SLR SA Letter Template

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

31 March 2021

Dear Sir/Madam, IMPALA PLATINUM LIMITED SUMMARY OF THE BASIC ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED INCREASE OF THE FLASH DRYER CAPACITY AND ASSOCIATED FEED CIRCUIT MODIFICATIONS AT THE IMPALA RUSTENBURG SMELTER COMPLEX BASIC ASSESSMENT REPORT AVAILABLE FOR PUBLIC REVIEW INTRODUCTION

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

SLR Consulting (South Africa) Proprietary Limited

Registered Address: Suite 1 - Building D, Monte Circle, 178 Montecasino Boulevard, Johannesburg Office: Physical Address: Suite 1 - Building D, Monte Circle, Fourways, Johannesburg, Gauteng, 2191 178 Montecasino Boulevard, Fourways, Johannesburg, Gauteng, 2191 Postal Address: PO Box 1596, Cramerview, 2060, South Africa Postal Address: PO Box 1596, Cramerview, 2060 Tel: +27 11 467 0945

Reg. No: 2007/005517/07 Cape Town Office: Physical Address: 5th Floor, Letterstedt House, Newlands on Main, Cnr Main and Campground Roads, Newlands, Cape Town, Western Cape, 7700 Vat No: 4630242198 Postal Address: PO Box 10145, Caledon Square, 7905 Tel: +27 21 461 1118

Directors: R Hounsome, F Fredericks, D Junak www.slrconsulting.com

Page 2

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

SLR, an independent firm of Environmental Assessment Practitioners (EAPs), has been appointed by Impala to manage the environmental authorisation process. In this regard, the Basic Assessment Report (BAR) and Environmental Management Programme (EMPr) for the proposed project is available for a public review. This document presents a summary of the findings for the BAR undertaken for the proposed project. In this regard the following sections have been extracted from the BAR and included in the summary document:

• the executive summary – included in Appendix A of this document; and • summary of issues and concerns raised by Interested and Affected Parties (I&APs) – included in Appendix B of this document.

REVIEW OF THE BASIC ASSESSMENT REPORT

This BAR will be distributed for a 30-day period from 1 April to 5 May 2021 in order to provide I&APs with an opportunity to comment on any aspect of the proposed project and the findings of the Basic Assessment (BA) process. Copies of the full report are available on the SLR website (at https://slrconsulting.com/public-documents) and the SLR data free website (at slrpublicdocs.datafree.co). If you have any questions, please contact the undersigned.

Yours faithfully

Reinett Mogotshi

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 3

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

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

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

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

STAKEHOLDER ENGAGEMENT The stakeholder engagement process commenced prior to the submission of the Basic Assessment Report (BAR) and has continued throughout the environmental assessment process. As part of this process, the following activities were undertaken: • focussed meetings were held with the Mine Community Leadership Engagement Forum; • a focussed meeting was held with the North West Provincial Department of Environment, Conservation and Tourism;

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 4

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

• distribution of public participation material (flyers, advertisements, site notices and Background Information Document (BID)) to inform commenting authorities and Interested and Affected Parties (I&APs) of the proposed project; and • the electronic review of the Background Information Document by Interested and Affected Parties (I&APs). Commenting authorities and I&APs now have the opportunity to review this BAR. All comments submitted to date by the commenting authorities and I&APs have been included and addressed in this BAR. Further comments arising during the review of the BAR will be handled in a similar manner.

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

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

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

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

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Limpopo KwaZulu-Natal Mpumalanga Limpopo Kilometers Gauteng 2020/11/13 ! ( Free State Free Eastern Cape Eastern North West North SLR Consulting (Africa) (Pty)Consulting SLR Ltd Scale:1:250 000 @ A3 ImpalaPlatinum Limited Datum: Hartebeeshoek, Lo 23 Projection:TransverseMercator Project Location 0 4 8 P O Box 1596, Cramerview, 2060, O 1596, Cramerview,Box Africa P South Tel: +27 (11) 467-0945 +27 Tel: (11)+27 Fax: (11) 467-0978 Towns Villages / Towns Main Roads Power Line Railway Line Rivers Dams AreasProtected Nature/ Reserves ImpalaSurface Area Use ImpalaSmelter Complex Northern Northern Cape 720.19136.00002 ! O ! (

± Western Cape Western

Figure1 RegionalSetting Legend

-2790000 -2795000 -2800000 -2805000 -2810000 -2815000 -2820000 -2825000 -2830000 -2835000 -2840000 -2845000 -2850000

e !

! m o

h o r t s k r s e t S T

1 ! 51

R !

! ! Mooinooi Dam

e ! ! l i Roodekopjes d Modikwe

55000 o 55000

c Barseba ! ! o r a Wonderkoppies C an

! w ! etl ar !

M ! !! ! !

! !

h t !

w !

G !

! !

! ! ! ! !

Hartbeestfontein ! !

Marikana

! ! 50000 50000

o ! !

k r

! t ! ! S

Dam !

Vaalkop

! !

e s !

H Maumong d

! !

! ! ! n

l E

Vaalkop Dam Vaalkop

45000 ! 45000 ! !

Nature Reserve

! !

! 4

1 R

! ! ! Lekojaneng

i Rankelenyane

! t ! i k ! i

Boyateng s ! 40000 t ! 40000

! a Nkaneng

M !

Thekwane !

! ! !

Lesung

! ! !

Ga-Mogajane ! !

! ! Mogajane

Tantanana

! ! ! Mosonthane

! it Motsitle

! ! u

Mfidike

Photsaneng

! r

35000 ! 35000

! ! p !

! !

! ! s

! d BospoortDam ! n

Lesung a Waterval

Tsitsing

Paardekraal S

! !

o ! h s ! t a m a i b ! d a M Matalaneng

! ! ! !

! !

! ! !

510 Setlhokwe ! !

R Kana

! ! Mafika

! ! !

30000 ! 30000

Maille ! !

Roodekopjes !

na !

onga ! ! Klipfontein

Sun City m ! a ! gw !

pon !

!! ! la 30 ! R ! o !

! M ! !!

! ! ! !

Kapman

! !

! ! !

! ! ! ! ! !

! Jabula

Maile

! ! t i ! Freedom Park

! Rustenburg ! ! !! u

! !

! r

! ! p

! Zinniaville ! s 25000 25000

!! Geelhoudpark !

! ! f ! !! !

! o

! ! !

! ! !! !! ! o ! l ! ! ! ! !

! ! ! k ! ! i Doringpoort ! ! !!! t

! ! !! !! ! i ! o

! Mogwase ! ! !

! Thalabane u

!!! ! ! r o

! Proteapark

! d ! ! ! !!! ! p R

6 R s Lefaragatlhe

5 ! f

5 a ! ! i o !! !!! !

R ! n o

l Kgaswani

! o k !

s r

! t ! ! ! !! e ! ! ! t Nature Reserve

! ! ! a 20000 ! ! 20000 ! ! ! !

Ga Ga Luka ! !

! !! ! ! W

! ! Wa Mogono ! ! !

! ! !

! !

! ! ! !

! ( ! !!

RustenburgNorth ! ! ! ! ! !

! ! ! ! ! ! Ga-kgale ! Lenatong ! ! ! ! !

!! !

! ! ! ! ! ! ! !

! Phokeng !

! ! ! !

e !!

! !!! ! n ! !

a !

g ! !! ! a !

r !

! ! !

e ! ! 15000 15000

L ! ! !

Dam

! !

Tshaneng ! !

Houwater Robega

! ! !

! !

! ! Magalies Protected

! Rasimone

! ! Natural Environment ! ! ! !

! ! ! ! ! ! ! !

Letsasing ! ! ! 10000 10000 ! !

! !

4 Lekwadi

! Ledig

! s

e n

a o

r el w Complex

a S

Location of t

! -

u a

a ImpalaSmelter r

! t G M

i p

5000 5000 PilanesbergNational Park s

ru e

! 2

p o 5

! s R

d e 5 o

6 n

! 5 a ! K W i l g e s p r R u i t S Phatsima

! 0 0 !

! !

p !

Tlhatlhaganyane s

Maologane s r -5000 -5000

othlabe a !

M w D

r Dam

t Koster Modimong s

o ! K

Mabeleleng -10000 ! -10000

u !

s !

Batlhalerwa !

Bapong g

n e

-15000 -15000

b !

o ±

-2790000 -2795000 -2800000 -2805000 -2810000 -2815000 -2820000 -2825000 -2830000 -2835000 -2840000 -2845000 -2850000 Kilometers 2020/11/13 SLR Consulting (Africa) (Pty)Consulting SLR Ltd Scale:1:50000 @A3 Datum: Hartebeeshoek, Lo 27 ImpalaPlatinum Limited Projection:TransverseMercator 0 1 2 P O Box 1596, Cramerview, 2060, O 1596, Cramerview,Box Africa P South Tel: +27 (11) 467-0945 +27 Tel: (11)+27 Fax: (11) 467-0978 Towns Villages / Towns Main Roads Power Line Railway Line Rivers Dams ImpalaSurface Area Use ImpalaSmelter Complex Project Footprint 710.09003.00140 " /

Figure2 LocalSetting Legend

-2820000 -2825000 -2830000

Freedom Park Freedom 25000 25000 Dam Rockwall Impala Hospital 20000 20000

Bobuantswa

Ga Luka Ga

Mogono

u ath K To

Lenatong Complex

Phokeng ImpalaSmelter 15000 15000

5 56 R

u r

s l

± o

-2820000 -2825000 -2830000 Page 7

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Table A: Summary of potential impacts Aspect Potential Impact discussion and reference to mitigation measures Significance impact Unmitigated Mitigated Geology Loss and Impact Insignificant sterilisation of • mineral resources can be sterilized and/or lost through the placement of infrastructure and activities in close mineral proximity to mineral resources. resources • the proposed project footprint is within an existing Impala Smelting Complex and does not influence current underground mining activities. It follows that the proposed project will not result in the sterilisation of any mineral reserves.

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

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

Mitigation measures: • not applicable. Biodiversity Physical Impact Insignificant destruction • areas of ecological sensitivity include functioning biodiversity areas with species diversity and associated intrinsic and general value. Linkages between these areas have value because of the role they play in allowing the migration or

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 8

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Aspect Potential Impact discussion and reference to mitigation measures Significance impact Unmitigated Mitigated disturbance of movement of flora and fauna between the areas, which is a key function for a broader ecosystem. The biodiversity transformation of land for any purpose increases the destruction of the site-specific biodiversity, the fragmentation of habitats, reduces its intrinsic functionality and reduces the linkage role that undeveloped land fulfils between different areas of biodiversity importance. • the proposed project is located is within the concrete lined Smelter Complex and as such all-natural vegetation has been removed. Further to this, the Smelter Complex is an enclosed facility and does not allow for the natural movement of faunal species, while noisy and vibrating equipment scare off faunal species. It follows that the proposed project will not have an impact on biodiversity.

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

Mitigation measures: • not applicable.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 9

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Aspect Potential Impact discussion and reference to mitigation measures Significance impact Unmitigated Mitigated Contaminatio Impact: Medium Very Low n of surface • The project presents contamination sources that have the potential to pollute surface water, through accidental water spills and leaks. These do not differ from current Smelter contamination sources. resources • The closest surface water resources are the non-perennial Leragane stream, its tributary and wetland (based on provincial database only, not a true reflection of on-site condition). • Without mitigation, contaminates can reach surface water resources, which can be used by third parties for domestic purposes. • With mitigation it is unlikely for contamination to reach surface water resources as these will be contained within the Smelter Complex. Further to this, the surface water resources are non-perennial and communities do have access to reticulated water. Mitigation measures: • Continued implementation of containment of dirty water. • Continued monitoring and investigation (where necessary). • Equivalent alternative water supply if Impala operations result in contamination of a surface water resources that cannot be accessed by third parties. Groundwater Contaminatio Impact: Insignificant n of • groundwater is a valuable resource and is defined as water which is located beneath the ground surface in groundwater soil/rock pore spaces and in the fractures of lithological formations. Activities such as the handling and storage resources of general and hazardous wastes have the potential to result in the loss of groundwater resources, both to the environment and third-party users, through pollution. • the proposed project is located within the existing Smelter Complex on an impermeable concrete layer. The proposed project activities/infrastructure is unlikely to contribute to groundwater contamination impacts.

Mitigation measures: • not applicable.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 10

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Aspect Potential Impact discussion and reference to mitigation measures Significance impact Unmitigated Mitigated Air quality Air pollution Impact: Low Very Low (the flash • the proposed project presents emission sources that have the potential to contribute to air pollution, through

dryer together dust fallout, fine particulate matter (PM10 and PM2.5) and gaseous emissions (SO2, NOx and CO) as a result of with existing transportation, handling materials as well as operation of the second flash dryer emitting through a dedicated smelter baghouse stack. activities) • scenario 1 (Flash dryer only): Based on modelled results, with and without mitigation the proposed project is unlikely to exceed the NAAQS and NDCR limits. • scenario 2 (the flash dryer together with existing smelter activities): Based on modelled results, with and without mitigation, the Smelter operations (are unlikely to exceed the NAAQS and NDCR limits). Mitigation measures: • continued implementation of the Impala air quality monitoring programme Air quality Air pollution Impact: High Medium

(flash dryer • Scenario 3 (flash dryer with all Impala operations): Based on the model results, the PM10 NAAQS, PM2.5 NAAQS Medium (Dust Low (Dust

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

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

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

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

Mitigation measures: • Continued implementation of the Impala air quality monitoring programme. • Implementation of measures for reduction of fugitive PM and vehicle exhaust emission. • Implementation of control efficiencies for vehicles traveling on paved roads.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 11

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Aspect Potential Impact discussion and reference to mitigation measures Significance impact Unmitigated Mitigated Noise Increase in Impact: Insignificant disturbing • Mining activities and infrastructure have the potential to cause an increase in ambient noise levels that may cause noise levels a disturbance to nearby sensitive receptors. It is however important to note that, the noise contributions associated with the proposed project are unlikely to be noticeable in the context of the existing noise environment within the Smelter Complex. Mitigation measures: • Not applicable. Visual Negative Impact: Insignificant visual views • Mining infrastructure has the potential to alter the landscape character of an area through the establishment of infrastructure. It is however important to note, that the establishment of infrastructure as a result of the proposed project will be absorbed within the Smelter Complex. • The proposed project is unlikely to generate additional negative views that will be noticeable from Ga-Luka, located approximately 2 km away from the proposed project location. Mitigation measures: • Not applicable. Traffic Road Impact: Insignificant disturbance • Existing traffic volumes comprising public traffic and traffic from the Impala Smelter operations utilise several influence on roads intersections. The existing road network of relevance to the proposed project (Lefaragatlha Road, Luka Road the level of and R565) are considered to have an acceptable level of service. service • The proposed project is not anticipated to generate a significance increase in the number of additional trucks (additional 26 trucks per day, transporting toll) and would therefore have an insignificant impact on the condition of the existing road network. Mitigation measures: • Not applicable. Road safety Impact: High Medium impacts • traffic from mining projects has the potential to result in public road safety issues such as pedestrian accidents and vehicle accidents. • the project will result in additional trucks transporting toll material using Lefaragatlha Road, Luka Road and Road R565. Construction related traffic is limited. • the Lefaragatlha Road and Luka Road have a medium sensitivity as they run through communities. These roads require geometric upgrade in the context of existing public infrastructure. • in the unmitigated scenario the significance is high, particularly where the geometric upgrades are not implemented.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 12

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Aspect Potential Impact discussion and reference to mitigation measures Significance impact Unmitigated Mitigated • in the mitigated scenario the significance reduces to medium because the frequency of accidents is expected to reduce. Mitigation measures: • undertake a road safety assessment on roads adjacent the Impala Smelter Complex including Intersections A, B, C and F to determine the need for the reflective studs, updating and maintaining road markings and provision of relevant road traffic signs where required. • provide Impala Smelter Complex workers and contractor workers with training on road safety; and • Run road safety and awareness campaigns at the mine.

Heritage/cultu Loss of Impact: Insignificant ral and heritage/cultu • In general, the proposed project area is situated in the Central Bankeveld which has a rich archaeological heritage palaeontologic ral and dating from prehistoric and historic (or colonial) periods, which form a record of cultural heritage of most groups al resources Palaeontologi living in South Africa. However, none of the identified heritage resources lies within the proposed project footprint cal resources • The palaeontological studies conducted indicated that the surface use areas are situated on underlying igneous rocks of the Precambrian Rustenburg Layered Suite of the Bushveld Igneous Complex and as such palaeontological resources are not associated with this underlying geology. In addition, the site is located within the disturbed footprint of the Smelter Complex. Mitigation measures: • Not applicable. Socio- Inward Impact: Insignificant economic migration • Mines tend to bring with them an expectation of employment in all project phases prior to closure. This expectation can lead to the influx of job seekers to an area which in turn increases pressure on existing communities, housing, basic service delivery and raises concerns around safety and security. • The proposed project is located within an existing Smelter Complex and will result in limited short-term employment opportunities through usage of registered community vendors during construction, therefore negative project-related socio-economic impacts including inward migration, which could place additional pressure on housing and municipal services, are not expected to occur. Mitigation measures: • Not applicable. Economic Impact: Insignificant Very Low impact • Mining activities contribute towards a positive economic impact. (Positive) • The proposed project will allow for the creation of limited short-term employment for communities during the construction.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 13

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Aspect Potential Impact discussion and reference to mitigation measures Significance impact Unmitigated Mitigated • The proposed project will allow continuation of the current employment opportunities during operation, decommission and closure. Mitigation measures: • Continued implementation of the existing Impala management actions pertaining to the procurement of local people (where possible) and procurement of local goods. Land use Change in land Impact: Insignificant use • There are a number of land uses in the surrounding proposed project area which may be influenced by the proposed project and associated potential environmental impacts. • Given that the Land use within the proposed project is limited to mining as a result of the existing smelter operations, the proposed project will not result in changes to the current land use. Mitigation measures: • Not applicable.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 14

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

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

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 15

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

APPENDIX B: SUMMARY OF ISSUES RAISED BY I&APS A summary of the issues and concerns raised by I&APs, regulatory authorities and commenting authorities to date as part of the public participation process are tabulated below.

Table B: Summary of issues and concerns raised

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Tribal Authority, Community Leadership including Ward Councillors Procedural and project related concerns Councillor Dikebane X 29 October 2020 What is a flash dryer? As part of Impala’s operations, ore from underground mining operations is Not applicable at the Mine concentrated at the concentrator plant. The wet concentrate from this Community process needs to be dried before it can be put through the furnaces. Impala Leadership has two drying processes for the wet concentrate i.e. spray dryers and a flash Engagement dryer. The flash dryer is used to dry filter cake material from third parties such Forum Focus as Marula. The material is dried and goes through the furnaces for smelting. Meeting Councillor Mekgoe X 29 October 2020 What is the size of the flash dryer? The current flash dryer is 45 tons per hour of dry concentrate, the second flash Not applicable at the Mine Some of us don’t know what a flash dryer will be the exact replica of the existing flash dryer. The reason for the Community dryer looks like. installation of the additional flash dryer is to allow for maintenance of the Leadership existing dryer. This will allow Impala to have a flash dryer operational while Engagement one is undergoing maintenance. Forum Focus Meeting Councillor Ntikelane X 29 October 2020 We advise that that the proposed This has been done. Refer to Section 7.2.1 at the Mine flyers and site notices can be placed Community at the following locations:

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 16

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 17

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

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

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 18

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

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

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 19

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Councillor Masilo X 01 December Why is the Public Participation Your comment has been noted. The public participation materials have been Appendix C and Councillor 2020 Feedback material being distributed through distributed by a local supplier. The Royal Bafokeng Nation and the ward (Stakeholder Mekgoe Meeting with the the RBN only, if the project area does councillors and were notified of the placement on materials on 15 February Engagement) Mine Community not fall on RBN land, in which case 2021. Leadership the ward councillors from the Local Engagement Municipality need to also be Forum involved in the distribution of the PPP material. Please amend the presentation to reflect this Councillor Masilo X 29 October 2020 Three years back, a company from SLR has been selected as a supplier due to its extensive experience in Not applicable at the Mine Joburg was stopped from making a managing complex environmental authorisation processes for mining Community presentation. Why has Impala projects as well as their history of the Impala operations and their knowledge Leadership appointed another company from of the stakeholder structures. Engagement Johannesburg? There is lack of Forum Focus transformation at Impala, why are Meeting local companies not considered? Why are big companies awarded millions of tenders? Councillor Mekgoe X 01 December Why is Impala always awarding 2020 Feedback tenders to Consultants in Meeting with the Johannesburg? The Rustenburg Mine Community community is being undermined, Leadership and the MCLEF cannot be subjected Engagement to this discrimination. Are these Forum consultants transferring knowledge and skills to the local companies?

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 20

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

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

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 21

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Councillor Mputle X 29 October 2020 Give us statistics on the employment Impala Platinum is the biggest employer in the North West Province and the Not applicable. at the Mine created by Impala. breakdown of the information from provincial to local level is presented Community below. Leadership • North West Province – 14 676 Engagement • Bojanala District Municipality – 9637 Forum Focus • Rustenburg Local Municipality – 8087 Meeting • Royal Bafokeng Nation - 2823 Councillor Mekgoe X 01 December The employment statistics are not Not applicable 2020 Feedback clear, therefore making it difficult for Meeting with the the CLEF to understand. The Mine Community presentation should be given to the Leadership CLEF in time for them to understand Engagement the contents thereof. Forum Councillor Lefyedi X 01 December The procurement system for third Impala is currently applying to install the second flash dryer which will be used Not applicable 2020 Feedback party mining companies (i.e. Marula) to treat concentrate from other mining companies. Impala does not have an Meeting with the delivering toll materials to the input on the procurement system of other mining companies based on the Mine Community Smelter Complex should make following: Leadership provision to extent opportunities to • Mining companies have their own mine leadership that require them to Engagement the communities surrounding the extend opportunities to the local communities. Forum Smelter Complex or create a • Mining companies are governed by different procurement systems and requirements. platform where they can be engaged

by the community leadership. Failure to extent such opportunities or to provide a platform where they

can be engaged will result in the

community making decisions on

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 22

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted what happens when they are delivering toll material to the Smelter Complex. Councillor Lefyedi X 01 December According to the presentation, 2020 Feedback opportunities will be extended to Meeting with the communities where possible? This Mine Community statement implies that contractors Leadership will come and use their own people. Engagement There should be a clause in the Forum agreement between Impala and the appointed contractor to extend employment opportunities to the community. Third-party trucks will increase, and the community will not benefit. These truck owners must be forced to provide employment opportunities to the community or to partner with the local people. Councillor Mekgoe X 01 December How was the traffic specialist The traffic specialist was appointed by SLR. The appointment of the specialist Not applicable 2020 Feedback appointed by Impala? The tender was based on their experience and knowledge of the area. However, SLR will Meeting with the was not made available to the identify subcontracting activities that could be extended to the community in Mine Community community. future. Leadership Engagement Forum

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 23

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

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

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 24

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Potential air and related health impact concerns Councillor Ntikelane X 29 October 2020 According to your presentation, the Criteria pollutants are considered those pollutants most commonly found in Section 7.7 and 7.8 at the Mine potential impacts with respect to air the atmosphere, that have proven detrimental health effects when inhaled Appendix E (Air Community are low. However, we must have and are regulated by ambient air quality criteria. These generally include Quality Study)

Leadership control measures because the PM10, PM2.5, SO2, NO2, CO and O3. Main emission sources within and around

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 25

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Engagement project results in additional air Impala include dust fallout and gaseous emissions. Dust fallout represents the Forum Focus emissions in relation to existing coarse fraction >10m of total suspended particles that can visually be seen Meeting emissions in the area. by third parties. PM has the potential to contribute to health concerns as Kgosana Rapebana X 29 October 2020 My main concern is air pollution, we particulate matter with an aerodynamic diameter of less than 10m (PM10) at the Mine are currently experiencing air and an aerodynamic diameter of less than 2.5m (PM2.5) is the finer inhalable Community pollution and the project will result fraction. Gaseous emissions (gaseous material released) include SO2, NOx and Leadership to an increase in air pollution in the CO and also contributes to health concerns. Engagement area. Please make sure that you Forum Focus monitor air pollution. Current baseline monitoring indicates that the PM2.5 and PM10 monitored Meeting data shows exceedances of the annual and 24-hour NAAQS. The SO2 monitored data (specific to the Smelter Complex) shows no exceedances of Kgosana Mothibe X 29 October 2020 Our women are miscarrying, reports the annual, daily and hourly NAAQS. The operations off-site dustfall rates at the Mine like these will give us answers. Community Currently, the way the project is sampled complies in terms of the NDCR. It is however important to note that Leadership presented, it’s to help Impala make Impala is not the only contributor to emission sources. Surrounding Engagement profit. As a community we will industries/mines and community activities such as farming activities, Forum Focus never get a cent from it. domestic fires, vehicle exhaust emissions and dust entrained by vehicles also Meeting contribute to PM and dust fallout concentrations. Impala has submitted an Councillor Mputle X 29 October 2020 Studies should be done to determine offset plan to DEFF to assist in addressing current air quality related matters. at the Mine the health impacts from the Impala Community operations. As part of the proposed project, an independent air quality specialist was Leadership appointed to determine the contribution that the proposed project will have Engagement on existing ambient concentrations. The scope of the study was confined to Forum Focus the quantification of impacts due to exposures via the inhalation pathway Meeting only. Simulated ambient pollutant concentrations and fallout rates were compared to NAAQS, health risk screening levels, and NDCR, nuisance Kgosana Montsho X 29 October 2020 The clinics are full. This is because of screening levels. Compliance was assessed, and a health risk/nuisance at the Mine emissions from the Impala plant. Community Has impala taken time to screening completed.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 26

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Leadership understand why people are sick? The results of the Air Quality Study indicate that on its own and within the Engagement Life expectancy is questionable, and context of the existing Smelter Complex the proposed project does not result Forum Focus we don’t have facts. Studies should in any exceedances of the NAAQS and the NDCR at AQSRS. When the Meeting be done to help us understand this, proposed project is considered in the context of the existing Impala instead studies are only done to operations exceedances of the future PM2.5 and current PM10 and NOx in help Impala kill us. terms of the NAAQS limits with mitigation was noted. It is however important to note that these exceedances are as a result of existing on-site exceedances and as such the proposed project operations resulted in a minimal increase in simulated ambient pollutant concentrations and dust fall rates in comparison to what was simulated for existing operations.

A copy of the Air Quality Study is included in Appendix E. Councillor Mekgoe x 01 December What is the air quality monitoring The air quality monitoring programme is conducted to monitor air emissions Appendix D (Detailed 2020 Feedback programme? associated with Impala operations and community activities. Impala will Impact Assessment) Meeting with the consider sharing the monitoring results at the MCLEF in future. What new technologies that can be Appendix E Mine Community used to manage air pollution, which As part of the air quality impact assessment undertaken, three impact (Air Quality Study) Leadership form part of Scenario 3 (Modelling assessment scenarios were analysed to understand the impact of the Engagement scenario that takes into account proposed project on the current air quality baseline (Scenario 1), the impact Forum emissions associated with the of the smelter operations including the proposed project on the current air proposed project, smelter quality (Scenario 2) and the cumulative impact of the proposed project, operations and all impala smelter operations and all impala operations (Scenario 3). The findings from operations in the area) as per the this assessment indicate that there is a possibility of exceedances of air finding of the air quality assessment emission limits under Scenario 3 in 10 years’ time, provided that all impala undertaken. operations are run simultaneously. The new technologies mentioned with Councillor Masilo x 01 December Can the MCLEF be provided with Scenario 3 refer to any technology that could be identified in future to Appendix D (Detailed improve the state of air quality. 2020 Feedback more information on the air quality Impact Assessment)

Meeting with the legislation (i.e. the National Air Appendix E (Air Mine Community Quality Standard and Dust Control Quality Study)

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 27

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Leadership Regulations) as well as the findings Engagement of the Air Quality Study, which Forum states that the project will not affect the community from an air quality perspective in writing. Groundwater Councillor Mputle X 29 October 2020 We can’t use boreholes; the water Impala has an existing groundwater monitoring programme that is utilised Section 7.4.1.7 at the Mine is salty. Some animals are dying. to monitoring the quality and quantity of groundwater within the Impala Community surface use area. Boreholes within the vicinity of the Smelter Complex are Leadership only utilised for monitoring purposes. Any groundwater complaints need to Engagement be directly to Impala and site-specific investigations can be undertaken. Forum Focus Meeting Councillor Lefyedi X 01 December My main concern is groundwater. The following findings from the BAR in terms contamination of groundwater Appendix D (Detailed 2020 Feedback The information provided in the resources are noted: Impact Assessment) Meeting with the presentation states that the project • The proposed project is located within the existing Smelter Complex on Mine Community will not affect our groundwater an impermeable concrete layer; Appendix E (Air Leadership supply. Please provide this • The proposed project activities/infrastructure is unlikely to contribute to Quality Study) Engagement information in writing. groundwater contamination impacts; and Forum • In the event of groundwater related compliant, this needs to be

investigated by Impala.

Surface Water Councillor Masilo X 01 December We are currently having a water The potential impact on surface water resources was considered by SLR as Section 26 Councillor Mekgoe 2020 Feedback problem in Rustenburg. We are not part of the proposed project. The specialist investigations indicate that it is Appendix D (Detailed Meeting with the sure how the project will unlikely that the proposed project will result in the contamination of surface Impact Assessment) Mine Community contaminate our water. Please water resources. All dirty water run-off will be contained within the Smelter

Leadership Complex via existing stormwater management infrastructure. In the unlikely

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 28

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Councillor Masilo X 01 December In terms of water, will the project not The issue raised makes reference to provision of clean water which should be Appendix D (Detailed 2020 Feedback result in contamination of our addressed by the municipality and the Rand Water Board. Impact Assessment) Meeting with the water? If there are any problems The installation of the flash dryer will not result in significant impact to the Mine Community with our water supply, the localised surface water resources and groundwater resources. Leadership alternatives will be rivers Engagement Forum Socio-Economic Councillor Nameng X 29 October 2020 This consultation process is a tick box Your comment has been noted. Public participation is a legal requirement in Not applicable. at the Mine exercise for the application to be terms of the NEMA. The purpose of the public participation process is to allow Community lodged in terms of Section 102. for the community to be provided with an opportunity to provide input and Leadership Somebody will benefit, the status comment on the project which will enable the authority to make an informed Engagement quo must change. decision. Forum Focus Meeting Councillor Mekgoe X 29 October 2020 Communities are not benefiting Positive impacts associated with the proposed project include job Section 3.3.5 and at the Mine from the project; how do we ensure opportunities, however due to the nature of the project, the proposed project Appendix D (Detailed Community that communities benefit? External is not anticipated to generate significant job opportunities. Limited job Impact Assessment) Leadership trucks will be used for transportation opportunities will be available during the construction phase of the project Engagement of the materials. There must be and will be limited to a period of 2.5 years. Once an appointed contractor has Forum Focus economic- spin-offs for the been appointed to undertake the establishment of the proposed project Meeting community. We propose that we use components, employment opportunities will be extended to communities local companies owned by our (where possible). During the operational phase of the project, no new job people for transportation. opportunities are anticipated as existing employees will be utilised.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 29

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Councillor Mputle X 29 October 2020 Every day we bury our people, that at the Mine indicates that there is poverty in the Community area. If the project does not provide Leadership employment for people, it will not go Engagement ahead. Forum Focus Meeting Councillor Lefiedi X 29 October 2020 How will the project affect us at the Mine positively? How will this benefit me? Community What are the benefits within the Leadership project so that I know how to Engagement participate? Forum Focus Meeting Councillor Mekgoe X 29 October 2020 The project will result in additional at the Mine traffic that will have an impact on Community communities, however, external Leadership companies will benefit. If there is no Engagement proper plan from Impala on how the Forum Focus communities will benefit, this Meeting community will protest until economic spin-offs are derived from the project. Councillor Lefiedi X 29 October 2020 How will the project affect us The main negative impacts associated with the proposed project that have a Appendix D (Detailed at the Mine negatively? potential to influence communities include traffic safety impacts and air Impact Assessment) Community quality impacts. Leadership

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 30

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

In terms of air quality an independent air quality specialist was appointed to determine the contribution that the proposed project will have on existing ambient concentrations. The results of the Air Quality Study indicate that on its own and within the context of the existing Smelter Complex the proposed project does not result in any exceedances of the NAAQS and the NDCR at AQSRS. When the proposed project is considered in the context of the existing Impala operations exceedances of the future PM2.5 and current PM10 and NOx in terms of the NAAQS limits with mitigation was noted. It is however important to note that these exceedances are as a result of existing on-site exceedances and as such the proposed project operations resulted in a minimal increase in simulated ambient pollutant concentrations and dust fall rates in comparison to what was simulated for existing operations.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 31

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Councillor Ntikelane X 29 October 2020 I also don’t agree with the socio- The toll materials transported to the Smelter Complex comes from third party Appendix D (Detailed at the Mine economic ratings, there will be mining companies. As a result, Impala does not have an input on third party Impact Assessment) Community additional trucks resulting in socio- procurement process including appointment of contractors. It is also Leadership economic benefits. We already have important to note that the increase in the flash drying capacity does not Engagement socio-economic challenges in the increase the production capacity within the Smelter Complex. As a result, the Forum Focus area, please address the impacts and project will not result in an increase in the matte that would be transported Meeting include control measures. to the Impala Refinery. The proposed project will result in job opportunities, however due to the nature of the project, the proposed project is not anticipated to generate significant job opportunities. Limited job opportunities will be available during the construction phase of the project and will be limited to a period of 2.5 years. Once an appointed contractor has been appointed to undertake the establishment of the proposed project components, employment opportunities will be extended to communities (where possible). Councillor Mputle X 29 October 2020 Somebody will see the newspaper The proposed project is located within an existing Smelter Complex and will Appendix D (Detailed at the Mine and assume that there are job result in limited short-term employment opportunities through usage of Impact Assessment) Community opportunities. This will make people registered community vendors during construction, therefore negative Leadership protest, how are we going to resolve project-related socio-economic impacts including inward migration, which Engagement that? Where do these diseases come could place additional pressure on housing and municipal services, are not Forum Focus from? This is not included in the expected to occur. Meeting presentation. Councillor Nameng X 29 October 2020 The farm presented belonged to my Impala Platinum has a surface signed lease agreement with the RBA which Not applicable. at the Mine grandfather, but not a single person covers Portion 2 of Beerfontein 263 JQ farm. The Title Deed for the said farm Community benefited from Impala even by a is T373/1883 BP allocated for use. Any claims need to be discussed with the Leadership million or half a million. Impala RBA. Engagement should have compassion.

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 32

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Forum Focus The DRDLR Land Claims Commissioner in North West has been contacted to Meeting confirm if there were any land claims on Portion 2 of the farm Beerfontein 263 JQ. The Land Claims Commissioner has confirmed that no land claims have been lodged on Portion 2 of the farm Beerfontein 263 JQ. Traffic Councillor Mekgoe X 29 October 2020 I disagree with the concept that the The installation of the second flash dryer and the upgrades to the existing feed Appendix D (Detailed at the Mine project does not encroach on circuit project activities will not encroach on community related activities as Impact Assessment) Community existing communities, an increase in they are confined to the Smelter Complex and are not near any communities Leadership traffic is an encroachment on and will therefore not influence day to day community activities. The project Engagement communities. will result in additional vehicles along the Lefaragatlha road and Luka Road Forum Focus and as such a traffic specialist has been appointed to determine the impact Meeting that this will have on the community. In this regard, the proposed project will not influence the current condition of the roads however, there is a potential for traffic related accidents associated with the movement of trucks. It is however important to note the increase in the number of trucks as a result of the proposed project is considered to be insignificant in the context of the existing Impala transport network along the Lefaragatlha road and Luka Road. As part of the proposed project, the specialist has however recommended additional geometric upgrades along the Lefaragatlha road and Luka Roads given that these roads run through communities. These geometric upgrades aim at reducing the probability of accidents occurring. Reotshepile X 19 November With regards to the Traffic Study, will The focus of the Traffic Study is the route that will be utilised by trucks Section 7.4.3.3 and Tlhapane 2020 at the Royal there be transportation of toll transporting material to and from site. The project specific transport route is Appendix F (Traffic Bafokeng Nation material from area A to area B the Lefaragatlha Road that runs through the Bobuampja and Lefaragatlha Study) Virtual Meeting outside the project study area? communities. Should this road not be used, an alternative road would be considered which runs through Phokeng community (Luka road)

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 33

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Where will the toll material be Impala treats third-party toll material from Marula and other mines coming from? transported to the Smelter Complex for processing via trucks., Impala receives third-party toll material from the Impala Group, specifically Marula, Two Rivers Mine, and the Zimplats Mine. Authorities Ellis Thebe X 04 December Please advise if SLR has a project The project schedule is available and takes into consideration Regulation 3(3) Not applicable 2020 Focussed schedule that takes into account of the 2014 NEMA EIA Regulations (as amended). Group Meeting Regulation 3(3) of the EIA with the North Regulations, which states that Public West Provincial Participation Process cannot be Department of undertaken between the closure Environment, period (i.e. from 15 December 2020 Conservation and and 5 January 2021)? Tourism Victor Loate X 04 December What is the sub-category 4.1 for? Sub-Category 4.1 is the Listed Activity for drying, calcining of mineral solids, Section 3.2 2020 Focussed including ore as indicated by GN R893 of 2013. An application for amendment Group Meeting of the existing AEL will be lodged with the Bojanala Platinum District with the North Municipality under sub-category 4.1. SLR has stated that the existing flash West Provincial dryer will be switched off when the Department of The proposed project consists of two phases. The first phase is the installation new flash dryer will be operational. Environment, of the second flash dryer within the Smelter Complex. The second phase of Kindly elaborate this. Conservation and the proposed project includes the flash drying circuit upgrade and structural Tourism From the project description, it is the modifications to the existing flash dryer. When the construction of the second department’s understanding that flash dryer is complete, the existing flash dryer will be switched off for the proposed project is not an maintenance and structural modification. amendment of an existing air emissions licence but an

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 34

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 35

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Victor Loate X 04 December Did SLR raise the query regarding the 2020 Focussed competent authority with the DMRE The DEDECT has been confirmed that the DMRE is the competent authority Group Meeting during the pre-application meeting for the proposed project. A copy of the corresponded received from DEDECT with the North and what was the DMRE’s view on is included in Appendix C. West Provincial this. Department of Environment, Conservation and Tourism Portia Krisjan X 04 December We will response once the necessary Comment noted. Not applicable 2020 Focussed information has been provided. Group Meeting with the North West Provincial Department of Environment, Conservation and Tourism Ellis Thebe X 04 December We need to discuss the project with Comment noted. Not applicable 2020 Focussed other divisions of our Department Group Meeting before providing a response given with the North that certain aspects of the project West Provincial may fall within their ambit of Department of responsibility. An example includes Environment, the Compliance and Air Quality Conservation and divisions. Tourism

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 36

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

Interested and Mark Date comment Issues raised Response provided Section and affected party with an X received paragraph reference if those in this report where who the issues and or must be responses were consulted incorporated were in fact consulted Other I&APs Paseka Dhlamini X 23 February 2021 I got this email last week, so I just The Background Information Document has been prepared to provide Appendix C Email want you to explain to me the stakeholders with the overview of the proposed project and an opportunity (Stakeholder purpose and what am I expected to to have input into the environmental assessment process. Engagement) do with this matter Boitshepo Mafoko X 23 February 2021 Did Bafokeng administration which Please be informed that that proposed project footprint is located within the Not applicable Email are the shareholders of Impala farm Beerfontein 262 JQ, and the farm Roodekraalspruit 113 JQ does not form Platinum informed you regarding an part of the proposed project footprint. These comments have been outstanding land dispute between forwarded to Impala for their attention. themselves and Ezrom Mafoko's clan. The Title holders of the proposed land Roodekraalspruit 113JQ. Therefore, we need them to come to party on resolving this dispute for progress. Boitshepo Mafoko X 15 March 2021 You have not responded neither Email acknowledge my letter dated the 24 February 2021. It is with sad regrets that your institution ignores my correspondence, but it is okay. Your actions simply say we have nothing to discuss about. Boitshepo Mafoko X 23 March 2021 It is with sad regrets that Bafokeng Email administration opted to use force against our people/community at Maile Roodekraalspruit, we

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com

Page 37

Project Reference: 710.09003.00140 File Ref. Summary of the Basic Assessment Report for The Impala Flash Dryer Project for public review

SLR Consulting (South Africa) Proprietary Limited www.slrconsulting.com