marginalized moving to areas where grazing opportunities were less attractive to pastoralists (Parkington et al 1986). The precise origin of early stock keeping and ceramic technology in southern Africa is still unclear but it is suggested that it was introduced from the north.

By comparison to the old artefact scatter, the petroglyphs (rock engravings) and burial sites (graves) date back to less than 300 years i.e. the colonial period, having been inscribed in the rock by the Khoekhoen pastorilists and hunter foragers with the result that certain of the engravings depict ox-wagons.

Photo EF8 shows an example of the typical rock engravings/petroglyphs mainly made in the dark coloured, easily engravable dolomitic limestones of the Bloeddrif area while photo EF9 shows one of the many grave sites recorded. (Many of the graves are pioneer children’s graves who died of the Flu epidemic of 1913-1916).

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13.11.4 Damage to sites between 2001 and 2020 Already recorded in the earlier EMP is the earlier damage to a very valuable petroglyph site on the western slope of the hill at Bloeddrif where large overburden rock has been dumped on the petroglyph site while old Bloeddrif buildings constructed by Octha Diamonds damaged a floodplain petroglyph site at Bloeddrif and a road to the river has further impacted on the Bloeddrif (No. 28) site.

Later erection of a viewing platform at the Annis River cluster of petroglyphs had such a negative vandalised impact that the platform was completely removed. By comparison, a photograph 20 in the Phase One report acknowledges that “graves demarcated by fencing erected by Transhex certainly prevents accidental damage.” Furthermore, many petroglyphs are defaced by recent graffiti.

As seen in Figure A-5 the occurrence of archaeological sites are quite distant from proposed mining areas and while possibly not requiring protection from direct mining they will require protection from associated infrastructure, logistical facilities and increased habitation of the area.

Chapter 9 of the Phase One Study Area contains recommendations on heritage management procedure for the company and these will be considered in the EIA- EMP phase of this application. Such chapter 9 is contained in Annexure Q1.

13.12 Sensitive Landscapes Within the regional and long term (post-mining) perspective there is no doubt that the lease area and the wedge of land between it and the present Richtersveld National Park will best be included as part of the wilderness eco-tourism resource inclusive of potential irrigation agriculture.

From the following photos, it is obvious that the preservation of unspoiled wilderness landscapes and views classifying as attractive tourism views are important for them to fulfil their role in the post mining use of Mining Right area into its post mining tourism function in order that incorporation of this portion of the lease area especially the Jakkalsberg to Nxodap river areas will make a major contribution to the attraction of the Transfrontier Park.

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Photo 35: Magnificent unspoiled scenery seen from the main access road to Reuning

Photo 36: The stoney desert environment seen from Jakkalsberg

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Photo 38: Spectacular northward views along river from Photo 37: Spectacular river scenery between Jakkalsberg and Hennies Terrace Nxodap

Photo 39: Spectacular northward views of the distant Namibian mountains from Balcony of the Reuning Club (SANSParks office)

On the question of development and rehabilitation context certain fundamental decisions must be taken as the basis for formalisation of a rehabilitation aim and process in so far as it pertains to the overall revitalisation of post mining landscapes within the Transfrontier Park. The EMPR bases its proposal in this regard on the following questions / statements: • why do we in South Africa at the cost of millions of rands demolish the old Okiep Copper Mine leaving a bare landscape when in fact O’kiep is synonymous with a 300 year history of copper mining? Is such mine not part of our history and in fact our Cornish mining heritage? While we are tearing down our mining heritage millions of tourists visit the cornish pump houses of the Lands – End mining town in England. • why does the retention of mining towns and old works in Arizona serve as major tourist attractions yet we insist on demolishing them, as we do coastal whaling stations and fish factories? • does the outback tourist really come to see the red data lizards and flowers or does he visit the wilderness for an overall wilderness experience? In such experience he no doubt becomes appreciative of its harshness and remoteness and we believe is impressed as part of the experience to be exposed to the challenges which he sees earlier miners of Numees copper prospects and Sendelingsdrift diamond miners had endured. 119 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

It should therefore be the aim of the EMPR in respect of Sensitive Landscape to: a) not unnecessarily disturb any areas by mining, roadside material selection or uncontrolled 4x4 activity as visual scars, as they take years to heal in the desert environment. b) fully rehabilitate all minor and major works which would leave a tatty landscape impact but also, c) identify impressive features which are of such scale, mining relevance or other nature to warrant their preservation as a mining feature to be incorporated into the tourism experience. Deep plunge pools and remnant mega-trenches surely qualify for this classification.

Photo 40: Baken remaining deep prospecting trench

13.13 Visual Aspects As reflected in Figure A-3, most of the mining areas lie low-down in the western extremities of the catchment basins, well isolated from any views from public roads as reflected by the distant view of the Baken operations from the Kuboes/Sandrift intersection (see photo 41).

Photo 41: View of the Baken Central Plant not visible despite size

Exceptions to this are: • the overburden heaps of Swartwater (Baken south) along the Alexander Bay – Kuboes road (photo 42).

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Photo 42: Rounded overburden dumps along the Alexander Bay – Kuboes road

• future mining impacts of Terrace 1 and Terrace 2 south of Swartwater. • Reuning – Mehl – Southgate insofar as these areas and plant are exposed to visitors to the Richtersveld National Park who collect their gate entrance tickets at the National Park’s offices in Reuning (photo 43).

Photo 43: Mehl-South gate public visitor road to Reuning FRP

Given the scale of operations in the total lease area, the resultant visual impacts are in fact fairly limited but within the pristine riverine landscape with stark mountain backdrops, the areas of Nxodap and Jakkalsberg require special care and serious consideration should be given to not unnecessarily disturb the Hennie’s Terrace backdrop area area given it’s special scenic value as seen in photo 44.

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Photo 44: Scenic Hennies Terrace In fact the impacts of the mining attract less negative public complaints than do the small ad-hoc gravel borrow pits for road maintenance along the public roads such as the pit at Cornellsberg.

As the major operational impact pertains to visual impact of especially overburden dumps, the EMPR highlights this aspect of the mine and the EMP provides for the reprocessing of the coarse tailings dumps and appropriate disposal of the resulted material as backfill of excavations. Visual impact of the dumps relates to three elements namely: a) shape; b) colour; and c) texture at closer view.

a. With respect to shape in the natural landscape of the lease area the southern area Baken is characterised by both: (i) flat topped old terrace gravel deposits as seen in photo 45 with 43° natural edge slopes, while other conditions are,

Photo 45: Flat topped gravel terrace deposits

(ii) rounded or jiggered skyline (photo 46)

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Photo 46: Rounded or jiggered skyline backdrop to mining operations

In terms of blending dump shapes into the surrounding topography, both rounded and flat topped terrace-like shapes can be accommodated with success in the Baken area.

b. In terms of colour of material, the deep overburden does not differ in colour from the soils of the southern mining area nor those of the alluvial soils of the northern area, thus enabling blending of dumps with alluvial material backgrounds.

The yellow sub-soils do however, contrast sharply with the dark rock outcrops of the steep hills of especially Bloeddrif – Jackalsberg and Mehl areas as seen in photo 46. Here colour contrast emphasises form and greater care is required in blending the dump into its natural backdrop.

c. Texture - as most natural terraces are characterised by surface deflation cobbles and pebbles as per photo 47 (Baken Lower Terrace), a dump which is partially armoured with a cobble surface as in photo 19 presents a much more natural appearance and appears to host more rapid revegetation (probably related to the shade and under- side moisture (condensation under the large pebbles / boulders).

Photo 47: Natural Cobble deflation surface Baken lower terrace

While a significant level of visual impact as presently experienced is to be expected for the life of mine, visual impact is probable, presently at its peak and will, through precautious including positioning and shaping of dumps be reduced in further operations especially where continuous backfill of mining operations can provide the sought after altenative.

Of cardinal importance in avoiding further visual impact is: • not permitting off-road tracks in the veld and up steep slopes.

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• not siting bright colour water tanks on hills. • achieving appropriate shaping of dry tailings dumps. • not routing electricity supply lines along scenic travel routes (photo 48).

Photo 48: Powerline impact on main tourism route into the Park

13.14 Land Capability a) Pre-Mining Land Capability of the Lease Area As shown in table below and Figure 5a the land capability of the lease area is identified as follows: Present 2001 To be further disturbed by Classification mining ha % ha % Urban Use (Baken, Sanddrif and Reuning) ±90 0.2% - - Arable land (irrigable, as dry land cropping Planned 0.9% - - is not possible ±368 Grazing land (given that carrying capacity is below 1 SSU/20ha and therefore All dry land considered as Wilderness given low restricted to nomadic herds. Grazing land carrying capacity and wilderness land are seen as falling into the same category. Wilderness land (outside the Richtersveld ±30254 73.2 ±384 National Park) Wilderness land (inside the Richtersveld ±8793 21.3% ±16 National Park) Area denuded by mining to date Representing ±400 ha to be 1% of the ±1840 4.5% further total lease disturbed area Total mining = 1240ha = 5% Wetland (taking the south bank as Nil Nil boundary TOTAL LEASE AREA 41343 100% NIL NIL

13.15 Land Use Pre-mining use of the land was nomadic grazing of a wilderness area.

Refer para 4.2.1 a) Towns of Reuning and Baken for:  Figure 5 for all land uses in Baken with photos; and  Figure 6 for all land uses and photos of Reuning. For the best record of LOR Land uses outside of the towns, the land use maps and the mine plans of the April 2009 EMP Volume V Figures: Baken, Xheis, Sanddrif 124 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

i. Figure 7a: Infrastructure and Existing Land Uses (Baken Proper) ii. Figure 7ai: Surface Infrastructure (Baken Proper) iii. Figure 7b: Infrastructure and Existing Land Uses (Sanddrif - Xheis - Baken Town) iv. Figure 8a: Mine Plan (Baken Proper) v. Figure 8b: Mine Plan (Sanddrif-Xheis) vi. Figure B11ai: Dump, Excavation and Tailings Pond Rehabilitation (Baken Proper - South) vii. Figure B11aii: Dump, Excavation and Tailings Pond Rehabilitation (Baken Proper - North) viii. Figure B11bi: Dump, Excavation and Tailings Pond Rehabilitation (Xheiss & Sanddrif Terrace) Bloeddrif ix. Figure D11a: Dump, Excavation and Tailings Pond Rehabilitation (Bloeddrif B1) x. Figure D7: Infrastructure and Existing Land Uses (Bloeddrif) xi. Figure D7a: Surface Infrastructure (Bloeddrif) xii. Figure D8: Mine Plan (Bloeddrif) Nxodap and Jakkalsberg xiii. Figure 7d: Infrastructure and Existing Land Uses (Nxodap) xiv. Figure R7c: Infrastructure and Existing Land Uses (Jakkalsberg) xv. Figure R7 (c ): Infrastructure and Existing Land Uses (Jakkalsberg and Nxodap)

Reuning xvi. Figure R7 (b) Infrastructure and Existing Land Uses (Reuning (South) FR Terrace to Southgate xvii. Figure R7b: Infrastructure and Existing Land Uses (Reuning South - Suidhek) xviii. Figure R7 (a): Infrastructure and Existing Land Uses (Reuning North – Aace to Reuning Central) xix. Figure R7a: Infrastructure and Existing Land Uses (Aace-Reuning Central)

13.16 Regional Socio-economic Structure

13.16.1 Regional socio economic context of the lease area is shown in Figure 2 and the table below to reflect the following: • Springbok as the regional centre of Namaqualand with a town population of 10 000 persons and a regional population of 43 000 persons (Nama Khoi and Richtersveld municipalities). • The port town of Port Nolloth which has fishing and marine diamond mining as its economic base. • Alexander Bay which still is an existing diamond mining town. As the tar road to the lease area follows the Steinkopf, Port Nolloth, Alexander Bay – Baken route, these towns benefit most from mine generated traffic and logistics to supply vehicles which originate in Cape Town or Bitterfontein (fuel). While Trans Hex maintained the gravel road from Alexander Bay past Baken and Cornellskop to

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Reuning in the absence of regular maintenance by the relevant roads authority, the Company could not commit itself to doing it in perpetuity.

By comparison, the gravel road from Vioolsdrift via Eksteensfontein is largely unmaintained and consequently the towns of Eksteensfontein has poor contact with the mine.

In the past Baken mine employed ±185 persons from the surrounding towns of Kuboes, Sanddrif, Lekkersing and Eksteensfontein thereby providing direct benefit of income to 740 persons at 4 persons per household in these towns, current expectations of employment under LOR-D and the JV is in the order of 800 persons.

13.16.2 Economic Activities of the Region LOR mining represents the major economic activity of Namaqualand. Other major employers include: • Alexander Bay coastal diamond mining. • Port Nolloth marine diamond mining. • Port Nolloth fishing industry. • Lekkersing quartzite tile mining. • An ailing copper mining industry in Springbok. • A dimension stone industry in the Springbok area. • Richtersveld National Park and river recreation tourism industry.

13.16.3 Unemployment Unemployment (persons actively looking for work) in Namaqualand is 10% as per the table overleaf which also shows that in Kuboes, Sanddrif and Lekkersing between 54% and 76% of persons are unemployed revealing a very high dependency ratio.

13.16.4 Housing The mining company provides some 130 houses to its staff while up to a further 200 to 300 persons are potentially accommodated in single quarters with additional facilities for contract construction teams.

13.16.5 Social Infrastructure (see photos BT2 and RO7) At district level the two mining towns of Baken and Reuning provide the mine employees / residents of the towns with the following services: • General dealer. • Filling station. • Clinic on site with doctors visits once / week from Alexander Bay. • Recreation club facilities. • Sports fields and club facilities. • Crèche facilities. In addition, the mine provides daily transport of school children to Alexander Bay.

13.16.6 Water supply (Domestic) Potable water to Reuning and Baken towns and to the mines is provided from pump stations on the Orange River which feed purification works at each of Baken and Reuning while a further pump station at Baken provides water to Kuboes via a Kuboes 126 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

pumping line on which the Kuboes purification works is located at seen in photo 12a. Refer para 4.2.1 c)

Table 2.16. Population and socio-economic indicators of Richtersveld Municipal and certain Nama Khoi Municipal towns and villages

Sum of Un- Sum of % HH Sum of # % of HH % of HH Settlement employ % Un- Municipa Total income HH below below with below Name and ed, employ lity populati =

127 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

The respective capacities / consumption of these systems is as follows: Purification Works Capacity Domestic Consumption Bloeddrif at hostel of JV 10m³/day Reuning 2 kl/hr 312000m³/yr Baken and Sanddrif 24kl/hr -350031m³/yr Baken mine (potable) 12kl/hr 60000m³/yr TOTAL 38 kl/hr 722031m³/yr

13.16.7 Power Supply Power supply to the West Richtersveld is by Eskom 66kV grid which feeds from the Beesbank substation (which has a 22kV supply to Baken mine) in the south via the Bloeddrif substation (at Cornell’s Kop) (which supplies Bloeddrif mine and Baken mine with 22kV supply). The main Eskom line continues north-ward as a 66kV line past the Octha Substation (which supplies Reuning mine with 22kV supply) to Rosh Pinah in Namibia as shown diagrammatically below and in Diagram 2.

An updated GIS drawing will be prepared by LOR-D survey department when sufficient finality is achieved on the LOR JV Plant 22kV lines and incorporated into the EMP update process.

Diagram 2: Schematic distribution of Eskom supply

128 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

14 Overall site environmental features

14.1 Description of infrastructure and specific environmental features on the site Paragraph 4 fully reflects on the overall mining right area perspective of existing infrastructure and activity areas reflecting on mining to date and the planned mining under LOR-D new mine plan in para 4.4 with a discussion of the post mining land use plan in para 4.6 and Figure 10 (for detail consideration of past infrastructure and activities refer the plans in Annexure R which are a comprehensive record at 2009). Paragraph 13 describes the specific environmental features/attributes of the Mining Right area.

14.2 Environmental and current land use map (Show all environmental and current land use features)

Refer figures as follows: Figure 1: Locality Plan Figure 2: Regulation 2 (2) Sketch Plan Figure 3: Geology Plan Figure 4: Geological and Historical Mining Informants to Overall Mine Planning Figure 4a: Record of earlier THG Processing Plants at Cession. Figure 5: Baken Town Figure 6: Reuning Town Figure 7: Main existing roads serving the mining area Figure 8: Overall JV Geographic Area Identification/Allocation Feb 2020 Figure 9: Provisional Overall Mine Plan (Early 2020) Figure 10: Post Mining Land Use Figure 11: Vegetation classification of Mucina and Rutherford (2012) Figure 12: CBA Classification map

15 Impacts identified (Provide a list of the potential impacts identified of the activities described in the initial site layout that will be undertaken, as informed by both the typical known impacts of such activities, and as informed by the consultations with affected parties together with the significance, probability and duration of the impacts).

Note that in this Draft Scoping Report, only the potential impacts identified are the typical impacts known for such activities. This will be subject to further public participation to identify additional / different impacts.

Step one is to identify applicable impacts, as per table below. Second step is to ascribe significance and details as per table thereafter.

Note: that the following table (after the one below) will only discuss negative impacts (those highlighted in grey in table above as those highlighted in green show that a positive impact is expected. 129 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Activity.

This table identifies potential impacts.

Geology Topography Topsoil Soil/ Visual Capability Land Vegetation Water Surface Water Ground Life Animal Noise (Dust) Quality Air Economic Social/ Archaeology/ Cultural Hydrocarbon Impact Traffic/Access Section 102 Application: EMP Update/revision over approved Mining Right area 41343.4340ha 1. ESTABLISHMENT/CONTINUED USE As this EMP Update/Revision is initiated by a Cession of the Right to a ACTIVITIES new company and must accommodate the new companies corporate structure, mining process and rationalisation of facilities and processing plants with new locations, the following activities/facilities must be put in place to reduce/eliminate impacts as discussed above 1.1. Continued maintenance and use of Baken and Reuning Towns 1.2. Demarcation of Joint Venture (JV) Geographic areas within which each JV will proceed with continued mining in its area and the required temporary logistical support structures (Office, stores, personnel amnesties and minor workshop containers/ski cabins, plant and bunded fuel tanks). 1.3. Access road is already in place and approved in terms of earlier EMP. 1.4. All main haul roads and on-site roads are already in place but is included as a listed activity in any event. 1.5. Main offices and admin buildings are already in place 1.6. Main workshop are already in place 1.7. Central Bunded Fuel Tanks are already in place at Baken BCP (400kl), Bloeddrif (80kl) and Reuning Industrial (320kl). 1.8. Points 1.3 and 1.4 include personnel amenities to septic tank and then French drain 1.9. Airstrip (1.2km long) in place on old Baken Central Access road 1.10. Mining Areas: Further use and new areas in terms of para 4 and figure 4

130 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Activity.

This table identifies potential impacts.

Geology Topography Topsoil Soil/ Visual Capability Land Vegetation Water Surface Water Ground Life Animal Noise (Dust) Quality Air Economic Social/ Archaeology/ Cultural Hydrocarbon Impact Traffic/Access 1.11. Processing plant: LOR-D have established mobile pan processing plants and final recovery plants (Bourevestnik plants) per JV Geographic area (15 Plants at April 2020). These plants generally replace all previous THG large DMS plants which are either demolished or in an advance stage of demolition at this stage of establishment. Refer Annexure G, past, present and planned processing plants. 1.12. Establishment of bunded diesel tanks generally of less than 20m3 capacity per tank in JV Geographical Areas where required. 1.13. Continued use of existing licensed domestic and industrial waste sites. 1.14. Continued use and maintenance of existing potable water plants at Baken and Reuning 1.15. Continuous use of existing process * water extraction points and re- 0 establishment of the pumping points at others as per Annexure D (Water with Fig W-1) 1.16. Continued use and maintenance of electrical supply 1.17. Asbestos management Annexure E. 1.18. Builders rubble burial sites Annexure E-3 2. OPERATIONAL PHASE ACTIVITIES The exact footprint of mining in alluvial diamond bearing gravels is impossible to accurately pre-determine. Future Mining area at this stage is based on the target mining areas identified through earlier prospecting by THG and interpreted by LOR-D and such prospecting will remain a continued process within the mine plans informing regular update. Mining Cycle The mining cycle of a mine block (few hectare over a channel reserve) consists of a cycle of the following activities. For * 0-4 see notes below table. 2.1. Demarcation of mine block on aerial image with GIS/GPS definition.

2.2. Topsoil removal to perimeter topsoil *1 stockpiles/berms 2.3. Clearing of overburden as dump for later backfill to previously mined area 131 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Activity.

This table identifies potential impacts.

Geology Topography Topsoil Soil/ Visual Capability Land Vegetation Water Surface Water Ground Life Animal Noise (Dust) Quality Air Economic Social/ Archaeology/ Cultural Hydrocarbon Impact Traffic/Access 2.4. In pit screening of ore defined gravel material and all +32mm retained in pit as backfill 2.5. Loading and hauling of in pit screened or directly loaded ore grade to plant 2.6. Plant processing of ore grade gravels yielding concentrate for diamond recovery and coarse and fine tailings 2.7. Return of tailings to excavation as operational backfill 2.8. Temporary ponding of process water * from plant 2 2.9. Backfilling of excavations 2.10. Covering of backfilled excavations with previously stockpiled topsoil 2.11. Periodic establishment of in field screening plants and their continued relocation as mining progresses. 2.12. Periodic establishment of * processing pan plants or re- establishment of existing pan 3 plants 2.13. Establishment of a final recovery Bourevestnik plant adjacent to a pan plant 2.14. Use of water for processing of material at plant Other OPERATIONAL ACTIVITIES 2.15. Use of small JV workshops 2.16. Use of wash bay (if contemplated) 2.17. Use of central Refuelling supply at Baken and Reuning 2.18. Use of small bunded tanks at each JV plant 2.19. Use of access/delivery roads to and in each JV Geographic area 2.20. Water Use: Water License in place. Will require additional Amendment 2.21. Initiate agricultural projects 3. OPERATIONAL NON – MINING REHABILITATION ACTIVITIES 3.1. Maintain access/delivery road on site

132 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Activity.

This table identifies potential impacts.

Geology Topography Topsoil Soil/ Visual Capability Land Vegetation Water Surface Water Ground Life Animal Noise (Dust) Quality Air Economic Social/ Archaeology/ Cultural Hydrocarbon Impact Traffic/Access 3.2. Waste management including use of existing domestic waste sites, proposed asbestos waste disposal (waste burial site) and builders rubble site. Ref Annexure E. 3.3. Enforce no-go area access 3.4. Hydrocarbon Management: Decontaminate floors and service aprons when required 3.5. Agricultural projects 4. DECOMMISSIONING PHASE ACTIVITIES 4.1. Identify all facilities and activities for retention within the post Mining Land Use context 4.2. Finalise transfer of town facilities, administration and liabilities 4.3. Foster agricultural projects 4.4. Complete backfilling of excavations with nearby material (when available) and cover with topsoil 4.5. Shape excavation edges to 1:3 slope and topsoil 4.6. Shape any remaining dumps as per EMP specification and cover with topsoil if available 4.7. Demolish all unrequired structures 4.8. Remove all process plants and steel structures 4.9. Remove all protruding foundations * and footings 4 4.10. Remove all pipelines and cables 4.11. Remove diesel tanks, bunds, rehabilitate footprint & decontaminate 4.12. Rip / scarify logistical facilities/areas and footprints and apply pebble deflation surfaces where appropriate. 4.13. Retain access roads for future use 5. AFTERCARE PERIOD 5.1. Remove alien vegetation (if applicable) 5.2. Conduct final performance assessment 5.3. Lodge closure Application 5.4. DMR Grant Closure Application

133 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

*0: In order to avoid disturbance of the highly ranked riparian vegetation zone of the orange river bank earlier pumping points must be prioritised for future reuse as opposed to pump installation at new points requiring disturbance of riparian vegetation. This EMP emphasises the need for No-Go restriction zones to be respected and avoided given especially vegetation and archaeological sensitivity. *1: While the creation of temporary topsoil berms will have dust impacts requiring control and ensuring that vegetation is removed from surfaces to be occupied, the advantages posed by such temporary topsoil storage for later reuse as topsoil cover in the rehabilitated backfill excavation area and removed plant areas plays a vital positive role in the broader operation rehabilitation program. *2: Temporary ponding of process water in shallow lined ponds is positive in that it facilitates maximum process water recycling at the pan plants reducing water pumping from the Orange River. Any superfluous water can be used to fill dust attenuation vehicles. *3: While relocation of pan plants has impacts, the sites selected for their new location are to be sites generally previously disturbed during earlier prospecting or where an excavation has been fully backfilled but not yet topsoiled previously served as logistical areas for nearby THG plant. The positive considerations of reduced hauling of ore to the relocated plant site and reduced return hauling of waste to backfill the excavations must offset the financial and environmental cost of the semi-mobile pan plant relocation. Furthermore, temporary pan plants impacts are vastly lower than those of earlier employed large DMS plants. *4: Where especially existing old plant footings, heavy concrete floors or stub columns would require significantly invasive excavations to remove, or where unsurfaced areas are highly compacted by earlier activities and can be ripped by dozer, these areas can be rehabilitated through the principle of creating Pebble Deflation Surfaces mimicking those of a stoney desert and the pebble deflation surfaces of especially Aace through the covering of these area with 350-500mm of coarse tailings or screenings under the principles discussed earlier in this document as Pebble Deflation Surfaces.

134 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Table 15.2: Impact, nature, extent, duration and intervention possibility Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Section 102 Application: EMP Update/revision over

approved Mining Right area 41343.4340ha As this EMP Update/Revision is initiated by a Cession of the Right to a new company and must accommodate the new companies corporate 1 ESTABLISHMENT/CONTIN structure, mining process and rationalisation of facilities and processing plants with new locations, the following activities/facilities must be put in UED USE ACTIVITIES place to reduce/eliminate impacts as discussed above 1.1. Continued maintenance and use of Baken and Reuning Towns 1.2. Demarcation of Joint Venture (JV) Geographic areas within which each JV will proceed with continued mining in its area and the required temporary logistical

support structures (Office, stores, personnel amnesties and minor workshop containers/ski cabins, plant and bunded fuel tanks). 1.3. Access road is already in place and approved in terms of earlier EMP.

135 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated 1.4. All main haul roads and on-site roads are already in place but is included as a listed activity in any event. 1.5. Main offices and admin buildings are already in place 1.6. Main workshop are

already in place 1.7. Central Bunded Fuel Tanks are already in place at Baken BCP

(400kl), Bloeddrif (80kl) and Reuning Industrial (320kl). Managed i.t.o hydrocarbon Fully 1.7.1. Hydrocarbon Potential leaks Local Until mitigated Possible Significant No management plan reversible to prevent occurrence Managed i.t.o hydrocarbon Naturally 1.7.2. Groundwater Leaks or spills Local Until mitigated Possible Minor No management plan reversible to prevent occurrence 1.8. Points 1.3 and 1.4 include personnel

amenities to septic tank and then French drain Spill from Fully Can be fully 1.8.1. Surface water Local Until mitigated Possible Insignificant No personnel amenity reversible mitigated

136 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Spill from Until filtered by Naturally Can be fully 1.8.2. Groundwater Very local Possible Insignificant No personnel amenity natural process reversible mitigated 1.9. Airstrip (1.2km long) in place on old Baken Central Access road 1.10. Mining Areas: Further use and new areas in

terms of para 4 and figure 4 1.11. Processing plant: LOR-D have established mobile pan processing plants and final recovery plants (Bourevestnik plants) per JV Geographic area (15 Plants at April 2020). These plants generally replace all previous THG large DMS plants which are either demolished or in an advance stage of demolition at this stage of establishment. Refer Annexure G, past, present and planned processing plants. Local if Insignificant if Avoidance by 1.11.1. Surface water Local Until mitigated Possible Reversible No uncontained managed management Dust from tipping If required Avoidance by 1.11.2. Air Quality (Dust) Local Life of Mine Likely Moderate No into hopper apply wetting management

137 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated 1.12. Establishment of bunded diesel tanks generally of less than

20m3 capacity per tank in JV Geographical Areas where required. Managed i.t.o hydrocarbon Naturally 1.12.1. Groundwater Leaks or spills Local Until mitigated Possible Minor No management plan reversible to prevent occurrence Managed i.t.o hydrocarbon Fully 1.12.2. Hydrocarbon Potential leaks Local Until mitigated Possible Significant No management plan reversible to prevent occurrence 1.13. Continued use of existing licensed

domestic and industrial waste sites. 1.14. Continued use and maintenance of existing

potable water plants at Baken and Reuning 1.15. Continuous use of existing process water extraction points and re-establishment of the pumping points at others as per Annexure D (Water with Fig W-1)

138 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated 1.16. Continued use and maintenance of electrical supply 1.17. Asbestos management

Annexure E. Insignificant Mitigated by Local, size of on Yes to area of 1.17.1. Land Capability Isolated burial Permanent Definite No strict site burial site surrounding burial site management users Insignificant Site location Mitigated by Local, size of Duration of (none on Yes to area of 1.17.2. Surface Water Local at burial site Definite and design to strict site burial site activity surrounding burial site avoid any risk management land users Definite if Site location Mitigated by Local, size of Duration of Yes to area of 1.17.3. Groundwater Local at burial site not Insignificant and design to strict site burial site activity burial site mitigated avoid any risk management Dust generated by Moderate Mitigated by Local site and Duration of Yes to area of 1.17.4. Air Quality (Dust) handling prior to Definite when No strict site local downwind activity burial site regular burial mitigated management 1.18. Builders rubble burial

sites Annexure E-3 Noise generated Moderate Mitigated by by equipment and Local at point of Duration of Yes to area of 1.18.1. Noise Definite when No strict site demolition of demolition activity burial site mitigated management structures Dust generated by Moderate Mitigated by demolition and Local site and Duration of Yes to area of 1.18.2. Air Quality (Dust) Definite when No strict site handling prior to local downwind activity burial site mitigated management regular burial

139 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Managed i.t.o hydrocarbon Potential At time of leak 1.18.3. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 2 OPERATIONAL PHASE

ACTIVITIES The exact footprint of mining in alluvial diamond bearing gravels is impossible to accurately pre-determine. Future Mining area at this stage is based on the target mining areas identified through earlier prospecting by THG and interpreted by LOR-D and such prospecting will remain a continued process within the mine plans informing regular update. Mining Cycle The mining cycle of a mine block (few hectare over a channel reserve) consists of a cycle of the following activities. For * 0-4 see notes below table. 2.1. Demarcation of mine block on aerial image with GIS/GPS definition. 2.2. Topsoil removal to perimeter topsoil stockpiles/berms Significant but Topsoil Area of mining temporary as management as Relocation of Period of strip 2.2.1. Soil/Topsoil strip in strip Definite part of Yes No part of topsoil mining mining operational operational rehabilitation rehabilitation Area of mining Low given Temporary loss of Period of strip Managed by strip 2.2.2. Land Capability strip in strip Definite temporary Yes No strip mining mining process mining nature Temporary Area of mining displacement of Period of strip Managed by pre 2.2.3. Animal Life strip in strip Definite Low Yes No invertebrates and mining chase and rescue mining rodents Dust generated by Period of strip Mitigated by pre- 2.2.4. Air Quality (Dust) Local Definite Moderate No No dozing mining wetting

140 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Managed i.t.o hydrocarbon Potential dozer At time of leak 2.2.5. Hydrocarbon Very local Possible Negligible Yes No management plan leak occurrence to prevent occurrence 2.3. Clearing of overburden as dump for later

backfill to previously mined area Temporary dumps Yes part of Managed i.t.o During period of 2.3.1. Topography given prioritised Local Definite Low/moderate backfill No backfill during excavation direct backfill process strip mining Dust generated by Period of strip Mitigated by pre- 2.3.2. Air Quality (Dust) loading, hauling Local Definite Moderate No No mining wetting and tipping in pit Managed i.t.o hydrocarbon Potential At time of leak 2.3.3. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 2.4. In pit screening of ore defined gravel material

and all +32mm retained in pit as backfill 2.5. Loading and hauling of in pit screened or

directly loaded ore grade to plant Dust generated by Period of strip Mitigated by pre- 2.5.1. Air Quality (Dust) loading, hauling Local Definite Moderate No No mining wetting and tipping in pit

141 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Managed i.t.o hydrocarbon Potential At time of leak 2.5.2. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 2.6. Plant processing of ore grade gravels yielding concentrate for diamond recovery and coarse and fine tailings Typical small semi Very local to Low part of Yes when 2.6.1. Visual Life of mine Definite No Not applicable mobile pan plant plant mining relocated Managed by Temporary loss of Life of plant 2.6.2. Land Capability Area of plant Definite Low Yes No avoidance of bulk site location concrete work Avoided by 2.6.3. Surface Water Plant spillage Point Life of plant Possible Low No No management and plant adaption 2.7. Return of tailings to excavation as operational backfill 2.8. Temporary ponding process water from plant 2.9. Backfilling of

excavations Dust generated by Period of strip Mitigated by pre- 2.9.1. Air Quality (Dust) loading, hauling Local Definite Moderate No No mining wetting and tipping in pit

142 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Managed i.t.o hydrocarbon Potential At time of leak 2.9.2. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 2.10. Covering of backfilled excavations with

previously stockpiled topsoil Dust generated by Period of strip Mitigated by pre- 2.10.1. Air Quality (Dust) Local Definite Moderate No No dozing cover wetting Managed i.t.o hydrocarbon Potential At time of leak 2.10.2. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 2.11. Periodic establishment of in field screening plants and their continued relocation as mining progresses. Managed i.t.o hydrocarbon Potential At time of leak 2.11.1. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 2.12. Periodic establishment of processing pan plants

or re-establishment of existing pan plants Typical small semi Very local to Low part of Yes when 2.12.1. Visual Life of mine Definite No Not applicable mobile pan plant plant mining relocated

143 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Managed by Temporary loss of Life of plant 2.12.2. Land Capability Area of plant Definite Low Yes No avoidance of bulk site location concrete work Avoided by 2.12.3. Surface Water Plant spillage Point Life of plant Possible Low No No management and plant adaption 2.13. Establishment of a final recovery Bourevestnik

plant adjacent to a pan plant 2.14. Use of water for processing of material at plant Other OPERATIONAL ACTIVITIES 2.15. Use of small JV

workshops Managed i.t.o hydrocarbon Potential At time of leak 2.15.1. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 2.16. Use of wash bay (if

contemplated) Managed i.t.o Contamination of hydrocarbon At time of 2.16.1. Hydrocarbon surface and Very local Possible Low No Yes management plan spillage groundwater to prevent occurrence 2.17. Use of central Refuelling supply at Baken and Reuning

144 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Managed i.t.o hydrocarbon Potential At time of leak 2.17.1. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 2.18. Use of small bunded

tanks at each JV plant Managed i.t.o hydrocarbon Potential At time of leak 2.18.1. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 2.19. Use of access/delivery roads to and in each JV Geographic area 2.20. Water Use: Water License in place. Will

require additional Amendment 2.21. Initiate agricultural

projects 3 OPERATIONAL NON – MINING REHABILITATION ACTIVITIES 3.1. Maintain access/delivery road on site Managed by road Generated by 3.1.1. Air Quality (Dust) Along route Life of route Definite Moderate No No wetting when traffic required

145 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated 3.2. Waste management including use of existing domestic waste sites, proposed asbestos

waste disposal (waste burial site) and builders rubble site. Ref Annexure E. 3.3. Enforce no-go area

access 3.4. Hydrocarbon Management: Decontaminate floors and service aprons when required 3.5. Agricultural projects 4 DECOMMISSIONING PHASE

ACTIVITIES 4.1. Identify all facilities and activities for retention

within the post Mining Land Use context 4.2. Finalise transfer of town facilities,

administration and liabilities 4.3. Foster agricultural

projects

146 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated 4.4. Complete backfilling of excavations with nearby material (when available) and cover with topsoil Dust generated by Period of Mitigated by pre- 4.4.1. Air Quality (Dust) Local Definite Moderate No No dozing shaping wetting Managed i.t.o hydrocarbon Potential At time of leak 4.4.2. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 4.5. Shape excavation edges to 1:3 slope and topsoil Dust generated by Period of Mitigated by pre- 4.5.1. Air Quality (Dust) Local Definite Moderate No No dozing sloping wetting Managed i.t.o hydrocarbon Potential At time of leak 4.5.2. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 4.6. Shape any remaining dumps as per EMP

specification and cover with topsoil if available Dust generated by Period of Mitigated by pre- 4.6.1. Air Quality (Dust) Local Definite Moderate No No dozing shaping wetting

147 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Managed i.t.o hydrocarbon Potential At time of leak 4.6.2. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 4.7. Demolish all

unrequired structures Managed i.t.o hydrocarbon Potential At time of leak 4.7.1. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 4.8. Remove all process

plants and steel structures Managed i.t.o hydrocarbon Potential At time of leak 4.8.1. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 4.9. Remove all protruding foundations and footings Dust generated by Managed in terms Period of 4.9.1. Air Quality (Dust) equipment and Local Definite Moderate No No of pebble shaping loading deflation surface 4.10. Remove all pipelines

and cables Managed by pre Period of 4.10.1. Air Quality (Dust) Linear disturbance Local Definite Low No No wetting digging activity line

148 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated Managed i.t.o hydrocarbon Potential At time of leak 4.10.2. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 4.11. Remove diesel tanks, bunds, rehabilitate

footprint & decontaminate Dust generated by Period of Managed by pre 4.11.1. Air Quality (Dust) equipment and Local Definite Moderate No No shaping wetting loading Managed i.t.o hydrocarbon Potential At time of leak 4.11.2. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 4.12. Rip / scarify logistical facilities/areas and footprints and apply pebble deflation surfaces where appropriate. Dust generated by Period of Managed by pre 4.12.1. Air Quality (Dust) equipment and Local Definite Moderate No No shaping wetting loading Managed i.t.o hydrocarbon Potential At time of leak 4.12.2. Hydrocarbon Very local Possible Negligible Yes No management plan equipment leak occurrence to prevent occurrence 4.13. Retain access roads

for future use

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Extent to which impact can cause or be: Activity Nature of impact Extent Duration Probability Significance irreplaceable loss avoided, managed reversed of resource or mitigated 5 AFTERCARE PERIOD 5.1. Remove alien vegetation (if applicable) 5.2. Conduct final performance assessment 5.3. Lodge closure

Application 5.4. DMR Grant Closure

Application

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16 Methodology used in determining the significance of environmental impacts (Describe how the significance, probability, and duration of the aforesaid identified impacts that were identified through the consultation process were determined in order to decide the extent to which the initial site layout needs revision). The reader must appreciate that the entire resource area within the Mining Right area has been subject to alluvial diamond mining under early prospectors and then Transhex Group and resultantly this scoping report is not discussing a green-fields site but looking at improvements in environmental management of the overall site, the excavation areas, the plant type and plant locations, the significant changes in processing and resultant shift away from large scale fine and coarse tailings disposal in dams slimes dams and coarse tailings dumps while also beginning to focus on post-mining use of future mined areas on the meso terraces where operational rehabilitation will occur in a much shorter cycle than that of THG deep proto channels and therefore permit more emphasis of achieving short period operational rehabilitation and operational post mining land use within certain individual JV Geographic areas capable of facilitating post mining irrigation agriculture development on a commercial scale.

Accordingly the reader’s attention is drawn to the discussion of the Preface in chapter 0 and Chapter 4 scope of overall activities placing this scoping report within the perspective of the change of management from THG to LOR-D.

Within this Draft Scoping Report, an initial table (Table 15.1) was compiled to identify potential impacts. Then Table 15.2 described each activity (whether listed or not in terms of NEMA), potential impact, significance and duration. Such foregoing tables are included in this draft Scoping report which is being made available to all identified Interested and Affected Parties for comment.

Any relevant responses received would then inform any appropriate and motivated revision of the site layout plan. Although there have been no revisions required as yet, it is possible that the site layout plan may require revision through continued input by I&AP’s as well as specialist studies yet to be expanded on.

As per Table 15.2 the impacts are rated according to nature, extent, duration, probability of occurring and significance.

a) The significance level is based on the following criteria: Significance Criteria Significant (S)  Recommended level always exceeded with associated widespread community action  Disturbance to areas that are pristine, have conservation value, are Negative important resource to humans and will be lost forever  Complete loss of land capability  Destruction of rare or endangered specimens  May affect the viability of the project

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Moderate (M)  Moderate measurable deterioration and discomfort  Recommended level occasionally violated – still widespread complaints  Partial loss of land capability  Complete change in species variety or prevalence  May be managed  Is insignificant if managed according to EMP provisions Minor/ (I)  Minor deterioration. Change not measurable Insignificant  Recommended level will rarely if ever be violated  Sporadic community complaints  Minor deterioration in land capability  Minor changes in species variety or prevalence Negligible  An impact will occur but it is barely discernible and not worthy of further investigation Minor  Improvements in local socio-economics Positive Significant  Major improvements in local socio-economics with some regional benefits

b) The duration is classified as:  Permanent (post-closure)  Life of Mine (LOM)  Temporary

c) The probability is ranked as:  Definite/Certain  Possible  Unlikely

17 The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives will have on the environment and the community that may be affected. (Provide a discussion in terms of advantages and disadvantages of the initial site layout compared to alternative layout options to accommodate concerns raised by affected parties)

Not Applicable Yet.

18 The possible mitigation measures that could be applied and the level of risk. (With regard to the issues and concerns raised by affected parties provide a list of the issues raised and an assessment/ discussion of the mitigations or site layout alternatives available to accommodate or address their concerns, together with an assessment of the impacts or risks associated with the mitigation or alternatives considered).

Not Applicable. No concerns raised at this stage.

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19 The outcome of the site selection Matrix. Final Site Layout Plan (Provide a final site layout plan as informed by the process of consultation with interested and affected parties)

Given the inheritance of the mining layout to date, no site selecting matrix was conducted. The interim Mine Layout Plan dd early contained in this draft Scoping Report is based on the discussions of informants to the mine plan as contained in Para 4 yielding Figure 4 Geological and Historical Mining informants reflecting the overall mine plan and an integration of disturbances to date with environmental attributes assessed in Chapter 13 and the mining methods and management structure required by LOR-D as holder of the Ceded Right to produce Figure 9: Proposed Overall Mine Plan (early 2020) in para 4.4.2.

20 Motivation where no alternative sites were considered Not Applicable.

21 Statement motivating the preferred site (Provide a statement motivation the final site layout plan that is proposed)

Refer para 19 above and para 4 informants to the overall mine planning which includes para 4.2 on continued uses including infrastructure and the 2 mine towns of Reuning and Baken.

22 Plan of study for the Environmental Impact Assessment process

22.1 Description of alternatives to be considered including the option of not going ahead with the activity

The following alternatives must be considered during the EIA process: Alternatives in respect of: Contained in draft Scoping Update in Final Scoping report report Property on which or location where it is proposed to Yes. Refer Para 11 Not yet applicable undertake the activity Type of activity to be Yes. Refer Para 11 Not yet applicable undertaken Design or layout of the Yes. Refer Para 11 Not yet applicable activity Technology to be used in the Yes. Refer Para 11 Not yet applicable activity Operational aspects of the Yes. Refer Para 11 Not yet applicable activity Option of not implementing Yes. Refer Para 11 Not yet applicable the activity

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22.2 Description of the aspects to be assessed as part of the environmental impact assessment process (The EAP must undertake to assess the aspects affected by each individual mining activity whether listed or not, including activities such as blasting, Loading, hauling and transport, and mining activities such as Excavations, stockpiles, discard dumps or dams, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc…etc…etc.)

The following activities and environmental aspects thereof will continue to be assessed during the EIA:

Environmental Was it provisionally assessed in Status in the Final Activity Aspect the Draft Scoping Report Scoping report Section 102 Application: EMP Update/revision over approved Mining

Right area 41343.4340ha

1. ESTABLISHMENT/CONTINUED USE As this EMP Update/Revision is initiated by a Cession of the Right to a new company ACTIVITIES and must accommodate the new companies corporate structure, mining process and rationalisation of facilities and processing plants with new locations, the following activities/facilities must be put in place to reduce/eliminate impacts as discussed above 1.1. Continued maintenance and use of

Baken and Reuning Towns 1.2. Demarcation of Joint Venture (JV) Geographic areas within which each JV will proceed with continued mining in its area and the required temporary logistical support structures (Office, stores, personnel amnesties and minor workshop containers/ski cabins, plant and bunded fuel tanks). 1.3. Access road is already in place and

approved in terms of earlier EMP. 1.4. All main haul roads and on-site roads are already in place but is included as a listed activity in any event. 1.5. Main offices and admin buildings are already in place 1.6. Main workshop are already in place

1.7. Central Bunded Fuel Tanks are already Yes. Refer Part 15 Not applicable yet in place at Baken BCP (400kl), Hydrocarbon Bloeddrif (80kl) and Reuning Yes. Refer Part 15 Not applicable yet Industrial (320kl). Groundwater 1.8. Points 1.3 and 1.4 include personnel Surface Water Yes. Refer Part 15 Not applicable yet amenities to septic tank and then Yes. Refer Part 15 Not applicable yet Groundwater French drain 1.9. Airstrip (1.2 km long) in place on old

Baken Central Access road 1.10. Mining Areas: Further use and new

areas in terms of para 4 and figure 4

154 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Environmental Was it provisionally assessed in Status in the Final Activity Aspect the Draft Scoping Report Scoping report 1.11. Processing plant: LOR-D have Surface Water Yes. Refer Part 15 Not applicable yet established mobile pan processing Yes. Refer Part 15 Not applicable yet plants and final recovery plants (Bourevestnik plants) per JV Geographic area (15 Plants at April 2020). These plants generally replace all previous THG large DMS plants Air Quality (Dust) which are either demolished or in an advance stage of demolition at this stage of establishment. Refer Annexure G, past, present and planned processing plants. 1.12. Establishment of bunded diesel tanks Groundwater Yes. Refer Part 15 Not applicable yet generally of less than 20m3 capacity Yes. Refer Part 15 Not applicable yet per tank in JV Geographical Areas Hydrocarbon where required. 1.13. Continued use of existing licensed

domestic and industrial waste sites. 1.14. Continued use and maintenance of existing potable water plants at Baken and Reuning 1.15. Continuous use of existing process water extraction points and re- establishment of the pumping points at others as per Annexure D (Water with Fig W-1) 1.16. Continued use and maintenance of

electrical supply 1.17. Asbestos management Annexure E. Land Capability Yes. Refer Part 15 Not applicable yet Surface Water Yes. Refer Part 15 Not applicable yet Groundwater Yes. Refer Part 15 Not applicable yet Air Quality Yes. Refer Part 15 Not applicable yet 1.18. Builders rubble burial sites Annexure Noise Yes. Refer Part 15 Not applicable yet E-3 Air Quality (Dust) Yes. Refer Part 15 Not applicable yet Hydrocarbon Yes. Refer Part 15 Not applicable yet 2. OPERATIONAL PHASE ACTIVITIES The exact footprint of mining in alluvial diamond bearing gravels is impossible to accurately pre-determine. Future Mining area at this stage is based on the target mining areas identified through earlier prospecting by THG and interpreted by LOR-D and such prospecting will remain a continued process within the mine plans informing regular update. Mining Cycle The mining cycle of a mine block (few hectare over a channel reserve) consists of a cycle of the following activities. 2.1. Demarcation of mine block on aerial

image with GIS/GPS definition 2.2. Topsoil removal to perimeter topsoil Soil/Topsoil Yes. Refer Part 15 Not applicable yet stockpiles/berms Land Capability Yes. Refer Part 15 Not applicable yet Animal Life Yes. Refer Part 15 Not applicable yet Air Quality (Dust) Yes. Refer Part 15 Not applicable yet Hydrocarbon Yes. Refer Part 15 Not applicable yet 2.3. Clearing of overburden as dump for Soil/Topsoil Yes. Refer Part 15 Not applicable yet later backfill to previously mined area Air Quality (Dust) Yes. Refer Part 15 Not applicable yet Hydrocarbon Yes. Refer Part 15 Not applicable yet 2.4. In pit screening of ore defined gravel Air Quality (Dust) Yes. Refer Part 15 Not applicable yet material and all +32mm retained in Yes. Refer Part 15 Not applicable yet Hydrocarbon pit as backfill 2.5. Loading and hauling of in pit screened Visual Yes. Refer Part 15 Not applicable yet 155 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Environmental Was it provisionally assessed in Status in the Final Activity Aspect the Draft Scoping Report Scoping report or directly loaded ore grade to plant Land Capability Yes. Refer Part 15 Not applicable yet Surface Water Yes. Refer Part 15 Not applicable yet 2.6. Plant processing of ore grade gravels yielding concentrate for diamond recovery and coarse and fine tailings 2.7. Return of tailings to excavation as Topography Yes. Refer Part 15 Not applicable yet operational backfill Visual Yes. Refer Part 15 Not applicable yet 2.8. Temporary ponding of used process

water from plant 2.9. Backfilling of excavations Air Quality (Dust) Yes. Refer Part 15 Not applicable yet Hydrocarbon Yes. Refer Part 15 Not applicable yet 2.10. Covering of backfilled excavations Yes. Refer Part 15 Not applicable yet with previously stockpiled topsoil Air Quality (Dust)

Yes. Refer Part 15 Not applicable yet Hydrocarbon

2.11. Periodic establishment of in-field Yes. Refer Part 15 Not applicable yet screening plants and their continued Hydrocarbon relocation as mining progresses. 2.12. Periodic establishment of processing Yes. Refer Part 15 Not applicable yet pan plants or re-establishment of Visual existing pan plants Yes. Refer Part 15 Not applicable yet Land Capability

Yes. Refer Part 15 Not applicable yet Surface water

2.13. Establishment of a final recovery Bourevestnik plant adjacent to a pan plant 2.14. Use of water for processing of Yes. Refer Part 15 Not applicable yet material at plant Surface Water Other OPERATIONAL ACTIVITIES

2.15. Use of small JV workshops Yes. Refer Part 15 Not applicable yet Hydrocarbon

2.16. Use of wash bay (if contemplated) Yes. Refer Part 15 Not applicable yet Hydrocarbon

2.17. Use of central Refuelling supply at Yes. Refer Part 15 Not applicable yet Baken and Reuning Hydrocarbon 2.18. Use of small bunded tanks at each JV Yes. Refer Part 15 Not applicable yet plant Hydrocarbon 2.19. Use of access/delivery roads to and in Yes. Refer Part 15 Not applicable yet each JV Geographic area Air Quality (Dust) 2.20. Water Use: Water License in place. Will require additional Amendment

2.21. Initiate agricultural projects

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Environmental Was it provisionally assessed in Status in the Final Activity Aspect the Draft Scoping Report Scoping report 3. OPERATIONAL NON – MINING REHABILITATION ACTIVITIES

3.1. Maintain access/delivery road on site Air Quality (Dust) Yes. Refer Part 15 Not applicable yet 3.2. Waste management including use of existing domestic waste sites, proposed asbestos waste disposal (waste burial site) and builders rubble site. Ref Annexure E. 3.3. Enforce no-go area access 3.4. Hydrocarbon Management: Decontaminate floors and service aprons when required 3.5. Agricultural projects 4. DECOMMISSIONING PHASE ACTIVITIES

4.1. Identify all facilities and activities for retention within the post Mining Land Use context 4.2. Finalise transfer of town facilities,

administration and liabilities 4.3. Foster agricultural projects 4.4. Complete backfilling of excavations Air Quality (Dust) Yes. Refer Part 15 Not applicable yet with nearby material (when available) Yes. Refer Part 15 Not applicable yet Hydrocarbon and cover with topsoil 4.5. Shape excavation edges to 1:3 slope Air Quality (Dust) Yes. Refer Part 15 Not applicable yet and topsoil Hydrocarbon Yes. Refer Part 15 Not applicable yet 4.6. Shape any remaining dumps as per Air Quality (Dust) Yes. Refer Part 15 Not applicable yet EMP specification and cover with Yes. Refer Part 15 Not applicable yet Hydrocarbon topsoil if available 4.7. Demolish all unrequired structures Yes. Refer Part 15 Not applicable yet Hydrocarbon 4.8. Remove all process plants and steel Yes. Refer Part 15 Not applicable yet Hydrocarbon structures 4.9. Remove all protruding foundations Yes. Refer Part 15 Not applicable yet and footings Air Quality (Dust)

4.10. Remove all pipelines and cables Air Quality (Dust) Yes. Refer Part 15 Not applicable yet Hydrocarbon Yes. Refer Part 15 Not applicable yet 4.11. Remove diesel tanks, bunds, Air Quality (Dust) Yes. Refer Part 15 Not applicable yet rehabilitate footprint & Yes. Refer Part 15 Not applicable yet Hydrocarbon decontaminate 4.12. Rip / scarify logistical facilities/areas Air Quality (Dust) Yes. Refer Part 15 Not applicable yet and footprints and apply pebble Yes. Refer Part 15 Not applicable yet deflation surfaces where Hydrocarbon appropriate. 4.13. Retain access roads for future use 5. AFTERCARE PERIOD 5.1. Remove alien vegetation (if applicable) 5.2. Conduct final performance assessment 5.3. Lodge closure Application 157 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Environmental Was it provisionally assessed in Status in the Final Activity Aspect the Draft Scoping Report Scoping report 5.4. DMR Grant Closure Application

22.3 Description of aspects to be assessed by specialists Specialist assessments had been conducted on the following aspects to inform the existing approved EMP. The specialist will again be engaged in any aspect requiring their further inputs but none have been identified to date. Given the background of mining to date, the existing approved EMP of 2009a approved 2015 was based on various specialist assessments of identified environmental attributes including: i. Natural Vegetation in para 13.5 ii. Soils in para 13.4 iii. Animal life in para 13.6 iv. Surface water investigation by E-Tek in Annexure H2 and streamflow diversion in Annexure H1. v. The existing 2017 water license as per Annexure D1 vi. Heritage/Archaeology assessed by specialist in 1997 and 1999 with a follow up report for Jakkalsberg in October 2001 as reference in the current scoping exercise in para 13.11, table 2.13 and various photos depicting petroglyphs. While other elements such as land use, regional economic structure, visual aspects, air quality and noise and groundwater have been elements dealt with internally by the mining company THG and its consultants to date during each EMP update and revision.

Unless through the public participation process any critical aspects are raised, no specialist studies are contemplated at this stage of the Scoping phase.

22.4 Proposed method of assessing the environmental aspects including the proposed method of assessing alternatives In this draft Scoping report the environmental aspects have been assessed based on the experience of the report compiler (Refer CV in Annexure A). This will be further assessed and refined in the following ways: - Consultation with / Call for comments from all Interested and Affected Parties (I&AP’s) - Call for specialist studies to include assessment on any specific environmental elements raised. The results of such further assessments will be included in the future reporting of the EIA/EMP phase.

22.5 The proposed method of assessing duration and significance As for Para 22.4.

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22.6 The stages at which the competent authority will be consulted This draft Scoping report will be submitted to relevant State Departments for comment. The final Scoping report will be submitted to the Competent Authority (DMR) and such report will contain the details and results of the initial public participation in Scoping. Consultation continues and all comments will be forwarded to the DMR and included in future EIA/EMP

The Competent Authority will decide on the implementation of the Plan of Study. If the applicant is given the go-ahead to continue, then the EIA and EMP will be subject to further public participation and finally lodged to the competent authority.

22.7 Particulars of the public participation process with regard to the Impact Assessment process that will be conducted

22.7.1 Steps to be taken to notify interested and affected parties (These steps must include the steps that will be taken to ensure consultation with the affected parties identified in (h) (ii) herein). Notification of I&AP’s will take place in a system relative to their expected input as follows: 1 Landowner: Through public meetings with the key 4 communities and personal consultation if possible with the Community of the Richtersveld through the Richtersveld Sida-Hub CPA and consultation the National Parks Board for the Department of Public Works. 2 Surrounding adjacent landowners: As per para 12 b) 2 these will include Oena Mine owners: African Star Minerals (Pty) Ltd and the National Parks Board 3 General public and residents of the area: Through advert in local press (Die Plattelander) 4 Notices placed mine office & local libraries’ notice boards. Copies of the Reports will be made available for perusal at the respect public libraries. Refer para 12b) 5. 5 In addition, the relevant Govt. Departments will be contacted by telephone and Email in respect of the proposed project.

Note that all parties will have full access to the Scoping report and EIA/EMP (in final or draft form depending on timing of consultation).

22.7.2 Details of the engagement process to be followed. (Describe the process to be undertaken to consult interested and affected parties including public meetings and one on one consultation. NB the affected parties must be specifically consulted regardless of whether or not they attended public meetings and records of such consultation will be required in the EIA at a later stage).

Landowner, Local Authorities and State Departments will be deemed to be registered I&AP’s. All other I&APs will have to register their interest in the matter.

All registered I&AP’s will be kept abreast of the application and will be supplied with all 159 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

relevant documentation as well as consultations (one on one), if they so wish.

All commenting periods will be minimum 30 days as per NEMA regulations. Any Covid- 19 extension to these periods will be made known in the correspondence/notifications at the time.

22.7.3 Description of the information to be provided to Interested and Affected Parties. (Information to be provided must include the initial site plan and sufficient detail of the intended operation and the typical impacts of each activity, to enable them to assess what impact the activities will have on them or on the use of their land).

The information presented will depend on timing. Initially, the draft Scoping report will serve as the basis for comment. The next round of public participation will use the draft EIA/EMP as the information provided for further consultation.

22.8 Description of the tasks that will be undertaken during the environmental impact assessment (EIA) process. The following tasks will need to be undertaken during the EIA process:  Public participation will again proceed as transparent and all-inclusive as possible.  All registered I&AP’s will be kept informed and provided several opportunities to comment.  Draft EIA / EMP will be compiled as basis for further consultation.  Any additional specialist assessments identified will be assessed in the EIA-EMP phase.

22.9 Measures to avoid, reverse, mitigate, or manage identified impacts and to determine the extent of the residual risks that need to be managed and monitored Potential Impact Mitigation Type Potential for (E.g. dust, noise, (modify, remedy, control, or Residual Risk drainage surface stop)Through (e.g. noise control disturbance, fly rock, measures, storm-water control, dust surface water control, rehabilitation, design Activity contamination, measures, blasting controls, groundwater avoidance, relocation, alternative contamination, and air activity etc.). E.g. Modify through pollution etc….etc.…) alternative method. Control through noise control Control through management and monitoring through rehabilitation. Section 102 Application: EMP Update/revision over approved Mining NA Right area 41343.4340ha NA NA

1. ESTABLISHMENT/CONTINUED USE As this EMP Update/Revision is initiated by a Cession of the Right to a new ACTIVITIES company and must accommodate the new companies corporate structure, mining process and rationalisation of facilities and processing plants with new locations, the following activities/facilities must be put in place to reduce/eliminate impacts as discussed above 1.1. Continued maintenance and use of Matter for NA NA Baken and Reuning Towns discussion 160 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Potential Impact Mitigation Type Potential for (E.g. dust, noise, (modify, remedy, control, or Residual Risk drainage surface stop)Through (e.g. noise control disturbance, fly rock, measures, storm-water control, dust surface water control, rehabilitation, design Activity contamination, measures, blasting controls, groundwater avoidance, relocation, alternative contamination, and air activity etc.). E.g. Modify through pollution etc….etc.…) alternative method. Control through noise control Control through management and monitoring through rehabilitation. 1.2. Demarcation of Joint Venture (JV) Geographic areas within which each JV will proceed with continued Limits are set by mining in its area and the required riparian vegetation temporary logistical support zone, 1:100 yr structures (Office, stores, personnel floodline etc amnesties and minor workshop containers/ski cabins, plant and bunded fuel tanks). 1.3. Access road is already in place and NA NA None approved in terms of earlier EMP. 1.4. All main haul roads and on-site roads NA NA are already in place but is included None as a listed activity in any event. 1.5. Main offices and admin buildings are NA NA already in place None 1.6. Main workshop are already in place NA NA None

1.7. Central Bunded Fuel Tanks are already Ensure bunding and service Although in place at Baken BCP (400kl), apron in place and maintained unlikely there is Bloeddrif (80kl) and Reuning (Managed i.t.o of Hydrocarbon a minor residual Industrial (320kl). Hydrocarbon Management Protocol) risk if a leak goes unnoticed or is not remedies Proper implementation of the Provided Hydrocarbon Management rehabilitation Groundwater Protocol with rapid response takes place no risk remains. 1.8. Points 1.3 and 1.4 include personnel Groundwater Control through management None amenities to septic tank and then None required at low density None Surface water French drain 1.9. Airstrip (1.2km long) in place on old NA NA None (existing) Baken Central Access road 1.10. Mining Areas: Further use and new All elements of Dealt with in relevant Dealt with in areas in terms of para 4 and figure 4 mining area paragraphs relevant impacts are dealt paragraphs with in the individual resultant specific impacts

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Potential Impact Mitigation Type Potential for (E.g. dust, noise, (modify, remedy, control, or Residual Risk drainage surface stop)Through (e.g. noise control disturbance, fly rock, measures, storm-water control, dust surface water control, rehabilitation, design Activity contamination, measures, blasting controls, groundwater avoidance, relocation, alternative contamination, and air activity etc.). E.g. Modify through pollution etc….etc.…) alternative method. Control through noise control Control through management and monitoring through rehabilitation. 1.11. Processing plant: LOR-D have As no chemicals are added in None established mobile pan processing pan plants, their periodic plants and final recovery plants spillage of process water does (Bourevestnik plants) per JV not pose any risk to surface Geographic area (15 Plants at April water but within the closed Surface Water 2020). These plants generally replace water cycle management all previous THG large DMS plants seeks to limit spillage and which are either demolished or in an provide a process water advance stage of demolition at this return dam for the closed stage of establishment. Refer water circuit. Annexure G, past, present and As the pan plants are operated None at mitigated planned processing plants. wet, the pans themselves pose level. no dust risk and the intake Air Quality (Dust) sand screening hopper dust generation can be reduced by water mist spray as the remaining process is wet. 1.12. Establishment of bunded diesel tanks Proper implementation of the Provided generally of less than 20m3 capacity Hydrocarbon Management rehabilitation Groundwater per tank in JV Geographical Areas Protocol with rapid response takes place no where required. risk remains. Ensure bunding and service Although apron in place and maintained unlikely there is (Managed i.t.o of Hydrocarbon a minor residual Hydrocarbon Management Protocol) risk if a leak goes unnoticed or is not remedies 1.13. Continued use of existing licensed Through prescribed Fully specified in the Low given domestic and industrial waste sites. managed of the management and licenses of appropriate site licensed facilities the various sites. choice during impact is minimised licensing to occasional windblown litter escaping the fencing 1.14. Continued use and maintenance of None (only chemical additives None existing potable water plants at Baken None are to be stored as required). and Reuning

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Potential Impact Mitigation Type Potential for (E.g. dust, noise, (modify, remedy, control, or Residual Risk drainage surface stop)Through (e.g. noise control disturbance, fly rock, measures, storm-water control, dust surface water control, rehabilitation, design Activity contamination, measures, blasting controls, groundwater avoidance, relocation, alternative contamination, and air activity etc.). E.g. Modify through pollution etc….etc.…) alternative method. Control through noise control Control through management and monitoring through rehabilitation. 1.15. Continuous use of existing process None if existing Pre assessment of riparian None, riparian water extraction points and re- sites reused. vegetation and minimising vegetation earlier establishment of the pumping points Potential impact on disturbance. disturbed will at others as per Annexure D (Water riparian vegetation recover. with Fig W-1) must be assessed and guide the choice of any new site. 1.16. Continued use and maintenance of Limited to light NA NA electrical supply 11Kv lines 1.17. Asbestos management Annexure E. Land Capability Managed in accordance with Residual impacts Surface Water Annexure E and Table 15.2 over the extent of Groundwater the site. Air Quality 1.18. Builders rubble burial sites Annexure Noise Managed in accordance with Residual impacts E-3 Air Quality (Dust) Annexure E and Table 15.2 over the extent of Hydrocarbon the site. 2. OPERATIONAL PHASE ACTIVITIES The exact footprint of mining in alluvial diamond bearing gravels is impossible to accurately pre-determine. Future Mining area at this stage is based on the target mining areas identified through earlier prospecting by THG and interpreted by LOR-D and such prospecting will remain a continued process within the mine plans informing regular update. Mining Cycle The mining cycle of a mine block (few hectare over a channel reserve) consists of a cycle of the following activities. 2.1. Demarcation of mine block on aerial None image with GIS/GPS definition NA None 2.2. Topsoil removal to perimeter topsoil Managed through topsoil Limited after Soil/Topsoil stockpiles/berms management protocol rehabilitation Manged by shaping and Low Land Capability topsoiling under operational rehab Managed through search and None Animal Life chase” Control through dust control None Air Quality (Dust) measures Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 2.3. Clearing of overburden as dump for Managed through topsoil Limited after Soil/Topsoil later backfill to previously mined area management protocol rehabilitation Control through dust control None Air Quality (Dust) measures

163 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Potential Impact Mitigation Type Potential for (E.g. dust, noise, (modify, remedy, control, or Residual Risk drainage surface stop)Through (e.g. noise control disturbance, fly rock, measures, storm-water control, dust surface water control, rehabilitation, design Activity contamination, measures, blasting controls, groundwater avoidance, relocation, alternative contamination, and air activity etc.). E.g. Modify through pollution etc….etc.…) alternative method. Control through noise control Control through management and monitoring through rehabilitation. Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 2.4. In pit screening of ore defined gravel Control through dust control None Air Quality (Dust) material and all +32mm retained in measures pit as backfill Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 2.5. Loading and hauling of in pit screened Control through dust control None Air Quality (Dust) or directly loaded ore grade to plant measures Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 2.6. Plant processing of ore grade gravels Visual Through site choice and None as the yielding concentrate for diamond Land Capability management plants are recovery and coarse and fine tailings removed and surface water is Surface Water not permanently impacted. 2.7. Return of tailings to excavation as Positive as original topography Positive Topography operational backfill is restored Visual Original topography is restored Positive 2.8. Temporary ponding of process water Positive as it reduces pumping None None from plant from the OR 2.9. Backfilling of excavations Control through dust control None Air Quality (Dust) measures Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 2.10. Covering of backfilled excavations Control through dust control None with previously stockpiled topsoil Air Quality (Dust) measures Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected.

164 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Potential Impact Mitigation Type Potential for (E.g. dust, noise, (modify, remedy, control, or Residual Risk drainage surface stop)Through (e.g. noise control disturbance, fly rock, measures, storm-water control, dust surface water control, rehabilitation, design Activity contamination, measures, blasting controls, groundwater avoidance, relocation, alternative contamination, and air activity etc.). E.g. Modify through pollution etc….etc.…) alternative method. Control through noise control Control through management and monitoring through rehabilitation. 2.11. Periodic establishment of in field Control and remedy through Although unlikely screening plants and their continued hydrocarbon management there is a minor relocation as mining progresses. Hydrocarbon protocol residual risk if leak goes undetected. 2.12. Periodic establishment of processing Through site choice and None as the pan plants or re-establishment of Visual management plants are existing pan plants removed and Land Capability surface water is not permanently impacted. Surface water

2.13. Establishment of a final recovery Temporary low visual None when Bourevestnik plant adjacent to a pan No significant removed plant 2.14. Use of water for processing of Water savings where possible None material at plant Surface Water by close circuit operation and return water pond Other OPERATIONAL ACTIVITIES

2.15. Use of small JV workshops Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 2.16. Use of wash bay (if contemplated) Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 2.17. Use of central Refuelling supply at Control and remedy through Although unlikely Baken and Reuning hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 2.18. Use of small bunded tanks at each JV Control and remedy through Although unlikely plant hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 2.19. Use of access/delivery roads to and in Control through dust control None each JV Geographic area Air Quality (Dust) measures 2.20. Water Use: Water License in place. NA NA Will require additional Amendment. None 165 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Potential Impact Mitigation Type Potential for (E.g. dust, noise, (modify, remedy, control, or Residual Risk drainage surface stop)Through (e.g. noise control disturbance, fly rock, measures, storm-water control, dust surface water control, rehabilitation, design Activity contamination, measures, blasting controls, groundwater avoidance, relocation, alternative contamination, and air activity etc.). E.g. Modify through pollution etc….etc.…) alternative method. Control through noise control Control through management and monitoring through rehabilitation. 2.21. Initiate agricultural projects NA NA None

3. OPERATIONAL NON – MINING REHABILITATION ACTIVITIES

3.1. Maintain access/delivery road on site Control through dust control None Air Quality (Dust) measures 3.2. Domestic waste management In terms of implementation of Limited to extent management prescriptions of of site each site 3.3. Enforce no-go area access None NA NA 3.4. Waste management including use of In accordance with Although unlikely existing domestic waste sites, Hydrocarbon management there is a minor proposed asbestos waste disposal protocol residual risk if (waste burial site) and builders rubble leak goes site. Ref Annexure E. undetected. 3.5. Agricultural projects None None as definition awaited. 4. DECOMMISSIONING PHASE ACTIVITIES

4.1. Identify all facilities and activities for Positive in terms Completion of negotiation on Low retention within the post Mining of re-use of post mining use for agriculture Land Use context existing facilities in and of mining town. the socio- economics of the region 4.2. Finalise transfer of town facilities, As above None As above administration and liabilities 4.3. Foster agricultural projects As above As above None 4.4. Complete backfilling of excavations Control through dust control None Air Quality (Dust) with nearby material (when available) measures and cover with topsoil Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 4.5. Shape excavation edges to 1:3 slope Control through dust control None Air Quality (Dust) and topsoil measures Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 4.6. Shape any remaining dumps as per Control through dust control None Air Quality (Dust) EMP specification and cover with measures 166 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Potential Impact Mitigation Type Potential for (E.g. dust, noise, (modify, remedy, control, or Residual Risk drainage surface stop)Through (e.g. noise control disturbance, fly rock, measures, storm-water control, dust surface water control, rehabilitation, design Activity contamination, measures, blasting controls, groundwater avoidance, relocation, alternative contamination, and air activity etc.). E.g. Modify through pollution etc….etc.…) alternative method. Control through noise control Control through management and monitoring through rehabilitation. topsoil if available Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 4.7. Demolish all unrequired structures Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 4.8. Remove all process plants and steel Control and remedy through Although unlikely structures hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 4.9. Remove all protruding foundations Control through dust control None and footings Air Quality (Dust) measures, cover by pebble deflation surface.

4.10. Remove all pipelines and cables Control through dust control None Air Quality (Dust) measures Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 4.11. Remove diesel tanks, bunds, Control through dust control None Air Quality (Dust) rehabilitate footprint & measures decontaminate Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 4.12. Rip / scarify logistical facilities/areas Control through dust control None and footprints and apply pebble Air Quality (Dust) measures and cover by deflation surfaces where pebble deflation surface. appropriate. Control and remedy through Although unlikely hydrocarbon management there is a minor Hydrocarbon protocol residual risk if leak goes undetected. 4.13. Retain access roads for future use None NA NA 5. AFTERCARE PERIOD 5.1. Remove alien vegetation (if applicable) None None Low 5.2. Conduct final performance assessment None NA NA 5.3. Lodge closure Application None NA NA 167 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Potential Impact Mitigation Type Potential for (E.g. dust, noise, (modify, remedy, control, or Residual Risk drainage surface stop)Through (e.g. noise control disturbance, fly rock, measures, storm-water control, dust surface water control, rehabilitation, design Activity contamination, measures, blasting controls, groundwater avoidance, relocation, alternative contamination, and air activity etc.). E.g. Modify through pollution etc….etc.…) alternative method. Control through noise control Control through management and monitoring through rehabilitation. 5.4. DMR Grant Closure Application None NA NA

23 Other Information required by the competent Authority

23.1 Compliance with the provisions of sections 24(4)(a) & (b) read with section 24(3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998). The EIA report must include the:-

23.1.1 Impact on the socio-economic conditions of any directly affected person. Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any directly affected person including the landowner, lawful occupier, or, where applicable, potential beneficiaries of any land restitution claim, attach the investigation report as Appendix 3 and confirm that the applicable mitigation is reflected in 2.5.3; 2.11.6.and 2.12.herein). Given that the Cession of the Mining Right from THG to LOR-D facilitates the required level of further developing the large remaining reserves of the mining area, mining in terms of this EMP and the Cession facilitates significant employment, retention of accomodation in the existing residential facilities and a basis for retained regional infrastructure including road maintenance. It also provides a long mining lifespan within which a refinement of the post mining land use including agricultural development can be planned and developed as final phases of operational and post mining rehabilitation while the mine remains a contributor through the social and labour plan to the Local Economic Development Projects and schools development of staff and community members.

23.1.2 Impact on any national estate referred to in section 3(2) of the National Heritage Resources Act. (Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any national estate referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) with the exception of the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act, attach the investigation report as Appendix 3 and confirm that the applicable mitigation is reflected in 2.5.3; 2.11.6.and 2.12.herein).

As the existing EMP has established the distribution of archaeological relics (refer para 13.11 Table 13.11 Archaeological sites taken from specialist report) requiring protection from disturbances, these will again serve this update but a new approach to their demarcation and role in tourism must be taken as the viewing platform over chosen petroglyphs was vandalised.

168 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020

Nonetheless this Draft Scoping report will be submitted to SAHRIS online systems for update of SAHRIS involvement within the current system.

24 Other matters required in terms of sections 24(4)(a) and (b) of the Act. (the EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in sub-regulation 22(2)(h), exist. The EAP must attach such motivation as Appendix 4).

Not applicable – refer Figure 9: Provisional Overall Mine Plan and Figures JVMP 1 to JVMP 11 for JV Geographic Area Mining Plans which reconsidered the current approved mine plan and its revisions required in terms of the new Cession of rights and the shift in target mining area focus from largely mined out proto terraces to the prospected but unmined meso terraces.

25 UNDERTAKING REGARDING CORRECTNESS OF INFORMATION I, Stephen van der Westhuizen herewith undertake that the information provided in the foregoing report is correct, and that the comments and inputs from stakeholders and Interested and Affected parties will be correctly recorded in the final report.

Signature of the EAP DATE: 01 September 2020

26 UNDERTAKING REGARDING LEVEL OF AGREEMENT I, Stephen van der Westhuizen herewith undertake that the information provided in the foregoing report is correct, and that the level of agreement with interested and Affected Parties and stakeholders to date has been correctly recorded and reported herein.

Signature of the EAP DATE: 01 September 2020

169 DRAFT SCOPING REPORT to the LOR Mine S102 Amendment/Update of MWP and EMP/SPC #2798/Sept 2020