ENVIRONMENTAL MANAGEMENT PROGRAMME AMENDMENT: BLACK MOUNTAIN MINING – VEDANTA RESOURCES, AGGENEYS, NORTHERN CAPE

DOCUMENT DESCRIPTION

Client: BLACK MOUNTAIN MINING

Proposal Name: Environmental Management Programme Amendment

RHDHV Reference Number: E00.CPT.000402

DMR Reference: ML 5/2000

Date: June 2013

Location: Aggeneys, Northern Cape

Compiled by: Ntšeketsi Lerotholi

Reviewed by: Bronwen Griffiths

© Royal HaskoningDHV All rights reserved No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without the written permission from RHDHV and Black Mountain Mining.

TABLE OF CONTENTS

LIST OF FIGURES ...... V LIST OF TABLES ...... VI APPENDICES-SUPPORTING DOCUMENTS ...... VII APPENDIX A: WATER QUALITY AUDIT REPORT, FEBRUARY, 2001 ...... VII ABBREVIATIONS ...... VIII 1 INTRODUCTION ...... 1 1.1 History and Background Information ...... 1 1.1.1 Contact details for the mine ...... 2 1.2 Location of the Operations ...... 3 2 DESCRIPTION OF THE RECEIVING ENVIRONMENT ...... 5 2.1 Geology of the Broken Hill Deeps Project Ore Body ...... 5 2.2 Ground Water ...... 7 2.2.1 Overview ...... 7 2.2.2 Depth of water table(s) ...... 7 2.2.3 Background Groundwater Quality ...... 9 2.2.4 Ground water quality around the tailings and ageing pond area ...... 11 2.2.5 Depth of water Table ...... 14 2.2.6 Seepage Volumes ...... 14 2.2.7 Seepage quality prediction ...... 15 2.2.8 Groundwater Use ...... 16 2.3 Climate ...... 16 2.3.1 Mean monthly and annual rainfall ...... 17 2.3.2 Maximum rainfall intensities ...... 18 2.3.3 Mean monthly, maximum and minimum temperatures ...... 19 2.3.4 Monthly mean wind direction and speed ...... 20 2.3.5 Incidence of extreme weather conditions ...... 20 2.4 Topography ...... 20 2.4.1 Description ...... 21 2.4.2 Soil ...... 21 2.5 Land use ...... 24 2.5.1 Pre-mining land use ...... 24 2.5.2 Historical agricultural production ...... 24 2.5.3 Evidence of misuse ...... 24 2.5.4 Existing structures ...... 24 2.6 Natural vegetation / plant life ...... 24 2.6.1 Priority and Sensitivity Analysis...... 30 2.7 Fauna ...... 31 2.7.1 Commonly occurring species ...... 31 2.7.2 Avifaunal Priorities ...... 31 2.7.3 Drainage Context ...... 33 2.7.4 Surface water quality ...... 37 2.8 Air quality ...... 37 2.9 Noise 37 2.10 Sites of Archaeological and Cultural interest ...... 37 2.10.1 Overview ...... 37 2.10.2 Earlier and Middle Stone Age sites ...... 39 2.10.3 Middle Stone Age sites ...... 40 2.10.4 Later Stone Age Sites ...... 40 2.10.5 Rock art sites ...... 44 2.10.6 Painted boulder site near Aggregate Quarry ...... 44 2.10.7 Cemeteries and graves ...... 51

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2.11 Visual Aspects ...... 51 2.11.1 Study Area Visual baseline ...... 51 2.11.2 Study area visual character and VAC ...... 54 2.11.3 Presence of Receptor Locations and Visual Sensitivity of the Area ...... 55 2.12 Socio-economic structure ...... 57 2.12.1 Overview ...... 57 2.12.2 Formulation of Integrated Development Plan‟s ...... 59 2.12.3 Aggeneys Community Engagement Plan ...... 59 2.12.4 Small Business Development ...... 60 3 PROCESS DESCRIPTION ...... 62 3.1 Mining Process ...... 62 3.2 Mineral Processing Plant ...... 62 3.2.1 Crushing ...... 63 3.2.2 Milling ...... 63 3.2.3 Aeration ...... 64 3.3 Flotation ...... 64 3.3.1 Copper Flotation ...... 64 3.3.2 Lead Flotation ...... 65 3.3.3 Zinc Flotation ...... 65 3.4 Thickening ...... 66 3.5 Tailings Dam ...... 67 3.6 Backfill ...... 68 3.7 Storage of finished products ...... 71 3.8 Dispatch of Products from Site ...... 71 3.9 Waste Rock ...... 71 3.10 Supporting Services and Activities ...... 71 3.10.1 Housing, recreation and other employee facilities ...... 71 3.10.2 Water Supply ...... 72 3.10.3 Power / Electricity ...... 73 3.10.4 Airfields, roads and railways ...... 73 3.10.5 Sanitation facilities ...... 73 3.10.6 Diesel/Fuel ...... 75 3.10.7 Storm water ...... 75 3.10.8 Solid waste management facilities ...... 75 3.10.9 Hazardous waste ...... 77 3.10.10 Emergency Incidents and / or Accidents ...... 79 3.11 Concurrent Rehabilitation ...... 80 3.12 Closure and Decommissioning ...... 81 3.12.1 Closure objectives ...... 81 3.12.2 Closure framework ...... 81 3.12.3 Rehabilitation Methodology proposed for the infrastructure on site ...... 82 4 PUBLIC PARTICIPATION ...... 90 4.1 Consultation Process...... 90 4.1.1 Background Information Document ...... 90 4.1.2 Key Issues Identified ...... 90 4.2 Ongoing Communication...... 90 4.2.1 Complaints ...... 90 4.2.2 List of Interested and Affected Parties ...... 91 5 METHODS USED TO UNDERTAKE THE IMPACT ASSESSMENT ...... 92 5.1 Legal Requirements ...... 92 5.2 Definitions ...... 92 5.2.1 Criteria to Consider when Determining Severity of impacts ...... 93 5.3 Explanation of Impact Rating ...... 93 5.3.1 Probability and Likelihood ...... 93

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6 IMPACT ASSESSMENT ...... 96 6.1 Impact Assessment of Mining Process ...... 96 6.1.1 Impact assessment during Exploration drilling surface ...... 97 6.1.2 Impact Assessment for Underground Mining ...... 99 6.1.3 Impact assessment during ore handling Deeps Underground, Surface Conveyors, Waste Rock Dump & Tony‟s dam ...... 103 6.2 Impact Assessment for Crushing ...... 106 6.3 Impact Assessment for Milling and Aeration ...... 110 6.4 Impact Assessment for Flotation, Thickening and Filtration...... 113 6.5 Impact Assessment for Tailings Dam ...... 115 6.6 Impact Assessment for Backfill ...... 118 6.7 Impact Assessment for Storage of finished products ...... 125 6.8 Impact Assessment for Dispatch of Products from Site ...... 127 6.9 Impact Assessment for Waste Rock ...... 130 6.10 Supporting Services and Activities ...... 131 6.10.1 Impact assessment during maintenance ...... 131 6.10.2 Impact Assessment for Office Operations ...... 139 6.10.3 Impact Assessment for Water Supply and Storm Water ...... 141 6.10.4 Power / Electricity; Use of Generators ...... 143 6.10.5 Impact Assessment for Hazardous waste ...... 144 6.11 Impact Assessment for concurrent rehabilitation ...... 150 6.12 Impacts Associated with Decommissioning and Closure ...... 153 7 ALTERNATIVE LAND USE AND DEVELOPMENTS CONSIDERED ...... 154 7.1 Land-use / development Alternatives Considered ...... 154 7.2 Alternative Mining Methods ...... 154 7.3 Consequences of Not Continuing with the Mine ...... 154 8 ENVIRONMENTAL GOALS AND OBJECTIVES ...... 155 8.1 Environmental Goals and Objectives ...... 155 8.1.1 Environmental Legislation ...... 155 8.2 Water Pollution ...... 156 8.3 Dust 157 8.4 Noise 157 8.5 Blasting ...... 157 8.6 Waste Management ...... 157 8.7 Rehabilitation ...... 158 8.8 Environmental Awareness Training ...... 158 8.9 Socio-economic Goals and Objectives ...... 158 8.9.1 Skills Development ...... 158 8.9.2 Local Economic Development ...... 158 8.9.3 Black Economic Empowerment and Small, Micro and Medium Enterprises ...... 159 8.10 Heritage Goals and Objectives ...... 159 8.11 Closure Goals and Objectives ...... 159 9 ENVIRONMENTAL MANAGEMENT AND MONITORING ...... 160 9.1 Environmental Management for Topography ...... 160 9.2 Environmental Management for Geology ...... 160 9.3 Environmental Management for Ground Water ...... 161 9.4 Environmental management for heritage resources ...... 162 9.5 Environmental Management for Visual / aesthetic value ...... 165 9.6 Environmental Management during Underground Mining...... 165 9.7 Environmental Management for Waste Management ...... 166

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9.8 Environmental Management during Ore handling Deeps Underground, Surface Conveyors, Waste Rock Dump & Tony’s dam ...... 167 9.9 Environmental Management during Crushing ...... 168 9.10 Environmental Management during during Milling and Aeration ...... 169 9.11 Environmental Management during flotation1, thickening and filtration ...... 169 9.12 Environmental Management for Tailings ...... 170 9.13 Environmental Management during Backfill ...... 171 9.14 Environmental Management during Storage of finished products ...... 172 9.15 Environmental Management during Dispatch of products ...... 173 9.16 Envronmental Management for Waste Rock ...... 173 9.17 Environmental Management for Hydrocarbon ...... 174 10 ENVIRONMENTAL AWARENESS PLAN ...... 175 10.1 Environmental Training and communication approach ...... 175 10.1.1 Identification of training needs ...... 175 10.2 Induction ...... 175 10.2.1 Environmental Procedure Training ...... 176 10.2.2 Training material development and review ...... 176 10.2.3 Training Assessment ...... 176 10.3 Environmental Communication and Awareness ...... 177 10.4 External Environmental Awareness Courses ...... 177 11 FINANCIAL PROVISION ESTIMATION ...... 178 11.1 Quantum of Financial Provision [Regulation 54(1)] ...... 178 12 UNDERTAKING ...... 179

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LIST OF FIGURES Figure 1-1: Ore sources for Black Mountain Mine...... 2 Figure 1-2: Location of Black Mountain Mine ...... 3 Figure 1-3: Aerial photo showing Black Mountain Mine main offices ...... 4 Figure 2-1: Generalized plan and section of the Broken Hill stratiform massive sulphide ore bodies at Black Mountain Mine...... 6 Figure 2-2: Position of ground water monitoring points...... 8 Figure 2-3: Water levels in the boreholes ...... 10 Figure 2-4: Schematic drawing of different mechanisms influencing the hydrochemistry around the slimes dam area...... 12 Figure 2-5: Google Earth Aerial view of Aggeneys showing the topography of the site (note the terrain has been vertically exaggerated) ...... 21 Figure 2-6: General Soils map of the study area and surroundings (SANBI BGIS)...... 23 Figure 2-7: National vegetation map for the study area (SANBI BGIS 2013) ...... 26 Figure 2-8: Northern Cape Critical Biodiversity Areas Priority Map (SANBI BGIS 2013) ...... 27 Figure 2-9: Site pictures of BMM koppie, drainage and flats surroundings...... 29 Figure 2-10: Priority analysis of sensitive ecological areas: Red = high, Amber = medium to high; and yellow = medium ...... 30 Figure 2-11: Hydrology Map depicting hydrogeomorphic feature map (SANBI BGIS 2013) ...... 35 Figure 2-12: National Freshwater Ecological Priority Area Atlas Map (SANBI BGIS 2013) ...... 36 Figure 2-13: Key sites at Black Mountain Mine ...... 38 Figure 2-14: Deflation hollow at Zuurwater – handaxe in foreground...... 39 Figure 2-15: Rock surfaces where water collects after rains ...... 41 Figure 2-16: One of several grinding stone surfaces in the vicinity of 29.25362o S 18.80600o E ...... 41 Figure 2-17: Location of Aggeneys Goras site 1 (white arrow) ...... 42 Figure 2-18: Bedrock exposure and hollow in which water collects after rain...... 42 Figure 2-19: Grinding groove in bedrock and examples of microlithic stone tools, pottery and ostrich eggshell...... 43 Figure 2-20: Location of the goras in the Aggeneys game farm (white arrow) ...... 43 Figure 2-21: Faintly visible ‘star’ image finger painting...... 45 Figure 2-22: painted boulder with protective fence and reed roof (needs repairing)...... 45 Figure 2-23: Quartz flake and ostrich eggshell fragment from painted boulder site ...... 46 Figure 2-24: Location of the painted boulder site (white arrow) ...... 46 Figure 2-25: Aggeneys cupule site: ...... 47 Figure 2-26: Zoomed in cupule site ...... 47 Figure 2-27: Location of the cupule site (arrow) (Zuurwater cupule site: 29.23668oS 18.72809oE) ...... 48 Figure 2-28: Waterfall with cupules (indicated by arrow) ...... 49 Figure 2-29: Cupules engraved/drilled into the face of the rock...... 50 Figure 2-30: Swartberg Mine and position of the cupule site (arrow) ...... 50 Figure 2-31: Visual impact of form ...... 52 Figure 2-32: Visual impact of line ...... 53 Figure 2-33: Visual impact of texture ...... 54 Figure 2-34: Study Area and Receptor Locations ...... 56 Figure 2-35: Labour sending areas by local municipalities ...... 58 Figure 2-36: Labour sending areas by Towns within thin the Namakwa and Siyanda District ...... 59 Figure 3-1: Typical Mine Flow Diagram ...... 63 Figure 3-2: Crushing Circuit...... 63 Figure 3-3: Milling Flow Diagram ...... 64 Figure 3-4: Copper Flotation Flow Diagram...... 65 Figure 3-5: Lead Flotation Flow Diagram ...... 66 Figure 3-6: Zinc Flotation Flow Diagram ...... 66 Figure 3-7: Thickener and Filtration Flow Sheet ...... 67 Figure 3-8: Backfill Plant Layout ...... 68 Figure 3-9: The Mine Sewage System ...... 74 Figure 3-10: BMM General Waste Flow Diagram ...... 76 Figure 3-11: BMM Hazardous Waste Flow Diagram ...... 78 Figure 8-1: The black mountain HDSA/BEE spend targets (BMM SLP, 2009) ...... 159

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LIST OF TABLES

Table 2-1: Typical background hydro-chemistry in the Black Mountain area...... 9 Table 2-2: Typical hydro-chemistry in boreholes (M18 – 21, BH1 – 5, JMA1 – 4, M6, M7) in the vicinity and of the tailings dam and ageing pond area...... 13 Table 2-3: Operational rules at the Black Mountain tailings dam and return water dam used for prediction of seepage volumes...... 15 Table 2-4: Preliminary seepage volumes predicted for the tailings dam and the return water dam during the operational phase before the use of the new dams in 2010...... 15 Table 2-5: Preliminary operational phase seepage water qualities from the Black Mountain tailings dam and return water dam ...... 16 Table 2-6: Annual rainfall in Aggeneys: 1986 – 1992 ...... 18 Table 2-7: Mean, maximum and minimum monthly and annual rainfall and maximum recorded in 24 hours at Pofadder: 1993 - 1984 ...... 18 Table 2-8: Highest rainfall rates recorded and the computed 50 and 100 year maximum expected rates at Pofadder (mm) ...... 19 Table 2-9: Average temperatures and barometric pressures: 1986 – 1992 ...... 19 Table 2-10: Calculated average humidity during summer and winter ...... 19 Table 2-11: Wind data during 1975 for Aggeneys ...... 20 Table 2-12: Average daily evaporation rates at Aggeneys ...... 20 Table 2-13: Species of conservation concern for Aggeneys taken from a the Namaqua Biodiversity Plan ...... 31 Table 2-14: Fauna species of conservation concern of endangered or rare status ...... 31 Table 2-15: key species to the study area (from Birdlife South Africa, 2013) ...... 32 Table 2-16: Range and biome restricted Species of the study area (from Birdlife South Area 2013) ...... 32 Table 2-17: Catchment Characteristics of the study site ...... 34 Table 2-18: Total estimated job opportunities created by Black Mountain ...... 58 Table 3-1: Physico-chemical properties of the hydraulic backfill medium...... 69 Table 3-2: The chemical composition of reclaim water...... 69 Table 3-3: The chemical composition of the tailings...... 70 Table 3-4: Hydrocarbon register onsite ...... 75 Table 5-1: Scoring for environment impact assessment criteria...... 94 Table 5-2: Impact Significance ...... 95 Table 9-1: Environmental Management for Topography ...... 160 Table 9-2: Environmental Management for Geology ...... 160 Table 9-3: Environmental Management for Ground Water ...... 161 Table 9-4: Environmental Management for heritage resources ...... 162 Table 9-5: Environmental Management for visual/aesthetic value ...... 165 Table 9-6: Environmental Management during underground mining ...... 165 Table 9-7: Environmental Management for waste management ...... 166 Table 9-8: Environmental Management for Ore handling ...... 167 Table 9-9: Environmental Management for crushing ...... 168 Table 9-10: Environmental Management for milling and aeration ...... 169 Table 9-11: Environmental Management for flotation, thickening and filtration ...... 169 Table 9-12: Environmental Management for tailings ...... 170 Table 9-13: Environmental Management for backfill ...... 171 Table 9-14: Environmental Management for storage of finished products ...... 172 Table 9-15: Environmental Management for dispatch of products ...... 173 Table 9-16: Environmental Management for waste rock ...... 173 Table 9-17: Environmental Management for hydrocarbon ...... 174

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APPENDICES-SUPPORTING DOCUMENTS

Appendix A: Water quality audit report, February, 2001 Appendix B: Ecological Report April, 2013 Appendix C: Heritage Report Appendix D: Visual Impact Assessment Study, April 2013 Appendix E: Mine Plan Appendix F: Black Mountain Standard Operating Procedures (SOP‟s) ESOP033: Appendix G: Environmental Rehabilitation Programme for Life of Mine Phase 1. Appendix H: The Background Information Documents (BID) Appendix I: A list of I&AP identified and consulted with during the public participation process

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ABBREVIATIONS

AGIS Agricultural Geographic Information System AVCP Alien Vegetation Control Programme BEE Black Economic Empowerment CARA Conservation of Agricultural Resources Act, Act No. 43 of 1983 DSB Development Services Board DMR Department of Mineral Resources DWAF Department of Water Affairs and Forestry EC European Community ECA. Environment and Conservation Act, Act No. 73 of 1989 EDP Economic Development Plan EIA Environmental Impacts Assessment EMP1 Environmental Management Programme EMPR2 Environmental Management Programme Report GPS Geographic Positioning System HDSA Historically Disadvantaged South African I&AP Interested and Affected Parties IDP Integrated Development Plan ISO International Standards Organisation LoM Life of mine LED Local Economic Development masl meters above sea level MPRDA Minerals and Petroleum Resource Development Act, Act No. 28 of 2002 NEMA National Environmental Management Act, Act 107 of 1998 NEM: AQA. National Environmental Management: Air Quality Act, Act No. 39 of 2004 NWA. National Water Act, Act No. 36 of 1998 MWP Mining Work Programme OEL Occupational Exposure Limit QDS Quarter Degree Square OMP Overburden Management Plan ROM Run of Mine SABAP South African Bird Atlas Project SAHRA South African Heritage resource Agency SAWS South African Whether Service SANS South African National Standard SLP Social and Labour Plan SMME Small Micro and Medium Enterprise SSC Shared Service Centre TDS Total Dissolved Solids TWQR Target Water Quality Range USBM Unites States Bureau of Mines

1 Compiled in accordance with the requirements of the Minerals and Petroleum Resource Development Act, Act No. 28 of 2002. 2 Compiled in accordance with the Minerals Act, Act No. 51 of 1991.

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1 INTRODUCTION

This document constitutes the amended environmental impact assessment, which determines the significance of impacts associated with the Black Mountain Mine and the environmental management programme, which provides management measures to mitigate the significance of the impacts of the mining operation, for the Black Mountain Mine – Vedanta Resources. Royal HaskoningDHV (hereafter referred to as RHDHV) has been appointed to consolidate all the existing Black Mountain Mine (BMM) EMPRs into one over-arching document.

1.1 History and Background Information Exploration in the region of the Black Mountain Mine started in 1929 with the first shaft sunk on Swartberg – the „Black Mountain‟ of the company‟s name. Desultory investigations continued at sporadic intervals after that until 1970 when Phelps Dodge Corporation commenced a diamond-drilling programme.

In 1971 the Swartberg ore body was intersected, followed by the ore body at Noeniespoort se Kop („Broken Hill‟) in 1972 and in 1973 the Aggeneys Mountain („Big Syncline‟) ore body. The most promising of the three was at Noeniespoort and an audit was conducted in 1974 to procure bulk samples for metallurgical testing. In 1976 Phelps Dodge Corporation commissioned a feasibility study for an underground mine.

In October 1977, after a decision to seek a partner for the venture, Phelps Dodge came to an agreement with Gold Fields of South Africa Limited (GFSA) and its associates, who subscribed for a 51% interest in the Black Mountain Mineral Development Company (Proprietary) Limited. In the late nineties, GFSA decided to sell off its base metal assets, including Black Mountain. After conducting a due-diligence study, Anglo-American Corporation purchased Black Mountain and the nearby, as yet undeveloped Gamsberg zinc deposit.

Low-key exploration through the ‟90s, aimed mainly at finding extensions to the Broken Hill orebody, yielded little encouragement but the geologists were still optimistic. With the change in ownership almost certainly signalling an end to the drilling program, the Chief Geologist requested funds for one final hole to test an area further out from the previously drilled holes. This proved a turning point in the history of Black Mountain Mining, as high-grade mineralization was intersected at a depth of just over 1,000m. On 10 May 2010, Anglo American announced the sale of its Zinc portfolio to Vedanta Resources.

Four major sediment-hosted lead-zinc-copper-silver deposits: Broken Hill, Swartberg, Big Syncline and Gamsberg, occur in the Aggeneys area (See Figure 1-1). Broken Hill used to produce 1.56 million tonnes of ore per annum. Exploration drilling from surface indicated a major down-plunge extension to the Broken Hill ore body. This extension was named the Deep orebody. The Deep ore body‟s western extremity is approximately 390 m east of, and 240 m below, the current deepest level of the mine (800 m below surface). It has a known down plunge extent of 1 100 m and is open at depth. The deepest position of the ore body is 1 680 m below surface. The Deep ore body is sub-divided into five geologically distinct zones each comprising of iron formation and massive sulphide. Lead -zinc-copper-silver mineralisation occurs as fine to coarse disseminations or interbanded in the iron formations. Mineralisation in the massive sulphide is fine-grained and often brecciated. Economic ore occurs in all of the five ore body zones and is predominantly situated at or close to the footwall of each zone. The Deep ore body is contained in a synformal structure with a steep (63°-70°) and extensive southern limb. The northern limb of this structure has, so far, been poorly explored, however from existing information it seems to be refolded. Indications are that the shape and disposition of the ore body have been determined by both

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folding and thrusting. Black Mountain mine produces zinc, lead, and copper concentrate. Silver is produced as a by-product of lead and copper processing.

Figure 1-1: Ore sources for Black Mountain Mine.

1.1.1 Contact details for the mine

Name of Applicant: Black Mountain Mining (PTY) Ltd – Vedanta Resources

DME Reference No. 6/2/6/33; SCN 5/3/2/223; SNC 6/2/2/153; NCS 30/5/1/2/3/2/2/1 517 MR; NCPOF1/NAM/03/2007; ML 5/2000; ML 2/99

Contact Person (Black Mountain Mine): PD Venter

Physical Address: Black Mountain Mining (PTY) Ltd – Vedanta Resources 1 Penge Road Aggneys

Postal Address: Black Mountain Mining (PTY) Ltd – Vedanta Resources P O Box X01, Aggeneys 8893

Telephone Number: (054) 983 9345

Fax Number: (054) 983-9353

Email [email protected]

Commodity: Lead, Zinc and Copper

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1.2 Location of the Operations Black Mountain Mine is situated in Aggeneys, a small town in the Northern Cape Province (Figure 1-2). BMM is located 60km East of Pofadder and 110km West of Springbok. The map below illustrates BMM in relation to other centres and major infrastructures in the Northern Cape Province.

Figure 1-2: Location of Black Mountain Mine The BMM falls under the Kenhardt magisterial district and the Springbok regional services council authority. It is adjacent to the small village of Aggeneys located along the N14 highway between the towns of Pofadder and Springbok in the Northern Cape Province. The mine is synonymous with the settlement and is inhabited by employees of the mine (Figure 1-3).

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Figure 1-3: Aerial photo showing Black Mountain Mine main offices

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2 DESCRIPTION OF THE RECEIVING ENVIRONMENT

BMM has been operating since 1979. The description of the receiving environment describes the pre-mining environment and the current environment present on the site. The baseline description of the receiving environment has been extrapolated from the following sources (which are referenced throughout the report): The Environmental Management Programme Report compiled Groundwater Consulting Services cc, 2000. Black Mountain – A division of Anglo Operations Limited Original Environmental Management Programme Report, 1993. Environmental Management Programme for the tailings dam extension compiled by Oryx Environmental, 2007. Recent environmental auditing and monitoring results. The Visual assessment carried out by RHDHV, 2013 The Ecology assessment carried out by RHDHV, 2013 The Heritage assessment compiled by Dr David Morris, McGregor Museum, Kimberley, March 2013

2.1 Geology of the Broken Hill Deeps Project Ore Body Geology information in this section is obtained from the existing original EMPRs. The Aggeneys copper-lead-zinc-silver deposits occur in the Precambrian metavolcanic metasedimentary Bushmanland Group which forms part of the Namaqualand Metamorphic Complex. The Bushmanland Basin occupies an area measuring around 18,000km in the western half of the Namaqualand-Natal Mobile Belt.

Ore at the Black Mountain Mine is more copper-rich, in contrast to the other deposits to the east which are all more zinc-rich. This deposit comprises two superposed massive sulphide bodies namely the thicker Upper Ore Body (UOB) and a thinner Lower Ore Body (LOB) (See Figure 2-1). Both ore bodies, which also carry disseminated sulphides, are hosted in the banded iron formation. The iron formation horizons are both separated by and enveloped in northwest-dipping schist, which is overlain by a thick quartzite formation.

The UOB is comprised of three types of iron formation: magnetite quartzite, magnetite-amphibolite and barite-magnetite. Garnet-quartzite forms a halo around the UOB; it is locally enriched in copper (up to 3% copper (Cu)).

The LOB consists of baritic to quartzitic schist with disseminated sulphides which grades into magnetite- amphibolite. The footwall to the massive sulphide lenses is characterized by abundant sillimanite.

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Figure 2-1: Generalized plan and section of the Broken Hill stratiform massive sulphide ore bodies at Black Mountain Mine. The dip is to the north at 55° (fifty-five degrees) near surface and varies from almost sub horizontal to 40° in the lower western portion of the ore bodies. The contacts of the massive sulphide ore with the host rock are sharp. The ore bodies extend over a strike length of 1,600m from a surface outcrop in the west to about 800m in the east. The stratigraphy consists primarily of footwall schists, which contain little or no water. An unconsolidated weak zone 3m thick, consisting of graphite and mica rich ground, occurs in the footwall. The ore bodies and the hanging wall quartzite‟s contain water which is associated with fissures and cracks.

On a regional scale the area has been subjected to several phases of faulting and folding which has resulted in fracture zones. The surface rocks are invariably jointed and in some areas open partings are present along the east-west striking bedding planes. Much of the jointing and fracturing however extends to depths of less than 200m below surface and it appears that deep open fracturing of geohydrological significance only occurs on quartzite gneiss contacts where late stage folding and fracturing has occurred. The fractured contact zones may act as preferential flow paths for ground water. Black Mountain contains significant lead and copper mineralisation with zinc and silver, while Broken Hill, which is presently being mined, contains the highest grades of lead, zinc and silver, with lesser, although still economically important, copper.

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The entire known deposits outcrop at surface with well developed gossans up to 30m in thickness, which will not be mined due to metallurgical problems. An unknown, but probably significant, proportion of the mineralisation has been removed by erosion. Physical and chemical weathering is still occurring as evidenced by highly acidic spring water in Big Syncline, and by the name Zuurwater. The rocks form part of the Namaqualand Metamorphic Complex and are mid-Proterozoic age (1,200 – 1,600 million years (m.y.)). They are predominantly of sedimentary origin, with intrusive and minor volcanics, and have been subjected to medium to high grade metamorphism, with up to four phases of deformation, including thrusting and tight isoclinal folding.

Mineralisation is associated with, but not confined to, magnetite-rich banded iron formations. At Broken Hill, high grade ore also occurs in discrete massive sulphide bodies. The Big Syncline massif forms the northern boundary of the property, and contains a large tonnage of low-grade schist-hosted zinc/lead mineralisation in its central part.

2.2 Ground Water Information in this section was obtained from the existing EMPRs, water quality audit report, February, 2001 (Attached in Appendix A) and Geohydrological inputs for the Tailings Dam Area - Black Mountain Mine EIA.

2.2.1 Overview

Black Mountain groundwater system consists of two aquifers. An upper unconfined primary aquifer comprising of unconsolidated sand silts and clays and the lower confined secondary rock aquifer (gneiss, quartzite, schist and amphibolite), which is related to zones of secondary permeability. Groundwater quality in the primary (upper) aquifer is variable (TDS 500 – 25,000mg/l) and is generally of worse quality than the lower fractured rock aquifer.

There are no groundwater users in the immediate area of mine contaminant sources. During the EMP study (2000), it was determined that no groundwater user has been or will be affected by dewatering activities and contamination. Groundwater use is limited due to the general poor quality of groundwater and is mainly used for stock watering.

2.2.2 Depth of water table(s)

There are twenty-two (22) monitoring boreholes already in existence in the vicinity of the mine, mainly for monitoring of groundwater quality. These boreholes are numbered using M and N prefixes and have been used for groundwater quality monitoring since 1998. Not all of the available boreholes on the mine property are used for monitoring purposes, only selected boreholes are chosen based on their position from certain sources of pollution. A description of all sampling points is provided in Table 2-1. Figure 2-2 shows the monitoring points which were sampled in 2000 during the water quality audit.

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Figure 2-2: Position of ground water monitoring points.

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2.2.3 Background Groundwater Quality

The typical background groundwater quality of the area is given in Table 2-1 below. The results include all the hydro-chemistry results obtained from the mine as well as the chemistry analyses of the drilled JMA boreholes. A total of 159 (on hundred and fifty-nine) hydro-chemical samples were assessed in order to identify the background ground water hydro-chemical signature. Most of the groundwater in the area was not fit for long-term human consumption even before mining activities started. It is difficult to define the background groundwater quality as the ambient groundwater quality is naturally elevated in salts. A screening process was used to identify the typical background groundwater quality. However, as more groundwater hydro-chemistry data becomes available in future, the screening process as well as the proposed background groundwater chemistry will be refined.

Table 2-1: Typical background hydro-chemistry in the Black Mountain area.

The following observations can be made from the background hydro-chemistry data of Table 2-1:

The typical background groundwater quality was found to have Sulphate (SO4) concentrations of below 600mg/l. The samples selected also have Chlorine (Cl) values of below 1,035mg/l (milligram per litre). Although this represents most background groundwater chemistry in the area, even higher Cl values might be expected in shallow groundwater that is subjected to evaporation. The typical groundwater quality is not recommended for long term drinking water use. The average Magnesium (Mg) and Lead (Pb) concentrations are non-compliant and the average Conductivity (EC), Total dissolved solids (TDS), Calcium (Ca), Chlorine (Cl), Fluoride (F), Iron (Fe), Manganese (Mn) concentrations are marginally compliant in terms of the SANS 241:2005 Drinking Water Standard.

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Figure 2-3: Water levels in the boreholes

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2.2.4 Ground water quality around the tailings and ageing pond area

The ground water quality in the tailings dam and ageing pond is of concern. The ground water quality down-gradient of the tailings dam has a different signature to the background ground water hydro- chemistry and some samples differ slightly from other contaminated samples in the larger Black Mountain mining site.

Six (6) sampling points are situated immediately down gradient of the tailings dam/ageing pond, namely boreholes JMA-1, JMA-2, M6 and M7, as well as manholes (large diameter shallow pits) M18 to M21. All these boreholes and manholes have sulphate concentrations between 2,000mg/l to 3,000mg/l, similar to that of the tailings dam and aging pond water. Other boreholes, further away, such as JMA-3, JMA-4, N9 to N12 and BH1 to BH5 also have similar sulphate concentrations.

Figure 2-4 was created in order to show different mechanisms influencing the hydrochemistry around the slimes dam area. The typical hydrochemistry found in the monitoring points in the vicinity of the tailings dam and the ageing pond is given in Table 2-2 below:

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Figure 2-4: Schematic drawing of different mechanisms influencing the hydrochemistry around the slimes dam area

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Table 2-2: Typical hydro-chemistry in boreholes (M18 – 21, BH1 – 5, JMA1 – 4, M6, M7) in the vicinity and of the tailings dam and ageing pond area.

The following observations could be made from Table 2-2 above (water qualities of the actual tailings dam and the ageing pond obtained in the Draft Ground water Section (August 2000) of the EMPR): Widespread non-compliance in terms of the SANS 241:2005 Drinking Water Standard for most constituents is present in the aquifer in the vicinity and down-stream of the tailings dam area. The Cl in the aquifer average at 3,294mg/l and are much higher than that of the tailings dam and ageing ponds (at respectively 327mg/l and 780mg/l). The TDS is much higher at 8,834mg/l in the underlying aquifer than in the tailings dam and ageing ponds (at respectively 2,884mg/l and 5,253mg/l).

The ground water quality below the tailings dam has average SO4 concentrations of 2,970mg/l

that compare well with the SO4 concentration in the tailings dam and ageing ponds (at respectively 2097 mg/l and 1881 mg/l). As with TDS and Cl, most cations and anions are much higher in the underlying aquifer than in

the tailings dam and ageing ponds except for Ca and SO4. It is suggested that because shallow groundwater is subjected to evaporation most cations and anions increase along with Cl in

concentration. The Ca and SO4 concentrations are strongly controlled by gypsum precipitation.

It was evident that the contaminated ground water has a strong SO4 and Cl dominance. It is not possible to distinguish between the hydro-chemistry of the tailings dam monitoring boreholes and that of other contaminated groundwater samples over the mine site. No specific cation dominance is present in either the background hydro-chemistry or in the all the contaminated samples on the site.

It was also evident that SO4 and Cl show a strong positive correlation in the background groundwater.

However, in contaminated samples SO4 does not increase with increasing Cl. This is especially the case in the tailings dam monitoring samples. Almost all the tailings dam monitoring samples show Cl values higher than 6,000mg/l.

It is suggested that the groundwater in the plume emanating from below the tailings dam area is subjected to evaporation in the shallow aquifer. The Cl therefore increases in concentration; however the

SO4 concentration does not increase with Cl as it precipitates with Ca to form gypsum.

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2.2.5 Depth of water Table

At the Black Mountain mining area there are currently two (2) major impacts on the groundwater levels as described in the Draft Ground water Section (August 2000) of the EMPR: Mining has resulted in a lowered water level (relative to pre-mining conditions) in the mine working areas. The water levels measured during 1978 are representative of the pre-mining water levels of the area. The average groundwater level was ±55mbs (metres below surface). Water level measurements in 2000 indicate that the piezometric water levels in the fractured aquifer system have dropped significantly in the Broken Hill area since mining has started (most of the boreholes were found to be dry and that the aquifer system could be totally dewatered in areas. At Swartberg, present mining activities are mostly above the saturated zone and ground water levels (boreholes N1, N2, N3, M1) are at depths between 60 and 80mbs.

Artificial surface water bodies created by the mining activities have resulted in groundwater mounding and are surrounded by subsequent shallower water level depths. Groundwater levels in the boreholes near the tailings dams, maturation ponds, plant area and reed beds, are a function of the proximity of the borehole to the nearest artificially created surface water bodies. Groundwater levels are very shallow near the ponds and get progressively deeper with distance away from the ponds. The geometry of the water mounds depends on the transmissivity of the underlying alluvial aquifer. Water which percolates vertically from the ponds, reaches either the underlying bedrock or impervious clay layers in the unconsolidated alluvium. The shallow groundwater level depths measured in JMA-1 to 4 (February 2007) in the vicinity of the tailings dam compare well with the shallow water level depths measured in boreholes in June 1998 and May 2000. This proves the presence of the groundwater mound in the larger tailings dam area ever since it was monitored. The depth to the water table in the boreholes around the tailings dam ranged from 2.1m in JMA-1 (adjacent to the tailings dam) to respectively: 11.1m in N9 (1,100m south-west and down-gradient of the tailings dam in the direction of Plaatjiesvlei), 12.7m in N7 (600m west of the Tailings dam) and 12.6m in N10 (700m south-east of the Tailings dam).

2.2.6 Seepage Volumes

Black Mountain Mine appointed Golder Associates Africa (Pty) Ltd to characterize seepage from the tailings dam and the return water dam. The following section is retrieved from their technical memorandum submitted to JMA Consulting entitled: “Source term study preliminary seepage load prediction for the Black Mountain storage facility – 30 March 2007”.

The Vadose/W iterative numerical software (Krahn, 2004) was used to predict the saturated and unsaturated flow components for the operational phase of the tailings dam as a function of the operational rules, climate variation, material properties and facility geometry. The tailings dam was modelled in a two dimensional model based on a cross section through the length of the facility. The Darcian equation was used to estimate the seepage volumes from the return water dam due to the presence of a permanent water head.

At the time of the ground water study, there was no lined water return dam. Annual rainfall data for the rain gauges in close proximity to Black Mountain tailings dam was extracted from the former Computing Centre for Water Research (CCWR) data base.

A five (5) year moving average on the annual rainfall was applied to determine the 5 year wettest (194mm) and driest (16.8mm) periods to simulate the worst and best case scenarios, whereas the mean 5 year rainfall (36.8mm) period were used for the likely case. The operational rules for the Black Mountain tailings dam and return water dam that were applied in the model are summarised in Table 2-3 below:

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Table 2-3: Operational rules at the Black Mountain tailings dam and return water dam used for prediction of seepage volumes.

The predicted daily average seepage volumes (cubic metres per day (m3/day) for the tailings dam and its return water dam during the operational phase are summarized in Table 2-4 below: Table 2-4: Preliminary seepage volumes predicted for the tailings dam and the return water dam during the operational phase before the use of the new dams in 2010.

The predicted seepage rates and volumes summarized in Table 2-5 should be viewed and applied as preliminary results and the ranges demonstrate the current uncertainty in the predicted seepage volumes. The predictions were based on current readily available data as input to the model. More confidence in the predicted seepage flows could be attained by improved data on the spatial distribution of soil depth and saturated hydraulic conductivity of the underlying calcrete. Predicted seepage volumes from the tailings dam and the return water dam were calibrated in the groundwater model that will take into consideration the surrounding borehole data.

2.2.7 Seepage quality prediction

The approach followed in the simulation of likely operational seepage qualities from the Black Mountain tailings dam is provided below: Seepage volumes from the tailings dam during the operational phase are predominantly driven by saturated flow processes associated with the penstock pool. This pool acts as a permanent head of water and is therefore the main driver of seepage. Recharge processes on the beach and wall sections are driven by unsaturated flow processes which are typically order of magnitude lower compared to saturated flow processes. It is expected that the quality of seepage associated with the penstock pool will be similar to that of the penstock water. Penstock water, although in near equilibrium with the fresh tailings material, has limited interaction with air before it seeps into the tailings material or is decanted. The predominantly saturated tailings material will also undergo insignificant oxidation due to the lack of oxygen and dissolved oxidants. Tailings material on beach and wall sections will start oxidizing during periods of drying and will significantly influence the quality of pore water migrating in the tailings dam beach and wall sections. However, due to the low recharge rates and values compared to the saturated conditions, the penstock pool will have limited influence on the operational seepage qualities. In the absence of any kinetic data (Humidity cell tests) and in order to provide a range of possible operational seepage qualities, use was made of fresh tailings supernatant, penstock overflow, leach pore water samples to request a Best Case, Likely Case and Worst Case seepage quality respectively. The above qualities were evaluated for possible geochemical controls that will affect the seepage quality. The simulated qualities, although showing the effect of Acid Rock Drainage (ARD) processes, were not simulated taking account of reaction kinetics.

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The worst case seepage qualities have the highest TDS which indicates salinisation of pore water quality related to ARD processes and/or concentration by evaporation. Table 2-5 below indicates the best, likely and worst case seepage qualities expected from the Black Mountain tailings dam and return water dam. Table 2-5: Preliminary operational phase seepage water qualities from the Black Mountain tailings dam and return water dam

In Table 2-5 marginal and non-compliance in terms of the SANS 241:2005 Drinking Water Standard for predicted leachate qualities is evident for many constituents. Parameters that show non-compliance even in the most likely seepage quality are TDS, Ca, Cu, Mn, Ni, Pb, F and SO4. The possible geochemical / mineralogical constraints on the seepage qualities were evaluated by using the geochemical speciation model, PHREEQC. It is likely that gypsum (CaSO4.2H2O) is controlling the Ca and SO4 concentrations. This can be seen in the relative lower Ca concentrations in the worst case seepage quality and the relative small change in SO4 concentration. Goethite (FeOOH) and Ferrihydrate (Fe(OH)3) will be the major controlling phases of Fe in the seepage water.

2.2.8 Groundwater Use

Nearly all water used by the Black Mountain mining operation is pumped from the Orange River. Down gradient of the tailings dam no external ground water users exist. The plume down gradient (south) of the tailings dam and ageing pond will not extend beyond the aquifer boundaries and is contained within the mine boundary. 2.3 Climate The climate information for the area was obtained from the existing tailing dam EMPR. The climate of the western areas of the Republic of South Africa is controlled to a great extent by the semi-permanent high pressure systems of the south Atlantic, the easterly moving low pressure systems of the sea areas in the region of 40°S and a low pressure system situated in the northern areas of Namibia. The movements of these pressure systems during the year and the influence of the cold Benguela current along the west coast combine to produce the arid climate of the north western part of the old Cape Province.

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During the summer, the South Atlantic High moves south and similarly the low pressure over northern Namibia also moves south causing moist air to flow from the tropical regions to the eastern portions of the country, causing precipitation in the form of violent thundershowers. These conditions are compounded by the topography in the east. Because of this movement of the air mass in a south-eastern (SE) direction, the western areas of the country are considerably more arid than the eastern and northern areas.

During winter, the low pressure systems associated with the sea areas in the region of 40°S extend their influence northwards and a continuous series of frontal depressions with associated inclement weather cross the south western part of the old Cape Province.

At the same time a permanent high pressure system develops over the eastern parts of the country which tends to block the eastward progress of these frontal depressions, steering them to the SE and giving rise to the strong northerly winds over the NW of the old Cape Province. These northerly winds have a tendency, during cold fronts, to veer southerly for short periods, causing low cloud and rain, the influence of which is mainly in the southern and western areas of the Cape, but which can extend as far as Aggeneys.

Aggeneys is situated in the NW region of Bushmanland, an area which is marginal to the winter and summer rainfall zones in the NW Cape Province. Namaqualand to the west is considered to constitute a winter rainfall area while Gordonia to the east is a summer rainfall area. Aggeneys gets very little of either type of rain, resulting in desert conditions, although more rain tends to fall in the summer months. Protracted droughts are a common feature, and in the recent past, some parts of Bushmanland did not have any rain for a period of ten (10) years.

2.3.1 Mean monthly and annual rainfall

The annual rainfall varies between 50mm and 190mm, averaging just over 90mm. Table 2-6 gives the annual rainfalls for the period 1986 – 1992.

Rainfall data has been recovered over a longer period at Pofadder, which lies 60km to the East of the property and is thus more liable to get summer rain (thunderstorms). Here the average rainfall from 1933 to 1984 was 105mm, with a maximum in any one year of 278mm, as can be seen in Table 2-7, November, February, March and April are the only months where mean monthly rainfall exceeds 10mm. Zero rainfall can fall in any month and up to tenfold the mean monthly rainfall has occurred.

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Table 2-6: Annual rainfall in Aggeneys: 1986 – 1992

Table 2-7: Mean, maximum and minimum monthly and annual rainfall and maximum recorded in 24 hours at Pofadder: 1993 - 1984

Although fairly high rates of precipitation have been recorded, even the maximum annual precipitation of 278mm, recorded in 1974, is hardly enough to produce a crop of Sorghum. Occasionally, high winter rain is sufficient to propagate spring flowers.

2.3.2 Maximum rainfall intensities

There is no reliable record at Aggeneys, but it believed that only very rarely would a daily precipitation in excess of 50mm occur. Table 2-8 shows the maximum rainfall intensity recorded and to be expected in a 50 year and a 100 year period at Pofadder.

The highest recorded rate over 30 minutes exceeds the computed 100 year maximum in five of the twelve months while over 24 hours the recorded maximum falls exceed the 100 year computed maximum in seven of the twelve months. This provides a measure of the deviation of actual rainfall from statistical norms.

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Table 2-8: Highest rainfall rates recorded and the computed 50 and 100 year maximum expected rates at Pofadder (mm)

2.3.3 Mean monthly, maximum and minimum temperatures

Temperatures at the mine site range between –2°C and 45°C. The mean summer temperatures are 31.4°C maximum and 20.2°C minimum, while the mean winter temperatures are 17.6°C maximum and 10.8°C minimum. Table 2-9 indicates the recent available results. Table 2-9: Average temperatures and barometric pressures: 1986 – 1992

From the figures shown in Table 2-9, relative humidity readings for the summer and winter periods have been calculated from the average temperature and barometric pressure readings. The results are shown in Table 2-10.

Table 2-10: Calculated average humidity during summer and winter

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2.3.4 Monthly mean wind direction and speed

The prevailing wind direction is southerly in summer and northerly in winter. The least common wind direction is north-westerly, which wind would seem to precede rain in the summer months. Wind velocities of up to 110km/hr have been recorded. Wind data including velocity and direction recorded at Aggeneys during 1975 are summarized in Table 2-11. The total evaporation rate over a year is 3.5m. The variation in the monthly evaporation can be seen in Table 2-11. Table 2-11: Wind data during 1975 for Aggeneys

The total evaporation rate over a year is 3.5m. The variation in the monthly evaporation can be seen in Table 2-12 below. Table 2-12: Average daily evaporation rates at Aggeneys

Annual evaporation is more than ten times annual average rainfall. There are only very short periods when precipitation is in excess of evapo-transpiration and when soil moisture will be adequate to supply any but xeric plant water requirements.

2.3.5 Incidence of extreme weather conditions

Occasional protracted droughts. Minor hailstorms have occurred, but only very rarely.

2.4 Topography The topography of the study area was obtained from the visual study undertaken in 2013 (Appendix B).

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2.4.1 Description

The area around the mine and Aggeneys is characterised by two distinct landform types; very flat plains characterised by dunes in places and rugged low mountains that rise in distinct from the surrounding plains, due to the presence of quartzite and iron formation layers within the stratigraphy that are les prone to weathering than other rocks (Norman and Whitfield, 2006).

Due to the arid nature of the climate, the mountain ranges / hills are very rugged and are highly visually prominent creating a strong landscape-level contrast with the surrounding plains. In the vicinity of the mine and the settlement of Aggeneys, the Swartberg Mountain and the Aggeneys se Berge range that stretches off to the north-east form the visual backdrop and frame the visual envelope.

The Windhoek se Berge, Skelmberg and Hoedkop Mountains enclose the viewshed from the mine to the south-west and the Ghaamsberg Mountain rises above the plains to the east, giving the viewer located at the mine or settlement of Aggeneys the impression of being completely encircled by hills and mountains (see Figure 2-5). The altitude is between 900 and 1,200masl (metres above sea level), sloping down towards the Kalahari-basin in the northwest.

Figure 2-5: Google Earth Aerial view of Aggeneys showing the topography of the site (note the terrain has been vertically exaggerated)

2.4.2 Soil

Information on the soils of the Black Mountain area was sourced from 1: 250 000 Land Type maps supplied by the Department of Agriculture, from Ecological Report attached on Appendix C and from the existing EMPRs.

2.4.2.1 Description The land type for the area (Memoirs of the Agricultural Natural Resources of South Africa 1987, No.9) is Ag26, which covers a total of 23, 280ha of which 500ha is available for agriculture. A total of three soil forms were identified in the area including: Hutton (Hu), Mispah (Ms) and Dundee (Du) which is less significant. The Hutton Form, 200 – 800mm in depth, is the most prevalent, occupying 85% of the area

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and dominates the lower part of the slopes and valleys; while Mispah, 50 – 100mm in depth, dominates the upper parts of the slopes.

These soils can be described as red, excessively drained sandy soils with high base status, on bedrock with presence of lime (Figure 2-6). The climatic conditions do not allow any large scale crop farming, but the experience in the village of Aggeneys would appear to indicate that there is an irrigation potential, although the high evaporation rates at certain periods of the year mean that the roots of many mesic plants are not be able to supply water to aerial parts fast enough to prevent wilting.

In terms of the Chamber of Mines Classification of Land capability (1981), the relief and mountainous areas can be classified as mainly “Wilderness Land”. Grass cover is extremely sparse in these areas due to the very rocky nature of the soil, its shallowness and the arid climate. A large component of the vegetation in the rocky/mountainous areas comprises inedible Euphorbia sp. The plain areas of the property should also be considered as “Wilderness Land” but had been used for grazing prior to the mien being established. The unsuitability of the land for this use resulted in heavy over-grazing. At the time when the mine started, the land was extremely dry and had been heavily overgrazed, resulting in very sparse vegetation as is explained in the next section.

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Figure 2-6: General Soils map of the study area and surroundings (SANBI BGIS)

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2.5 Land use

2.5.1 Pre-mining land use

Bushmanland was declared a game reserve in 1892, but, due to problems in controlling the area, was deproclaimed in 1920, when open grazing by sheep was permitted. This changed the whole nature of the veld, converting the once impressive grassveld into tractable brackish veld. (This had been the only true grassveld as it had sustained itself and did not have to rely on fire for this purpose). Previously, indigenous herbivores had roamed around a large unrestricted area, following patches of good vegetation. This meant that zones which had not had sufficient rain were left alone and were able to recover. With the introduction of farming, fencing was erected and thus areas were thereafter continuously grazed, irrespective of their condition. Sheep are selective grazers, finding only certain of the available plants palatable. Continuous grazing of these palatable species suppressed flowering, severely reducing contributions to the seedbank. The position was exacerbated by over-stocking.

2.5.2 Historical agricultural production

On surrounding farms, the stock density is currently eight (8) hectares per sheep. In years of poor rainfall even this low a density can be considered to be overpopulated.

2.5.3 Evidence of misuse

Of the three main land types in Bushmanland, mountain, gravel plain and dune, the latter two types were most affected by overgrazing. While the gravel plain type shows some ability to recover from a distortion of plant types, the effects of farming of the dune regions is to convert dune grasslands to shrub lands and stable to unstable dunes. This is because a diminution of palatable shallow rooted dune grasses causes the dunes to lose their cohesion and thus move. The movement of the dunes often destroys the bushes as well, causing complete desertification. In certain areas, cattle were introduced and the weight of their hooves further broke up the dune surfaces. Attempts to cultivate the fragile soil also caused immense damage. The importance of the top few centimetres of the soil in this sort of environment cannot be over- stressed, since it is the shallow rooted plants that hold the dune system in balance. Currently, less than 0.01% of the Arid Karoo is conserved by the State, while the only conserved part of the Koa Valley dune system is the private reserve on the Aggeneys property.

2.5.4 Existing structures

Prior to the commencement of prospecting, only the Aggeneys farmhouses were present on the property. When exploration activities commenced in 1970, a temporary camp was established near Black Mountain. As the present Aggeneys Township became established, the temporary camp was phased out.

2.6 Natural vegetation / plant life Information for this section is taken from the existing EMPRs and the ecological assessment undertaken in 2013 (See Appendix B).

Description At the time the mine commenced, this was a dry, desolate area with little or no vegetation due to a prolonged drought and overgrazing. Since then, the situation has changed dramatically. The natural vegetation has not only recovered on the mine property but is also fast recovering outside the mine‟s boundaries due to the re-creation of a natural seed bank. The dominant vegetation types classified for the area are Bushmanland Sandy Grassland, Bushmanland Inselberg Shrubland; and Aggeneys Gravel Vygieveld (Figure 2-7). The general Vegetation types can be described as follows:

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Found onsite on the plains forming part of the Nama-Karoo Biome and Bushmanland Bioregion: Bushmanland Arid Grassland and Bushmanland Sandy Grassland. Found onsite around hill outcropping forming part of the Succulent Karoo Biome and Richtersveld Bioregion: Aggeneys Gravel Vygieveld on the hillslope of the koppies; and isolated pockets of Bushmanland Inselberg Shrubland on koppies. All vegetation types found onsite have conservation status of least threatened (Figure 2-9 and Figure 2- 10). However, protected tree Acacia erioloba (Camel Thorn) is known to have a distribution range in the area and provides some conservation concern in terms of protected species.

The significance of the vegetation and ecology of the study site relates strongly to the alpha, beta and gamma diversity of the area where species turnover, over space can be regarded as high for biodiversity as well as available habitat (sandy soils and rocky soils over plains and over mountain hills). This is very important when considering the conservation implications for conservation planning. The fine-scale priority atlas for the region has identified the area to contain significant priority areas for ecological corridor management, of which the northern and north-western extents of the study site form part of a priority corridor (Figure 2-11).

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Figure 2-7: National vegetation map for the study area (SANBI BGIS 2013)

* Vegetation types: light pink=Bushmanland Sandy Grassland; dark pink=Bushmanland Arid Grassland; light gold=Bushmanland Inselberg Shrubland; and light gold= Aggeneys Gravel Vygieveld

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Figure 2-8: Northern Cape Critical Biodiversity Areas Priority Map (SANBI BGIS 2013)

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No significant fauna was found during the ecological assessment in 2013, but based on ecological processes and refugia availability; associated habitat fauna identified in the previous EMPRs should remain prevalent and relevant.

During the assessment, it was evident that although landscape was dominated by exposed soils, gravel or sands, the study area was very rich in biodiversity on all koppies as habitat availability, soil compositional change over space provided adequate support for high floral diversity and associated faunal refugia. However, the site drainage from koppies are largely affected by the harsh climate conditions persisting in the area with dry hot weather diminishing any potential surface seepage contributions when looking at the koppies from a watershed perspective. As a result, no real riparian ecology can be associated with these drainage lines except for where drainage depressions join the baseflow of the sub-surface drainage contributions from surrounding stormwater contributions. However, a high number of erosion based drainage lines are present throughout the landscape, which indicates ephemeral streams functioning during high precipitation intervals. In contrast to the koppies of the study area, the often sandy and/or stone-gravel based flats and general surrounding area has a very cosmopolitan habitat and species composition where very little biota resides besides the hardy scrub flora of the region and burrow based fauna (with the exception of avi-fauna which uses this terrain for foraging on rodents and reptiles). Evidence of buck (buck droppings) and baboons were noted.

Vegetation types delineated in the desktop screening assessment was found to be predominantly true, with the exception of the surrounding plains being compromised of mesic Bushman Grassland and not separated grassland vegetation types. All koppies, natural drainage lines and surrounding flats were comprised an estimated 90% natural vegetation of which 5% can be considered degraded and 5% transformed. In terms of vegetation community structure, the following applies (Figure 2-11):

On Koppies The vegetation community structures for the koppies are comprised of a dominant Aloe pillansii succulent tree species and Euphorbia dregeana ecotone species with Lycium ferocissimum being the dominant woody shrub. Aridaria noctiflora was found to be dominant on the footslopes which completes the canopy. The understory is comprised of scrub vegetation and an additional Aloe (Aloe claviflora) with Crassula spp., Cotyledon orbiculata residing amongst dwarf “vygie” succulents (no flowers) and Aristida spp. and Stipagrostis spp. grass compositional species.

On River Beds The natural drainage lines were dominated by surrounding flats terrestrial scrub Rhigozum trichotomum, with Juncus spp., Salix mucronata and Prosopis glandulosa residing in baseflow pools where surface water become exposed. In artificially modified drainage lines, which contain mine effluent and most stormwater contributions, the overgrowth of Phragmites australis was evident.

On Flats The general surroundings of the study area is comprised of low undulating flats, with canopy species Rhigozum trichotomum, Eriocephalus microphyllus and Galenia fruticosa dominant throughout the landscape with tufts of Stipagrotis spp. grasses evident in the landscape. Where flats eroded bedrock, the vegetation has some Euphorbia karroensi and Crassula spp.

On Transformed Flats The transformed flats are areas which have been used for mining activities, as well as settlement service uses and are predominantly comprised of cosmopolitan weedy grass Pennisetum spp. and Stenotaphrum secundatum and alien shrub species such as Atriplex semibaccata, Gomphocarphus fruiticosus (previously known as Aclepias fruiticosus) as well as the very problematic alien Prosopis glandulosa. Garden escapees are not a serious problem in the area, but will need to be monitored. These included all ornamentals used at households and for general greening uses.

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Rare and endemic species identified to reside in the BMM vicinity relates strongly to inconspicuous dwarf succulents, forbes, grasses and general underground found on the geologies of the areas prominent koppies of the area (Inselbergs) (Error! Reference source not found.). In fact, species turnover found onsite between koppies can be regarded as remarkable over space where population groupings and ecotone species have similar community structure in terms of species structural or family groupings, but with different species composition. In other words, where community structure was dominated by Aloe tree species on the one koppie, becomes Euphobia species on the following koppie, with a different dominant Aloe shrub species. However, no rare or endemics from Table 2-11 have been found onsite during the site assessment visit conducted.

Figure 2-9: Site pictures of BMM koppie, drainage and flats surroundings.

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Figure 2-10: Priority analysis of sensitive ecological areas: Red = high, Amber = medium to high; and yellow = medium

* Arrow indicates the identified conservation priority corridor from the Northern Cape Fine Scale Plan. **Red and amber polygons indicate High ecological areas having high biodiversity and/or high connectivity ***Light blue line indicate human induced drainage and dark blue line represents natural ephemeral drainage lines

2.6.1 Priority and Sensitivity Analysis

The assessment also provided a platform to check identified ecological sensitivities and priorities provided in the screening assessment. From the site visit undertaken, it can be confirmed that ecological important areas identified in the Northern Cape conservation plan is accurate and that identified critical biodiversity and ecological support areas are accurate. Two (2) Critical Biodiversity Areas (CBA) Class 1s were found in the area, with the koppie in the town of Aggeneys having a medium to high biodiversity composition and the koppie north-west of Aggeneys having a very high biodiversity. The relation of the areas biodiversity hotspots and its identified Ecological Support Area (ESA) forms a corridor to the south of Aggeneys, but doesn‟t relate strongly to the ecology of the surrounding flats very cosmopolitan mesic Bushmanland Sandy / Arid Grassland. These biodiversity hotspots found on the areas koppies may be better protected using drainage line corridors as a basis for ecological support areas (3).

According to Marsh et al (2009), a total of 854 plant species have been recorded in the Khai Ma Local Municipality area, of which the town of Aggeneys resides in. Forty-one (41) species are known as endemic to the area and an additional twenty (20) may be considered to be endemic as well. As previously stated, the primary type of endemism found in the area relates to species found within the fine grained quartz patches and which is typically dwarf succulents.

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Table 2-13: Species of conservation concern for Aggeneys taken from a the Namaqua Biodiversity Plan

Data source: (Marsh et al 2009) 2.7 Fauna Information in this section cannot be taken as definitive as there is a lack of faunal knowledge in the area, particularly as concerns insects of other invertebrates. Birds are well documented, and some work has been done on mammals and these are listed on Table 2-14 below.

2.7.1 Commonly occurring species

Table 2-14: Fauna species of conservation concern of endangered or rare status

2.7.2 Avifaunal Priorities

From the Important Bird Areas Directory (IBA Directory 1998) the study area of Black Mountain is well known for its importance to bird life (Birdlife South Africa 2013). The Black Mountain area is recognised as a protection site of both global and local significance, as habitat or biome range restricted bird species reside in the unique habitats of the area. In addition, key and threatend species are known to reside in the

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area such as the globally threatened Red Lark Certhilauda burra, which inhabits the red sand dunes, and the near-threatened Sclater's Lark Spizocorys sclateri, which occurs erratically on the barren stony plains. Furthermore, this site also holds 16 of the 23 Namib-Karoo biome-restricted assemblage species and a host of other arid-zone birds (2-15 and 2-16). Table 2-15: key species to the study area (from Birdlife South Africa, 2013)

Threatened Species

Name Breeding Total Numbers Pairs

Globally Threatened

Red Lark 700-900 1 500 - 2 000

Ground Woodpecker 50 - 100

Sclater's Lark 0 - 500

Regionally Threatened

Kori Bustard 10-Feb

Ludwig's Bustard 20-May

Table 2-16: Range and biome restricted Species of the study area (from Birdlife South Area 2013)

Name Status

Ludwig's Bustard Common

Karoo Korhaan Common

Karoo Long-billed Lark Common

Red Lark Fairly Common

Sclater's Lark Uncommon

Stark's Lark Uncommon

Black-eared Sparrow-lark Fairly Common

Tractrach Chat Fairly common

Sickle-winged Chat Fairly Common

Karoo Chat Common

Layard's Titbabbler Common

Karoo Eremomela Common

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Cinnamon-breasted Warbler Common

Namaqua Warbler Uncommon

Pale-winged Starling Fairly Common

Sociable Weaver Common

Black-headed Canary Fairly Common

2.7.3 Drainage Context

The study area falls within the Lower Orange River Water Management Area (WMA), Quaternary Catchment D82C (Table 2-17). The Orange River, about 40km to the north, does not have any significant tributary rivers associated with the study site. However, the study areas does reside in the Orange Rivers Tertiary Catchment‟s and the northern extents of BMM‟s mountain features forms a watershed for secondary streams which can be considered to be tributaries of the Orange River (indirectly connected to the Orange River tributaries). In terms of wetland features, the study sites drainage features can all be regarded as wetland in nature as a result of the general ephemeral nature of site drainage. In terms of classification, the study site is known to have both natural and artificial wetland depression on the valley floor and along watershed slopes ( Figure 2-11). In general, these drainage features are erratic, and characteristic of very dry areas where soil structures are relict and not conducive to the formation of riparian soils. However, on the extreme rainfall periods (significant rainfall events) these ephemeral features can becomes significant rivers or wetlands where storm water drainage lines are active for a short period of time (minutes or hours of flow in general and in the extreme rainfall event these features flow for a couple of days).

In terms of the importance and conservation value of these onsite drainage features, the National Freshwater Ecosystem Priority Area atlas identifies the quaternary as important in the northern and north- western extents of the site ( Figure 2-12). In terms of the Present Ecological State of the drainage tributaries within the general vicinity of the study area, a general natural to good class is given to all ephemeral and seasonal streams as a result of its uniqueness and the inability at present for DWA or SANBI to qualify its actual PES (No methods available due to the difficulty of providing reference conditions to these type of hydro geomorphic features). In general the Lower Orange River catchment in the study area is regarded to have a PES of B (good class) and is considered essential for conservation but not very important in terms of its irreplaceability and sensitivity (Status is not threatened).

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Table 2-17: Catchment Characteristics of the study site

Attribute Value

Catchment D82C

L1_ECOREGN 26

L2_ECOREGN 26_2

FLOW E

GEOZONE F

GZLUMP F

RIVTYPE 26_N_F

CLASS Dry

PES1999 CLASS B: LARGELY NATURAL

SURFACE Karoo

RIVCON AB

FFRID 0

FFRFLAGSHP 0

FEPACODE 0

CAT104060 Not threatened

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Figure 2-11: Hydrology Map depicting hydrogeomorphic feature map (SANBI BGIS 2013)

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Figure 2-12: National Freshwater Ecological Priority Area Atlas Map (SANBI BGIS 2013)

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2.7.4 Surface water quality

Any surface water would be present for very short periods during rainstorms and would thus be normal rainwater.

2.8 Air quality The main sources of dust in the area are the quarry and dust roads. There is no smelter on site. The existing tailings dam does not appear to be a major source of dust as evidenced by the lack of fallout adjacent to it. This may be as a result of the nature of the tailings material which appears to cake after deposition and is not easily mobilised by wind. Most of the large area owned by the mine is unused, which means that potential impact points within 3km of the working sites, i.e. plant, mine, sand quarry etc, have been assessed. There are no major atmospheric pollution sources in the vicinity of the property. The main Springbok/Pofadder road, the town of Aggeneys and the Eskom sub-station all fall within the mine boundaries but are greater than 3km from any activities that generate dust. No atmospheric pollution from sources outside the property is evident.

2.9 Noise The noise levels at Black Mountain were obtained from the existing EMPRs. Pre-mining noise was negligible. Noise produced by current operations is limited to noise emanating from the plant, traffic noise; various loading and trucking operations and occasional blasting in the aggregate quarry. The effect of this industrial noise on the Aggeneys Township, or any other dwelling place in the region, is negligible.

2.10 Sites of Archaeological and Cultural interest The information on this section was obtained from heritage assessment carried out in 2013 (Appendix C).

2.10.1 Overview

The archaeology of the Northern Cape is rich and varied, covering long spans of human history. Concerning Stone Age sites here, C.G. Sampson observed: “It is a great and spectacular history when compared to any other place in the world” (Sampson 1985). Some areas are richer than others, and not all sites are equally significant.

Known sites (See Figure 16) on Black Mountain Mining property provide local glimpses of this broad sweep of human history, from Earlier Stone Age times to the recent past.

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Figure 2-13: Key sites at Black Mountain Mine

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2.10.2 Earlier and Middle Stone Age sites

Isolated artefacts of Pleistocene age including handaxes have been documented at a few surface locales. It is possible that more substantial sites may yet be found.

In one example a single quartz biface (ESA) was found in a deflation area at 29.33123oS 18.74606oE. No other artefacts or notable features were found in association with it. Such completely isolated single- artefact finds could not be considered as constituting “sites” in a conventional archaeological or heritage sense.

Figure 2-14: Deflation hollow at Zuurwater – handaxe in foreground. In the wider vicinity of Aggeneys, ESA material has been found in the Gamsberg basin at GI 4 and 5. These are amongst the very few known Acheuland sites in Bushmanland.

Beaumont et al. (1995:240-1) note a widespread low density stone artefact scatter of Pleistocene age across areas of Bushmanland to the south east, where raw materials mainly quartzite cobbles, were derived from the Dwyka till. Systematic collections of this material made at Olyvenkolk, south west of Kenhardt and Maans Pannen, east of Gamoep, could be separated out by abrasion state into a fresh component of MSA with prepared cores, blades and points, and a large aggregate of moderately to heavily weathered ESA. The latter included Victoria West cores on dolerite, long blades, and, a very low incidence of handaxes and cleavers. The Middle (and perhaps in some instances Lower) Pleistocene occupation of the region that these artefacts reflect must have occurred at times when the environment was more hospitable than today. This is suggested by the known greater reliance of people in Acheulean times on quite restricted ecological ranges, with proximity to water being a recurrent factor in the distribution of sites. This must have been the case at Gamsberg, where clearly another draw-card, and undoubtedly the raison d’être for Sites GI 4 and 5, was the availability of suitable raw material for stone tool manufacture.

The artefacts found at these two Gamsberg sites include handaxes and Victoria West cores. The distribution of the rather specialised Victoria West technique of tool production in the Acheulean is known to be relatively restricted to the Karoo, western Free State, the old Transvaal area, and, part of the Northern Cape Province – in short, a certain geographical spread within the interior of the subcontinent (Sampson 1974, Volman 1984). The method is not in evidence in the southern Cape; nor is it found north of the Limpopo. However, writing in the early 1970s, Sampson noted that “nothing is yet known of the (Acheulean) typology of the western and eastern regions of the subcontinent”(Sampson 1974:121), the western-most known occurrence of Victoria West then being the vast site of Nakop near the Namibian border (Brain & Mason 1955;Sampson 1974). The evidence from Gamsberg has the potential to shed important light on this question, and for now at least extends the known distribution of the Victoria West technique yet further westwards.

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2.10.3 Middle Stone Age sites

Isolated artefacts of Pleistocene age probably attributable to the Middle Stone Age (MSA) have been documented at a few surface locales on BMM property. While Beaumont et al. (1995:241) find that “substantial MSA sites are uncommon in Bushmanland,” it is possible that some bigger sites may yet be found, such as the MSA workshop site, identified as Site GI 1, at the top of the northern rim of the Gamsberg inselberg. This is a regionally exceptional feature. It appears that the site was focused on a form of raw material, gossan, apparently favoured locally in MSA times. The surrounding plains are strewn predominantly with gneiss and ubiquitous small surface nodules of quartz. In such an environment, something of a premium must have been placed in those rocks with good or suitable flaking qualities, and this no doubt accounts for the extensive use of this localised Gamsberg source. Artefacts from here were carried away at least as far as the Gamsberg basin and the eastern plateau, and regional surveys may well show a wider distribution.

The significance of the site can be gauged in part from the known distribution of MSA sites at a regional scale, Beaumont et al. having shown that “substantial MSA sites are uncommon” (1995:241): with those that have been documented thus far generally yielding only small samples (Morris & Beaumont 1991; Smith 1995).

It has been suggested that “the relatively few [sites] that have been discovered [in Bushmanland] appear to be largely confined to the MSA3 or late MSA1 phases of that technocomplex” (Beaumont et al. 1995:241). Volman‟s (1984) scheme places the MSA1 in Marine Isotope Stage 6 (cold with warm oscillations, ending at 128 ka BP), the MSA3 in Stage 5a-3 (late Last Interglacial through Last Glacial, cold with warm oscillations, c. 82-32 ka BP).

2.10.4 Later Stone Age Sites

The records of the early travellers are of value for interpreting the final Later Stone Age (LSA) traces in the area. Late Holocene LSA sites are the predominant archaeological signature noted in surveys carried out in the Aggeneys-Pofadder region.

Known sites in the vicinity (including those documented at Aggeneys and Black Mountain and at places around Gamsberg and further afield) are dominated by quartz as raw material, but they also invariably have lithics made from exotic fine-grained river pebbles. Moreover, fragments of ostrich eggshell from broken water flasks are usually present. Most of the known LSA sites in the region also have pottery. The distribution of sites in the area show that late LSA inhabitants of the area preferentially occupied specific parts of the landscape, namely dune areas and alongside certain features including outcrops of bedrock or dry watercourses where water collects and might remain for a time in hollows after rains. Some of these sites have grinding grooves; and they all have stone artefacts, fine grit-tempered pottery and ostrich eggshell fragments. Another common feature of the sites is colonial era glass and porcelain, representing either interaction by LSA people with colonial farmers or the so-called Bastaards, or use of the sites by these frontiersmen themselves later one, or both. It is known that white farmers until as late as the 1930s practised transhumance, utilising the seasonal water sources known as Gorras.

Situated at the eastern end of the hill where the Aggregate Quarry is, gently sloping bedrock bears numerous grinding surfaces near to hollows where water collects after rains (goras). Other similar sites are known in the area north-west of Gamsberg and on the neighbouring farm of Bloemhoek (Morris 2010, in prep.).

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Figure 2-15: Rock surfaces where water collects after rains

Figure 2-16: One of several grinding stone surfaces in the vicinity of 29.25362o S 18.80600o E

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Figure 2-17: Location of Aggeneys Goras site 1 (white arrow) Aggeneys Goras Site 2: 29.33326oS 18.87979oE This and a cluster of similar nearby sites on the farm Bloemhoek is situated on the plain south of the band of dunes that define the Koa Valley east of Aggeneys. It consists of an exposure of bedrock where Goras (water hollows) have formed, and is surrounded by surface scatters of Later Stone Age stone tools, pottery and ostrich eggshell fragments. There are also bits of broken frontier / historical era ceramics / porcelain and glass, reflecting either interaction and exchange of material culture, or later occupation of these sites by colonial stock farmers (who were reliant on temporary water supplies such as these places afford prior to the advent of bore hole drilling in the early twentieth century).

Figure 2-18: Bedrock exposure and hollow in which water collects after rain.

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Figure 2-19: Grinding groove in bedrock and examples of microlithic stone tools, pottery and ostrich eggshell.

Figure 2-20: Location of the goras in the Aggeneys game farm (white arrow) Beaumont et al. (1995) have shown, with reference to the LSA, that “virtually all the Bushmanland sites so far located appear to be ephemeral occupations by small groups in the hinterland on both sides of the [Orange] river” (1995:263). This was in sharp contrast to the substantial herder encampments along the Orange River floodplain itself, which reflected the “much higher productivity and carrying capacity of these

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bottom lands.” “Given choice,” they add, “the optimal exploitation zone for foragers would have been the Orange River.” The advent of herders in the Orange River Basin, Beaumont et al. argue, led to competition over resources and ultimately to marginalisation of hunter-gatherers, some of whom then occupied Bushmanland, probably mainly in the last millennium, and focused their foraging activities on the limited number of water sources in the region. “Surveys of large areas away from [such water sources] have failed to yield any signs of human occupation, except around the granite inselsberg extruding above the peneplain, ... the red dunes which produced clean sand for sleeping, or around the seasonal pans” (Beaumont el al. 1995: 264). It is clear that, possibly following good rains, herders themselves moved into the hinterland. A further process attested by Thompson (1824) for herder groups settled at the stronger springs such as Pella, is that such groups will have dispersed during periods of drought. At such times competition between groups over resources, and stress within already marginalised hunter-gatherer society, must have intensified.

The „Bushmen‟ ultimately exterminated at sites such as Gamsberg would have been probably the last stone tool makers and the last representatives of the Later Stone Age in this part of South Africa.

2.10.5 Rock art sites

Some of the most significant sites on BMM properties are rock art sites with those already recorded being a finger painting site near the Aggregate Quarry and two sites with cupules on Zuurwater (on the south side of Swartberg) and at the southern-most edge of the farm Aggeneys.

2.10.6 Painted boulder site near Aggregate Quarry

A report by Deacon (1995) describes rock paintings found on a boulder next to the Aggregate Quarry at Black Mountain Mine, Aggeneys (29.25644oS 18.80339oE). These are simple finger paintings including two “Star” motifs and an indented oval shaped image. Paintings similar to these are to be found over a wide area in the western half of the interior of South Africa, not infrequently on isolated boulders in the Karoo (sometimes along with rock engravings), and in rock shelters. Their age and context is not well understood, but they appear to be associated in this region with KhoeSan (and possibly Khoekhoe specifically) of approximately the last millennium, rather than with other groups regarded as the makers of finger paintings elsewhere in the subcontinent.

Archaeological traces on the floor of the shelter formed by this boulder, namely pieces of ostrich eggshell and flaked quartz, were recorded by Morris in 2011.

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Figure 2-21: Faintly visible ‘star’ image finger painting.

Figure 2-22: painted boulder with protective fence and reed roof (needs repairing).

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Figure 2-23: Quartz flake and ostrich eggshell fragment from painted boulder site

Figure 2-24: Location of the painted boulder site (white arrow)

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The painted boulder site is highly vulnerable in terms of its location near the edge of the Aggregate Quarry and hence there are critical management needs. A reed roof constructed to shield the paintings from direct sunlight also requires to be repaired. Aggeneys cupule site is situated at the southern end of the game camp on the farm Aggeneys. It consists of a large boulder with a north-west facing concave surface making a small shelter, the wall of which is covered by cupules up to 1.5 cm in diameter.

Figure 2-25: Aggeneys cupule site:

Figure 2-26: Zoomed in cupule site

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Adjacent to the site is an extensive moderately dense surface scatter of Later Stone Age material including stone artefacts, pottery and ostrich eggshell pieces. It seems likely but not certain that these artefacts provide a context for the cupules. A few hundred metres away are possible isolated graves.

Figure 2-27: Location of the cupule site (arrow) (Zuurwater cupule site: 29.23668oS 18.72809oE)

The cupule site is situated on the south side of Swartberg, a few hundred metres downslope from the mining operation. A drainage line plunges over a waterfall feature and creates a (usually dry) pool at the base of the cliff. On a rock to one side of the pool a vertical face of about 2 x 1.5m is festooned with engraved cupules like the ones at the Aggeneys cupule site.

Similar cupules, in addition to the above Aggeneys site, were recently identified further west near Kangnas. Their context is uncertain. No stone artefacts or pottery were noted in the vicinity, but three lower grindstones with grinding grooves were found nearly.

This site is of high significance. Debris coming down the mountainside from the Swartberg mine would need to be managed in such a way that it does not encroach on this site.

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Figure 2-28: Waterfall with cupules (indicated by arrow)

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Figure 2-29: Cupules engraved/drilled into the face of the rock

Figure 2-30: Swartberg Mine and position of the cupule site (arrow) Gamsberg In his book, The Bushman, Dunn recalled “near N’Ghaums [Gams], I saw an engraving of a hippopotamus being dragged across the dry veldt by several Bushman people by means of a rope attached to its nose” (1931: 46). Dunn offers an explanation suggesting that the hippopotamus, associated with water, was shown in this way on the engraving in order that “rain would necessarily follow ... and an abundance of food be assured”. Current understandings of Later Stone Age rock art suggest

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that images of large mammals such as the hippopotamus may well have served as metaphors for “rain animals”. Dunn‟s hippo engraving has not as yet been located.

2.10.7 Cemeteries and graves

Towns as well as farms in the area contain grave yards including designated urban cemeteries and often small burial grounds on farms. There are also indications of isolated graves, some of which were found in the vicinity of Gamsberg. 2.11 Visual Aspects The information on this section was obtained from visual assessment carried out in 2013 (Appendix D).

2.11.1 Study Area Visual baseline

The study area visual baseline can be described in terms of a number of landscape structural elements that allow for a better understanding of the visual environment of the area. The elements are:

Form Line Colour Texture This approach is adapted from the (US Dept. of the Interior) Bureau of Land Management‟s Visual Contrast Rating Methodology. The descriptions of these elements below are made in the context of the tailings dam and the surrounding landscape.

Form There is a basic distinction in terms of the landform as apparent in views of the tailings dam from the south and east (directions of view from receptor locations); the flat foreground (plains) of the view contrasts strongly with the complex background, with a number of hills visible against the horizon. The tailings dam is set against this background and importantly is „dwarfed‟ by the larger hills in the background (especially when viewed from the south), thus being less visually prominent than the background hills, to which the viewer‟s attention is naturally drawn (See Figure 2-31).

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Figure 2-31: Visual impact of form Line Lines in the landscape are complex due to the presence of different landscape features. The foreground plains provide a horizontal line element, especially in terms of the point at which the lines plains meet the background hills (a visual focal point). The background hills provide a more complex line element with diagonal lines of the edges of hills, accentuated by outcrop lines within the hills. Nonetheless the interface between the hills and the horizon is strongly horizontal due to the flat topped nature of many of the hills. Infrastructural features (telephone lines) introduce a vertical line element and the Aggeneys road provides a distinct band in the foreground. The tailings dam is characterised by simple horizontal (the top) and diagonal (sides) lines, that assimilate easily with the surrounding hills (see Figure 2-32).

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Figure 2-32: Visual impact of line

Colour There is a contrast between the blanched yellow / orange plains and grey scrub vegetation in the foreground, and the slightly darker grey hills in the background. The tailings dam is brown in colour, which is similar to the colouration of the background hills. There is a small element of green in the middle of the view (Prosopis trees and trees around the golf course) which provides a strong, but visually non- prominent element. The arid climate entails that the blue of the sky is an almost permanent feature of the landscape, providing a strong contrast and accentuating the horizon as a visual focal point in the landscape (see Figure 2-33).

Texture The foreground has a fine texture (Figure 2-33) due to the vegetation on the plains. The background hills have a rougher texture, especially where outcrop lines and exfoliation domes are visible

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Figure 2-33: Visual impact of texture

2.11.2 Study area visual character and VAC

The above structural components of the landscape influence the visual character of the study area. The nature of the predominant landuse (livestock farming) and the relatively low level of change to the natural vegetation and landscape that this landuse has resulted in (apart from the introduction of typical rural infrastructure to the landscape such as fencing, feedlots and windmills) entails that the wider study area displays a largely natural visual character.

A natural character is characterised by a very low level of transformation of the natural landscape, with the limited introduction of infrastructure and structural changes to landscape features such as vegetation. However the presence of the Black Mountain Mine complex and associated infrastructure has introduced an industrial element to the study area. Although the visual influence of the Black Mountain Mine is not pervasive over the wider area due to the limited viewshed of the mine due to the presence of mountains around it that restrict its viewshed, the mine brings an industrial component to its immediate surroundings. The study area‟s visual character can thus be described as being rural with a strong industrial component.

This has an important bearing on the visual absorption capacity (VAC) of the study area. Visual absorption capacity can be described as the ability of a certain area / landscape to accept a new development or structures. This is largely based on the presence of existing infrastructure within the landscape; in a setting in which there is no or very little human presence, the VAC of the landscape / area could typically be termed as low – i.e. a new development would be incongruent with the setting and potentially visually intrusive. Conversely in a setting in which there is a high degree of development and existing infrastructure, a new development would be able to be easily incorporated into the landscape without creating a significant degree of visual intrusion and as such the VAC would be high.

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In the context of the study area, any planned activities relating to the expansion of the mining activities would occur in a context in which the mining infrastructure already occurs, thus the immediate area around the mine would have a high visual absorption capacity, as the area is already associated with mining infrastructure and a certain degree of transformation of the natural environment. The expansion to the mine would be unlikely to be seen as incongruent in this context.

2.11.3 Presence of Receptor Locations and Visual Sensitivity of the Area

Visual Impact is related to the presence of human receptors / viewers, thus visual impact is typically experienced from locations inhabited by humans. Accordingly an understanding of the areas inhabited / occupied by humans (even transiently) is important in the classification of potential visual impacts. As described above, there is a very low density of human settlement in the wider area due to its aridity and the nature of land use.

Although small, the settlement of Aggeneys is the most important receptor location as it represents the only cluster of human settlement and recreational activity for quite a distance. Much of the area around the mine itself is owned by the mining company and as such is access restricted, and thus there is no public access into this area. This includes the area to the north of the mine and an area to the south of the N14 highway.

Aggeneys is the only static receptor location within a 5km radius of the mine and tailings dam, and are located right at the edge of this 5km radius. Within a 10km radius of the tailings dam the only other static location is the Suurwater farmstead, located right on the edge of the 10km radius. The N14 highway traverses the area to the south of the mine, and could be considered a receptor location.

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Figure 2-34: Study Area and Receptor Locations

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A distinction can be made between receptor locations and sensitive receptor locations. Sensitive Receptors would be receptors which would potentially be adversely impacted by a proposed development, i.e. from which people viewing a development would view it negatively. This takes into account a subjective factor on behalf of the viewer – i.e. whether the viewer would consider the impact as a negative impact. In the context of visual impact, the adverse impact is often associated with the alteration of the visual character of the area in terms of the intrusion of a development into a „view‟, which may affect the „sense of place‟ of the area.

A question needs to be posed in terms of the visual sensitivity of the study area and whether any receptors in the study area could be termed sensitive receptors. In this context it should be noted that apart from the Suurwater farmstead and the N14 highway, all of the receptor locations in the study area, and indeed all of the human activity in the study area appears to be related to the presence of the mine. As described above, Aggeneys as a settlement is intrinsically related to the Black Mountain Mine. The village itself was only established once mining started in the early 1970‟s, and was set up for the purpose of providing housing and amenities to people working at the Black Mountain Mine (http://www.aggeneys.com/history). As most of the residents of the village inhabit it because of the mine, it is thought to be highly unlikely that they would associate the mine and any changes in the appearance of mine components as a visual impact due to the mine providing the means to sustain a livelihood.

The inhabitants of the Suurwater Farmstead could qualify as sensitive receptors, but are likely to be sufficiently distant from the mine (as explored in the section below) to not be affected by it. Similarly people travelling along the N14 road may view the mine negatively, but in the context of the road between Pofadder and Springbok (with its expanses of wide open, uninhabited land); the Black Mountain Mine occupies a relatively minor „segment‟ of the journey, and is not visually prominent, due to the distance of the road away from the mine.

The above factors influence the general visual sensitivity of the area; as stated previously the only reason for the vast majority of people inhabiting the study area and visiting it (apart from people travelling past the site along the N14 road) is due to the presence of the Black Mountain Mine. The village of Aggeneys owes its existence to the mine, and thus it is likely that the mining activities are viewed by most inhabitants and visitors to the study area as being an intrinsic part of the visual fabric of the area. It should also be noted that mining is not out of place in the wider context of the Northern Cape, as it is perceived by many to be an important means of generating economic activity and income in an area that suffers from an absence of income generating activities. In this context the visual sensitivity of the area is likely to be very low, which means that any visual changes to the area relating to the upgrading of the mine are unlikely to be perceived negatively. The exploration of potential visual impacts associated with the proposed mine upgrading as explored below must be seen in this context.

2.12 Socio-economic structure Most of this information was obtained from the existing EMPR and BMM Social and Labour Plan (SLP).

2.12.1 Overview

The value of the Black Mountain Mine‟s investment in this area to date was R1.421 billion. This included the purchase of the proclaimed town of Aggeneys. Since its operation, employee and contractor numbers have shown a steady increase and stabilised to current levels reflected in the table below as at December 2007.

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Table 2-18: Total estimated job opportunities created by Black Mountain

Category of Employment Number of Jobs

Total permanent employees (direct employment) 752

Total indirect employment 708

Induced employment 584 *

Total estimated employment 2 044

* According to SEAT - Induced employment is assumed to be 40% of direct and indirect employment.

Approximately 60% of direct employment is from the local communities within the Namakwa district municipal region, and it is Black Mountain‟s policy to request contractors to where possible, recruit their employees from local communities. The larger towns within the Namakwa district municipal area are Springbok, O‟Okiep, Nababeep, Concordia, Steinkopf, Pofadder and Pella. Black Mountain‟s policy regarding preference to local recruitment is borne out by the fact that 72% of the employees are from the Northern Cape Province.

Figure 2-35: Labour sending areas by local municipalities

The above graph illustrates the impact that inert Black Mountain has on the local towns and surrounding areas within the Khai-Ma (Pofadder), Nama Khoi (Springbok) and Khara Hais (Upington) municipal regions, Figure 2-36 provides further information regarding recruitment of employees.

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Figure 2-36: Labour sending areas by Towns within thin the Namakwa and Siyanda District Municipalities

From Figure 2-36 it is clear that the majority (60%) of employees were recruited from the local towns of Springbok, Pella and Pofadder. This is an indication of those municipal areas where the company has the most significant direct impact. A significant transfer of skills and development of the local human resource has taken place as a result of this operation being established, especially due to the technical nature of the operation in a traditional agricultural/subsistence-farming environment. Black Mountain is committed to the continued implementation and evaluation of an appropriate Local Economic Development Plan with the focus on sustainable development initiatives in local communities.

2.12.2 Formulation of Integrated Development Plan’s Black Mountain as a stakeholder participates and supports the Khai-Ma Municipality‟s Integrated Development Plan. It is the company‟s strategy to align its community social investment initiatives as closely as possible to the local municipal IDP. Based on the IDP, Khai-Ma municipality identified and prioritised projects which they requested company to fund and these are listed below and details are provided in the SLP. The full funding of the following projects are borne by the operation at the total cost of R16,5 million, which will be spent over a 5 year period which commenced in 2009. Poverty alleviation Infrastructure development Community upliftment and development Small business / Enterprise development

2.12.3 Aggeneys Community Engagement Plan Black Mountain has been in operation for the last 28 years and a formal annual Community Engagement Plan (CEP) is issued at the beginning of each financial year. The following are activities or projects that fall under this initiative:

Community Engagement Plan initiatives within the town of Aggeneys and surrounding towns:

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Education and Youth - BMM has embarked on a process to collaborate with Okiep FET college campus to reach its full potential with regards to further education and training especially in the field of technical training - Registration of 100 students from the Khai-Ma region which expenses will be covered in full by BMM for the 2013 academic year at the Okiep FET college - Full maintenance of state school buildings. - Skills upgrade of mathematics & science for teachers & learners - Free bus transport to and from school, including off site extra-curricula activities. - Community Work Exposure program - Bursary programme - iSchool programme for schools in our host communities - iPad training for selected teachers from the various schools were done in 2012 with the aim to start using the Ipads in the classroom - The establishment of a vegetable garden at Aggeneys High School is in progress - Africa Eco-gro Consultants have completed the feasibility study for a sizable Olive project in Aggeneys .

Medical facilities and Infrastructure - General Practioner, Paramedics & nursing staff - An eye–clinic where cataract surgery were conducted at the expense of BMM for patients from the Namaqua District was done at Aggeneys Clinic in December 2012 - Primary Healthcare and Occupational Health Clinic facilities - Subsidized facilities for State run clinic - HIV&AIDS and Voluntary Counseling & Testing program for employees, contractors and community Municipal Services - Refuse removal - Potable water provision to towns of, Pella, Pofadder & Aggeneys - Sewerage and waste management - In order to improve service delivery within our Host Communities, BMM has purchased Sewage truck, cherry picker, compressor and grader the to the amount of R1.3m Khai-Ma municipality

2.12.4 Small Business Development The company supports the development of small medium micro enterprises SMME‟s, especially those from the ranks of historically disadvantaged South Africans. This goal is achieved through the Procurement Department through its procurement of capital goods, consumables and services, including the outsourcing of non-core activities to historically disadvantaged employees and assisting them with the establishment of these companies, to date 10 companies have been formed via this method. Black Mountain has contracted a significant number of services to independent contractors and suppliers. Services contracted out include but are not limited to the following, security, garden maintenance and refuse removal services, transport of personnel and mineral concentrates. In addition to the financial contribution to the local economy the creation of these companies also contribute to the creation and retention of jobs within local communities. Those

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outsourced BEE companies established by or through the assistance of the operation are mentored by company officials on a regular basis by personal contact sessions being held with the owners.

The following is underway, in support of small business development

- Brick making project in Pella is being registered as non profit organisation, with 9 members selected from within the Pella community. Optimisation plan to increase production currently at 600 per day completed and they are able to reach 1000 per day now. - Plans to train the 9 members in business skills are underway - Both the fencing work and renovations to the ablution facilities at Onseepkans Primary School are complete - A request for the erection of High Masts public lighting at strategic points in Onseepkans is being processed

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3 PROCESS DESCRIPTION

This section provides an understanding of the basic activities that will be conducted by the mining operation in order to evaluate the impacts. 3.1 Mining Process The ore body is exploited by means of a surface vertical shaft having a 7.4m diameter, sunk to a depth of 1,752m below collar, and by the extension of the main decline of the Broken Hill mine. The decline from Broken Hill mine have dimensions of 5.5m x 4.7m ramps down at an inclination of –15% (8.5° or 1:6.7). The stoping method is Ramp-in Stope (RIS) cut and fill. The RIS method was developed from the sub level cut and fill method; the only difference being the position of the access ramp, which in RIS is also in ore. RIS cut and fill has the important advantage of reducing the amount of secondary waste development required for access to the stopes.

The mining process involves the listed activities below: Making safe – The miner assesses the area with a pinch bar and makes a call on whether the area is safe or not. An operator with a scaler further loosens and breaks down lose rocks to make the area safer. Installation of support – The Boltec machine is used to install 2.4m steel bars and resin capsules into the roof part of the area. The area is further assessed for safety until declared safe. Drilling/raise boring – The operator uses the Rocket Boomer for drilling 4.5m holes into the safe area. Charging and Blasting – The lifting machine is used to load holes with explosives. After charging, there is a 37 minute get-away period required before the area is blasted. Cleaning – A scoop is used to clean the blasted area and loads. Tramming – The scoop loads the collected ore onto a truck and has to load 50 tons of ore. Tipping – The truck tips the 50 tons of ore into a tipping area. Rock breaking – After tipping the large rocks of ore are broken down through the grizzly into a silo then through the apron feeder situated on a level below the tipping area. Crushing – The apron feeder feeds the crusher with ore, where the ore is crushed into 150mm sized rocks. The crushed ore goes further down into a smaller silo also known as a Y-leg. This is then transfers into a bigger silo also situated beneath the Y-leg. Conveying – The silo feeds a conveyor belt situated at the lower next level. The ore is transported by the conveyor belt into two loading boxes. Each loading box has a 13 ton skip which is filled with ore. Hoisting – The 13 tons skips are hoisted up to surface and tipped into the headgear bin. Overland conveying – The headgear bin feeds the overland conveyor belt and the ore is transported by the conveyor belt to the stock pilling area at Tony‟s Dam where it is stock piled for processing.

3.2 Mineral Processing Plant The concentrator at Black Mountain Mine (BMM) treats ore from the Broken Hill Deeps ore body. Ore can also be supplied from the Broken Hill, Swartberg and Gamsberg ore bodies. The plant currently produces 1.44 Mt of copper-lead-zinc-silver ore per year, producing a daily average of 38 tonnes of copper (Cu) concentrate, 282 tonnes of lead (Pb) concentrate and 168 tonnes of zinc (Zn) concentrate. The mineral processing is indicated on Figure 1 below and each process is explained in details from Section 3.3.1 to Section 3.3.10.

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Figure 3-1: Typical Mine Flow Diagram

3.2.1 Crushing

The blasted material is taken for crushing. A crushing section is where the ore is crushed by primary, secondary and tertiary crushers to a final product size of –12mm with an 80% passing. Dust generated in this section is suppressed by a dust suppression system to clean the dust-laden air prior to it being discharged to atmosphere (see crushing circuit below).

Figure 3-2: Crushing Circuit

3.2.2 Milling

Following the crushing section there is a wet grinding section consisting of a rod mill and ball mill, which does not produce dust, where the crushed ore is further reduced in size to facilitate flotation of the various minerals (Figure 3-3). The rod mill discharge is fed to the first stage cyclones (6 cyclones – 4 in use, 2 stand-by), the overflow is gravity fed to the aeration circuit and the underflow goes into the second stage cyclone feed sump. The slurry is pumped from the sump to the second stage cyclones (10 cyclones – 6 in use, 4 stand-by) where the overflow is also gravity fed to the aeration circuit and the underflow goes to

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the ball mill where it is being liberated further. The ball mill discharge combines with the rod mill discharge in the 1 stage cyclone feed sump.

Figure 3-3: Milling Flow Diagram

3.2.3 Aeration

The cyclone overflow feeds the aeration circuit. From the aeration cells it is pumped to the first conditioner tank of the copper flotation circuit. As the pump passes down the aeration banks, copper is increasingly activated, while lead is progressively depressed. The aeration process is done to ensure that the redox potential is at the correct level for successful copper flotation. 3.3 Flotation Flotation is an extraction process in which the mineral particles are fed in the form of pulp into a bank of flotation cells in which the pulp is agitated by impellers and air is bubbled through. By suitable chemical conditioning the desired mineral can be made to adhere to an air bubble so that a mineral-rich froth is removed and cleaned in further flotation stages, where after it is thickened and filtered to obtain the mineral concentrate. By this process the slurry is then passed through three flotation stages where, firstly 26% copper then 71% lead and finally 49.5% zinc are removed sequentially as explained below:

3.3.1 Copper Flotation

After aeration, the pulp is transferred to the copper conditioner tank (Figure 3-4) where mixing of the slurry takes place and the pH of the slurry is taken. Sodium ethyl xanthate (SEX) is added and mixed in with the pulp in the second conditioner. The SEX is a general sulphide collector. In the second copper conditioner tank, frother and sulphurous acid are added. From the conditioner tanks, the pulp (at a relative density of ~1.350) gravitates to the copper flotation circuit rougher cells. The concentrate from these is pumped directly to the first copper cleaner. The slurry from copper rougher cells is then passed through three copper cleaners where sulphurous acid is added for pH control and as a lead sulphide and zinc sulphide depressant. In the third copper cleaner lime is added to depress the pyrite (the pH increases to approximately 10.5). The concentrate from the third cleaner is transferred directly to the copper concentrate thickener.

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Copper recovery is usually about 65% with a concentrate grade analysing 26% Cu, 3.50% Pb, 3.00% Zn and 300 g/t Ag.

Figure 3-4: Copper Flotation Flow Diagram.

3.3.2 Lead Flotation

The underflow from the copper tails thickener feeds three lead conditioner tanks (Figure 3-5). Lime is added to the first conditioner tank, zinc sulphate and sodium cyanide, sodium ethyl xanthate (SEX), and frother into the second conditioner. The slurry is fed to the lead rougher circuit. The concentrate from both the first and the second and third rougher goes to the cleaner stage where the concentrate is being upgraded to a higher grade. The concentrate from the cleaner is pumped to the lead concentrate thickener, while the tails flow back into the conditioner. Lead recovery is usually about 90% with a concentrate grade analysing 0.6% Cu, 71.0% Pb, 3.7% Zn and 800 g/tAg.

3.3.3 Zinc Flotation

The tails from the lead rougher circuit are pumped as feed to the first zinc conditioner tank where the slurry is mixed and kept in suspension. At the lead tails pump CuSO4 is added to activate the zinc. Lime, SEX and frother are added to the second zinc conditioning tank. The lime depresses the iron, while the copper sulphate is used as a zinc activator. The rougher feed is split into 20% going to the 2nd rougher (conventional cell) and 80% to the 1st rougher tank cell. The tails of the first rougher tank cell is pumped to the 2nd rougher (conventional cell). The tailings of the second rougher are gravity fed to the third rougher conventional cell and the tailing of the third rougher is gravity fed to the rougher scavenger. The concentrate of the rougher scavenger is pumped to the conditioning stages again to refloat the material. The tailing of the rougher scavenger is pumped to the tailing dam. The concentrates from the 1st, 2nd and 3rd rougher is pumped to the cleaner stage where the grade in increased by adding additional lime to depress the iron. The final tails are pumped either to the Backfill plant or to the slimes (tailings) dam. Zinc (Zn) recovery is about 75.%, while the concentrate grade assays at about 49.5% Zn with 2.0% Pb.

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Figure 3-5: Lead Flotation Flow Diagram

Figure 3-6: Zinc Flotation Flow Diagram

3.4 Thickening The concentrate from each of the three flotation processes is pumped to its relevant concentrate thickener. The thickening process is a de-watering process, and, the overflow (water) from all of the operating thickeners is transferred to the water return dam (ageing pond). The underflow of the concentrate thickeners is pumped to the larox filters where the material is dried to 8% Cu moisture, 6% lead moisture and 8% zinc moisture. The filter cakes are conveyed to the concentrate sheds where the concentrates are being trucked to Loop 10 and trained to Saldanha. From Saldanha they are then shipped to European countries for further refinery.

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Figure 3-7: Thickener and Filtration Flow Sheet 3.5 Tailings Dam

1 The tails produced from flotation is transferred to the tailings dam. About /6 of the tailings produced is used underground as hydraulic backfill, the remainder being sent to a slimes dam.

Based on an in-situ density of 1.65 ton per m3, the total tailings deposition volume (airspace) required, assuming no backfill to the underground mine workings, amounts to 7.3 million m3. A pond is maintained on the top of the dam, in which the slimes settle out, the clear water overflow being decanted through a penstock and led to the ageing pond.

Any seepage from the sides of the dam, or at ground level, is caught by a drainage trench around the slimes dam and also led to the ageing pond.

The tailings are deposited by being pumped at a slurry density of 1.65 ton per m3 to the slimes dam, with the tailings underflow used to flatten the outer slopes whilst the overflow is deposited on the upper surface of the tailings dam. The final elevation is fixed at 858 mamsl, to limit the height of the tailings dam to 50m. The outer slopes on the western, eastern and northern flanks are 1:3 and the southern flank is 1:4. The dimensions of the upper surface, located within the final day-wall, is roughly 760 x 350m. The volume of tailings required on the outer slopes is 1.9 million m3 and on the top is 5.5 million m3. The required underflow / outerflow split for the cycloning process is thus 26% (twenty-six percent) underflow (outer slope deposition) and 74% (seventy-four percent) as overflow (upper surface deposition). The underflow has a fine tail but does not influence the performance as outer slope material. The rim walls are kept higher than the settling area to ensure that any heavy rains falling on the dam will be retained and led to the ageing pond via the penstock.

The drains comprise a 150mm thick washed 19mm stone layer wrapped in filtration geotextile, containing a perforated pipe. The drains are approximately 4m wide and collect seepage from the cycloned tailings underflow. The outlet pipes from the drains are solid walled and discharge into the solution trench. On the northern side of the tailings dam, the drains are elevated (i.e. constructed on fill to allow drainage to the solution trench). The solution trench is trapezoidal in shape and runs along the full perimeter of the tailings dam. Due to the flat grades of the solution trench on the northern and southern sides, it is lined with 100mm thick stone pitching

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There is a return water dam located where it allows for drainage of the solution trench under gravity. The dam is lined with a primary 1.5mm High Density Polyethylene (HDPE) geo-membrane and a secondary 1.0mm HDPE geo-membrane. A leakage detection system consisting of a 0.75mm cuspated drain direct any leakage to a sump from where it is pumped back into the dam. The dam receives two (2) sources of water: Decant from the tailings dam penstock; and Excess process water from the plant. 3.6 Backfill Slurry (a mixture of tailings and process water) from the metallurgical plant is fed to the slurry tank. The slurry tank overflow discharges into the tailings tank. Sand mined at the nearby dunes is added at a ratio of one ton sand for every four tons tailings in the 1st stage mixing tank. Reclaim water is added to ensure that the correct density is achieved. The mixture from the 1st stage mixing tank is pumped to the 2nd stage mixing tank. Cement is added in the 2nd stage tank at the required dosage. Chryso Fluid MF is added at a rate of 0.6 litres per ton of mix. The backfill is pumped from the second stage mixing tank to the borehole which discharges to the underground backfill system (See Figure 3-8). The composition and physical properties of the hydraulic backfill medium is described in Table 3-1.

Figure 3-8: Backfill Plant Layout

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Table 3-1: Physico-chemical properties of the hydraulic backfill medium.

Item Description

Content 20% sand: 80% tailings and cement (mixed at 10:1, or 60:1 for surface topping). Reclaim water is used for mixing

Backfill production rate 650 wet tonnes per hour

Frequency of production 80% of mining activity

Density 2.1 tonnes per cubic metre

Cement Afrisam strengthened with Chrysofluid MF

Temperature 23 ºC

pH 9.6-11.5

A chemical breakdown of the reclaim water and the tailings is given in Tables 3-2 and 3-3. The chemical composition of the slurry and tailings varies, but consists mostly of magnetite and silicates with lesser amounts of pyrite, chalcopyrite, galena, and sphalerite. The liquid component consists of trace amounts of dissolved calcium, xanthate, cyanide, copper and zinc. Table 3-2: The chemical composition of reclaim water.

SPECIFICATIONS Average values

PH 5.5 – 9.5 6.26

Dissolved solids < 2,000 mg/l 1,704

Sulphates < 1,000 mg/l 913

Total Alkalinity < 1,000 mg/l 26.36

Chlorides < 500 mg/l 220.17

Copper 3 mg/l < 0.01

Conductivity Msm-1 196.8

Oil and grease Mg/s 5

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Table 3-3: The chemical composition of the tailings.

Copper (Cu) 0.08% Lead (Pb) 0.44% Zinc (Zn) 0.59% 30% goes to Backfill, the rest to the Tailings Dam. Bismuth (Bi) 18.6 g/t This reduces the footprint of the Tailings Dam. Silver (Ag) 8 g/t Cobalt (Co) 159 g/t

The slurry tank receives tailings slurry from the process plant. The overflow of the slurry tank discharges into the tailings tank. The contents of the tailings tank are pumped to the slimes dam. The pumping distance to the slimes dam varies depending on the discharge location. The reclaim water tanks receive water recovered from underground, the decant backfill water as well as from the process plant. The 1st stage mixing system consists of the following main components: 3,000 ton sand bunker 300 ton sand hopper 1st Stage mixing tank Pumping system. The 3,000 ton sand bunker feeds the 300 ton sand tank. The variable speed belt feeder at the base of the tank feeds onto a fixed speed conveyor which discharges into the 1st stage mixing tank. The belt feeder speed is set in the control room. A belt scale measures the mass of sand added to the 1st stage mixing tank.

The 1st stage mixing tank receives slurry from the slurry tank, water from the reclaim water tanks, sand from the 300 ton sand tank. Adjusting the slurry and sand inflow into the tank controls the tank level. The pumps transferring the slurry to the 2nd stage mixing tank are fixed speed.

Two Weir EnviroTech 200×200 SRC fixed speed pumps in parallel transfer slurry from the 1st stage mixing tank to the 2nd stage mixing tank. Strainers are installed between the tank and the pump suctions. The 2nd stage mixing system consists of the following main components: 150 ton cement silo 2nd stage mixing tank Pumping system Chrysofluid MF dosing system The 150 ton cement silo is fitted with a variable speed screw feeder, which feeds a fixed speed conveyor. The fixed speed conveyor discharges into a cement feeder cone which discharges into the 2nd stage mixing tank. The operator in the control room controls the speed of the cement screw feeder. A belt scale measures the mass of cement added to the 2nd stage mixing tank. Slurry from the 1st stage mixing tank is mixed with cement from the silo through the cement mixing cone. Chrysofluid MF additive is added to the slurry in the 2nd stage mixing tank. The operator controls the additive dosage by: Switching the pump on and off at the dosage pump position. The correct feed is acquired by opening a valve to a predetermined setting at the pump. The following equipment is controlled from the Backfill Plant control room: Siren – to communicate between operators. Cement screw feeder speed – to control the slurry : cement ratio. Sand belt feeder speed – to control the slurry density. 200×200 SRC pump speed to control the level of the 2nd stage mixing tank.

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3.7 Storage of finished products The concentrate produced from flotation is transferred to the thickening and filtration plants for dewatering and drying. The final dried products (copper, lead and zinc) are then stockpiled for removal by truck. 3.8 Dispatch of Products from Site The finished products are loaded to the trucks by means of a front-end loader. All material removed from site is sent over a weighbridge to ensure that the correct weight of material is taken and to avoid overloading. Concentrates (copper, lead and zinc) are trucked to Loop 10 (Halfweg), stored there in an enclosed shed and when train arrived been load and rail via the Sishen/Saldanha railway line to Saldanha, for storage and export to various countries.

Moving concentrates by rail is our primary means of transportation. Most of the concentrate is transported in the same way, though a limited amount is trucked directly from the plant to Saldanha port as the need arises. During transport by both truck and rail, all concentrates are covered with tarpaulins, while storage and loading operations at both Halfweg and Saldanha take place within enclosed sheds. 3.9 Waste Rock The waste rock dump, which currently contains approximately 4,207,622 tonnes of waste rock is situated against the side of the Broken Hill and tends to blend with the slopes. No waste is anticipated to be hoisted from the Deeps mine, as all waste is stacked in the cut and fill stopes as filling occurs.

The waste rock dump might be used for the waste of the access decline for Swartberg that will be started near the Broken Hill area. The top area is currently at 88,911m2 and bottom area at 125,697m2. At the contact between dump and hill, the waste rock is slightly contoured up against the hillside.

The slope angle naturally achieved by the dumping of broken waste over the edge of the dump is 35°, which is a stable angle of repose that shows no sign of slippage. A trap drain catches water flowing off the hillside and delivers it to a drainage channel lying to the south of the dump, whence it flows to the backfill cyclone spill evaporation pond, lying to the south-west of the dump.

Although no significant seepage of water has originated from the dump to date, any seepage which could occur after rain would be caught in the abovementioned drainage channel. 3.10 Supporting Services and Activities The positions of the various features mentioned in this section could be located on the mine plan (Appendix E).

3.10.1 Housing, recreation and other employee facilities

Housing As there is no established community within a reasonable distance of the mine, accommodation is supplied for all employees.

Management and skilled persons are housed mainly in the North Village, which has 235 houses, a single quarter containing 12 rooms, 8 flats for senior single staff and visitors and 28 mobile homes. All semi-skilled persons, some skilled persons, and the more senior unskilled persons, are housed in the South Village, which comprises 254 houses, a male single quarter for 110 men and a female single quarter for 30 women.

The remaining employees are housed in single quarter accommodation in the hostel complex, in which are included 12 quarters, whilst married people stay in the houses. A clinic, primary and secondary schools, a small central business district (including a butchery, bottle store, grocery store, library, clothing store, bank agency, post office, police station, video store and

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hairdressing salon), a childrens‟ playground, and, a multi denominational church lie between the North and South Villages.

Recreation Facilities Each of the two (2) villages has its own recreation club, supporting all the popular sports such as squash, bowls, tennis, rugby, soccer, cricket, running, swimming, etc. The golf course has its own clubhouse. The 9-hole golf course is fully grassed. The hostels have TV show rooms and soccer fields.

Medical facilities The mine owns a clinic and there is a doctor who caters for the normal medical needs of the employees. A dentist, optometrist and a visits visit regularly and assistance is given to employees or their families who must travel to Cape Town / Upington for specialist treatment.

Workshops, administration and other buildings There are two (2) main workshops – one (1) to deal with production equipment and the other to handle the housing and township‟s requirements. The plant, shaft and workshops each have their own administrative offices, though the main company offices are situated near to the North Village.

An explosive factory and magazines are located within the mine‟s security area, as are the warehouse and salvage yard.

Areas have been set aside within the security area for certain contractors who supply services to the mine (See Appendix E).

3.10.2 Water Supply

Potable Water A pump station has been established by the Pelladrift Water Board to pump water for the mine and township from the Orange River. This scheme also supplies potable water to Pofadder, Pella and Swartkoppies.

A total of 4,580,000m3 was pumped by the scheme during the year ended 31 March 1992, of which 4,430,000m3 was used by the Black Mountain Mine and the Aggeneys Township. Potable water is supplied by Pelladrift Water Board.

Process Water Supply A pumpstation has been established by the Pelladrift Water Board to pump water for the mine and township from the Orange River. This scheme also supplies water to Pofadder, Pella and Swartkoppies. A total of 4,580,000m3 was pumped by the scheme in the year ended 31 March 1992, of which 4,430,000m3 was used by the Black Mountain Mine and the Aggeneys Township.

Groundwater source a) Underground mining operations Very little natural water is encountered underground. Orange River water is used for service and drinking, and also in the backfill plant when cemented fill toppings are being thrown. The bulk of the water being pumped from underground originates from backfill drainage. Dirty water pumps deliver unsettled water from underground to a water clarifier on surface. The underflow from this clarifier is sent to the slimes dam, while the clarified water is mainly used for backfilling operations, with any surplus being sent to the concentrator.

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b) Plant Water from the slimes dam is caught by drainage trenches around the foot of the dam and is led to an ageing pond, from where it is pumped for re-use in the plant and for hydraulic backfill. Further process water originates from water pumped from underground. Despite this reclamation, certain of Orange River water has to be used as make-up for the process. The quantity varies with the season and with the quality of the ore being treated, but averages slightly more than 1 m3/t milled

3.10.3 Power / Electricity

Electricity is provided to the mine by the Electricity Supply Commission network at the Hydra sub-station at De Aar, via two 66 kV overhead power lines. Each of the existing overhead power lines to the Black Mountain consumer substation can carry the existing as well as the future load. The Consumer Sub- station consists of standard switchgear consisting of bus couplers, vacuum circuit breakers, Solkor protection and ring feed system. The switchgear is housed in a building similar to the existing Broken Hill Shaft Sub-Station.

3.10.4 Airfields, roads and railways

A certified airfield has been constructed at Aggeneys by the mine. The main Springbok – Pofadder road, the N14, runs through the property about 3 km to the south of the tailings dam. The Sishen-Saldanha railway line passes approximately 170km to the south of the property, with Loop 10 being the closest siding.

3.10.5 Sanitation facilities

Sewage Two (2) sewage plants are in operation, one serving the mine and hostels and the other the township, as can be seen in Plan 4.A. Design capacities are 385,000 m3/annum, based on 1,050 m3/day. Sewage is treated in oxidation ponds, water emanating from the township plant being used for watering the golf course and water from the mine plant being used for irrigation of lucerne.

In the period that the mine has been in operation, it has been necessary to clean out the solid residue once only, and, on this occasion, the residue was buried in trenches situated next to the ponds. There are ten (10) septic tanks on the property. Each of these has a concrete floor with concrete rings mounted on top. The tanks are pumped out on a regular basis and the sewage delivered to one of the main sewage plants (Figure 3-9).

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Figure 3-9: The Mine Sewage System

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3.10.6 Diesel/Fuel

Petrol, diesel and lubricant oil is stored on site as indicated on the table below. Table 3-4: Hydrocarbon register onsite

Site Tank Capacity Frequency of deep stick

Underground 45 Level 4,000L X3 tanks -lubricant oil Daily

Underground 45 Level 7,000L – diesel tanks Daily

Stores – surface 23,000LX6 tanks – diesel Daily

Infront of repair shop 9,000L – diesel Daily

Infront of repair shop 2,300LX3 – 1 petrol and 2 diesel Daily

Gamsberg 2,300L – Diesel Daily

Loop 10 23,000L X 5 – Diesel Daily

SPH 23,000Lx 2 – Diesel tank Monthly

3.10.7 Storm water

The positions of various storm water walls forming the storm water protection system are indicated in the mine plan (Appendix E). These walls were constructed to protect houses and other installations in the event of a flash flood, as well as to prevent runoff rainwater from clean areas flowing through mining area.

3.10.8 Solid waste management facilities

Domestic and Industrial Waste Separate numbered bins with leads and skips are provided for different waste types, to facilitate correct disposal. The waste bins are emptied on weekly basis and disposed / recycled at the two refuse disposal sites located within the mining area. Waste is separated here where used cooking oil from recreational clubs and shops is given to the farmers and glass, paper and non perishable products are taken for recycling and the rest is burnt and buried at the mine domestic landfill (Figure 3-10). Further to this, certain waste materials resulting from mining and underground equipment maintenance activities are entombed within backfill placed in the stopes.

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Figure 3-10: BMM General Waste Flow Diagram

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3.10.9 Hazardous waste

Labelled bins with leads and skips are provided for hazardous waste which cannot be recycled and this is collected by the contactors and disposed off at Vissershok Hazardous landfill. Used oil is collected and returned to OilKol and printer cartridges returned to Nashua for recycling. Hazardous wastes produced by the mine include: Asbestos Oil contaminated waste Fluorescent tubes Lead contaminated PPE Chemical bottles Lead contaminated rubber Empty grease containers Old/waste oil Oil separators

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Figure 3-11: BMM Hazardous Waste Flow Diagram

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The waste products generated at Black Mountain Mine include: Brake fluid; Cleaned hydrocarbon spills; Degreaser; Domestic waste; Engine coolant; Fluorescent tubes; Medical waste; Oil contaminated waste; Oil filters; Oil (used); Oil (PCB contaminated); Paint tins; Rubber; Scrap metal; Tyres (used); Vehicle parts; Asbestos; Lead contaminated PPE; Chemical bottles; Lead contaminated rubber; and Empty grease containers.

3.10.10 Emergency Incidents and / or Accidents

Black Mountain has a Standard Operating Procedures (SOP‟s) ESOP033: Emergency Preparedness and Response is fundamental to manage environmental emergencies(Attached Appendix F): The purpose is to comply with ISO 14001 requirements and to provide guidance to all mine employees and business partners as to their responsibilities to the mine, fellow employees and colleagues in the event of an environmental emergency. The procedure aims to:

Minimize danger to the environment, personnel, Business Partners and non-employees; Limit legal liability; and Ensure public relations are effectively managed during and following an emergency. Potential Environmental Emergencies The following aspects have been identified as the potential of becoming environmental emergencies at BMM:

Chemical spills; Hydrocarbon spills; Veldt fires; Mineral residue dam failure; Process water spills; Tailings pipeline spills; Fresh water spills; Concentrate spills; Ore spills; Cyanide spills; and Other environmental emergencies requiring special services.

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3.11 Concurrent Rehabilitation Information in this section is obtained from the Environmental Rehabilitation Programme for Life of Mine Phase 1 (Appendix G). Mined-out areas are being re-vegetated concurrently with mining. This is done by confining any traffic to defined access roads and scarifying the remainder to allow the re-establishment of dune grasses and bushes. Should vegetation not spread naturally, expert advice would have to be taken as to the correct seeds to be used, but currently vegetation is already recovering. To assist this process, the top few centimetres stripped from the surface of the dune, which contain grass seeds and roots, are now being spread over some of the worked-out areas. Initial growth can be assisted by occasional watering with a water cart, but this must be done very sparingly in order to ensure that only those natural dune grasses than can resist dry conditions become established.

Due to mining of the sand dunes as primary source of sand since 1980 the area was changed to a flat topography with raised island where the exploration boreholes was encountered. The total sand mining area was also lowered by approximately 1,000mm to 2,000mm in relation to the neighbouring land. Previously rehabilitation of the sand dune mining area consisted of levelling the mined out area, ripping the soil and allowing natural vegetation to establish over time. This has led to the “natural” rehabilitation of the old mining areas. Rehabilitation practices during 2008 and 2009 included the spreading of topsoil on the worked out areas to facilitate the establishment of vegetation from the natural seed bank. Rehabilitation of the work out areas consists of the following steps: Surveying of surrounding slopes to ensure that correct profile is established. This will allow for natural drainage patterns and prevent the creation of ponds of water in the works. Any unnatural mounds created by sand mining activities will be levelled. Screened material will be spread over the new rehabilitation area. Compacted soils will be ripped to enable easier root establishment. Top soil stripped to a depth of 300mm from the new mining area will be spread over the newly ripped worked out area to facilitate vegetation establishment and prevent seed bank loss due to sterilisation in topsoil heaps. To facilitate grass establishment in the event of vegetation growth from the topsoil seed bed not taking, seed of the following grass species will be seeded before the rain: - Scmiditia kalihariensis (pioneer grass) - Stipagrostis obtusa - Stripagrostis ciliata

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3.12 Closure and Decommissioning Information in this section is taken/extracted from BMM Closure Plan Report (2010). MPRDA Regulation 56 defines closure as “a process, which starts at the commencement of an operation and continues throughout the life of that operation”. The MPRDA and applicable regulations further endorse the principle of systematic rehabilitation of mining induced impacts throughout the life of that operation, managing and mitigating environmental risks and impacts proactively. The areas of environmental concern are (in order of priority) in terms of closure Plaatjiesvlei; Tailings dam; Rock dumps; Reedbed; Swartberg and the Sand dunes.

3.12.1 Closure objectives

The aim of Black Mountain Closure Plan is to ensure that the area transformed by mining, processing and other operational activities is either returned to as natural a state as possible or facilities remaining at the end of the life of BMM are utilised for other economically viable and sustainable activities. The closure objectives should be achieved in as cost effective a manner as possible, and the closure solution should be sustainable in the long term.

Four Key Objectives are identified To secure the effective and sustainable transfer of the municipal services of the town, Aggeneys, and the Pella-drift Water Board to the Khai Ma municipality. To ensure that the biodiversity and environment on the site is protected. To make sure that the following commitments will be achieved as a minimum:  The site will be made safe for both humans and animals,  The site will be rehabilitated to be physically, chemically and biologically stable  The residual impacts will be managed to acceptable levels and will not  deteriorate over time, and  Closure will be achieved with minimal socio-economic upheaval. To provide sufficient funds at the end of life of mine, to properly implement the closure plan, and also to make provision for possible premature closure, and post closure monitoring requirements.

3.12.2 Closure framework

The following framework will provide the basis from which detailed, site specific closure plans; aimed at obtaining progressive systematic closure of the Black Mountain surface area will be prepared. Integral to this closure plan framework will be the following requirements which will require incorporation into the detailed site specific plans prepared. Public consultation and liaison with stakeholders and interested and affected parties (I&AP‟s) Integration of land and/or infrastructure, upon the issuing of a closure certificate, into the Local Economic Development Plan of the local authority (where relevant and applicable). Alignment of the closure plan(s) with the National Waste Policy and the applicable BMM Waste Policy and Waste Management Plan. Preparation of detailed site specific plans for closure activities planned, strictly in accordance with the requirements of MPRDA 2002 regulations 55(8) and (9), 60 and 62 Integration of the requirements of MPRDA 2002 regulations 63 to 73, where applicable into the closure plan(s) Integration of all DWAE and Mine Health and Safety requirements, cognizant of the fact that no closure certificate will be issued unless endorsed in writing by both DWAE and the Directorate: Mine Health and Safety (MPRDA 2002, section 43(5).

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Application and integration of DMR rehabilitation guidelines and generally accepted closure principles Examining and listing of existing servitudes and surface right permits over areas for which closure is contemplated

3.12.3 Rehabilitation Methodology proposed for the infrastructure on site

3.12.3.1 Shafts and associated infrastructure

In formulating a conceptual strategy for the rehabilitation and closure of the shafts at BMM, it has been assumed that steelwork will be cut up and reclaimed and that rubble generated by demolition activities will be disposed of via the shafts and adits, following which, shafts and adits will be capped and sealed. The following strategy will be implemented: Demarcate area earmarked for demolition/rehabilitation Conduct a detailed site assessment/survey aimed at identifying scope of demolition and rehabilitation required Identify and quantity all wastes and waste arisings Perform waste categorization to determine waste disposal options Identify scope and extent of surface contamination as well as identify contaminants Determine decontamination options Decontaminate contaminated areas in accordance with commensurate waste disposal options identified Remove and dismantle all saleable equipment (winders, fans etc) Dismantle, demolish super structures (concrete and steel as per safe work procedure) Demolish and remove foundations to one metre below natural ground level Backfill with subsoil/topsoil and contour Remove remaining alien/invasive plant species Establish vegetation or alternative depending upon final land use determined

3.12.3.2 Capping and sealing of shafts

The following requirements, as per the applicable Mine Health and Safety Guideline will be applied: The final level of the cap construction will be on natural ground level A beacon will be erected in the centre of the shaft and registered with a local survey authority A plate containing the details of the shaft, shaft coordinates etc will be fixed on the beacon The bottom edges of the shaft cap (a concrete slab) will rest on competent ground or on pile foundation, which reaches competent ground Competent ground means the ground with a bearing capacity sufficient ton support the shaft cap and additional load that may be imposed on this cap The strength of the slab will be such that the slab will support its own weight, weight of material above and any additional load of 20 kPa (2 tonne per square meter) The design of the plug/cap will be certified by a professional engineer. Steel reinforcement will be purchased from recognized suppliers whose stocks comply in all respects within SANS (SABS) standards.

3.12.3.3 Slimes dam

There is only one (1) slimes dam associated with the Black Mountain operation. The dam covers an extent of 61 hectares and the associated ageing pond, which is lined, covers a further 7,5 hectares.

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The following rehabilitation methodology is proposed for the slimes dam: Rock cladding of the side slopes of the tailings dam, no topsoil (300mm thickness) Limited rock cladding on the surface, approximately 100mm thickness with cluster vegetation established (no topsoil) This methodology is proposed for the following reasons: Although the rock material that is proposed is sulphidic by nature, due to the arid nature of the area, sulphide oxidation is extremely slow as has been confirmed by prior tests done by Envirogreen (Fraser Alexander Technical) on the slimes dam fines material. The slimes dam will remain an unnatural feature where sustainable vegetation establishment will be extremely difficult. The impact of creating and having to rehabilitate the borrow pit created to provide topsoil for rehabilitation is also considered to be of a further prohibitive factor. Rock cladding and limited cluster vegetation is proposed and has been costed into the quantum assessment.

3.12.3.4 Rock Dumps There are four rock dumps associated with the Black Mountain operation that will require rehabilitation. The rock dump at Deeps shaft is currently being rehabilitated as part of the concurrent rehabilitation programme. The rock dumps are: Broken Hill rock dump (the main rock dump) Gamsberg rock dumps (associated with the adits) Swartberg rock dump The Deeps rock dump It is not anticipated that there will be a long term use for the rock dumps. Although a portion is currently being exploited for aggregate production, this activity will only extend for the current life of mine.

In-situ rehabilitation of the rock dumps is therefore proposed. A methodology similar than for the slimes dam is proposed in the draft closure plan although additional provision will need to be made for slope flattening, especially at the Broken Hill and Swartberg dumps to mitigate the potential for erosion of which clear signs are evident, particularly at Broken Hill. The following methodology is proposed:

Broken Hill rock dump This will be the principal source of rock for rock cladding of the slimes dam. Concurrent with slope flattening, which is considered essential for the dump; material can be sourced for rock cladding. After slope flattening the surface will be scarified and cluster vegetation established. Gamsberg and Deeps No slope flattening, scarify and establish cluster vegetation. Swartberg This dump is situated in a natural drainage line and in the resulting seepage, signs of acid rock drainage are evident that will impact on the surrounding environment. For this dump, topsoil and vegetation is proposed.

3.12.3.5 Process plants

There are two process plants that will require demolition and associated rehabilitation of the surface area, namely the Concentrator Plant, and the backfill plant at Broken Hill. In line with the Black Mountain draft closure plan and the “DMR generally accepted closure methods”, the following methodology is proposed.

Conduct a detailed site assessment/survey aimed at identifying and quantifying all waste and waste arisings

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Determine waste disposal options i.e. borrow pits, disposal of material down redundant shafts, etc Dismantling and removal of saleable plant infrastructure Demolition of redundant steelwork Identification and quantification of extent of surface contamination (concrete and soil) and demarcation of such Planned demolition of concrete foundations and removal of contaminated soil in a phased and structured manner as to prevent „cross-contamination‟ (i.e. contamination of clean areas) Disposal of all waste and waste material with accurate, detailed waste accounting records Removal of concrete foundations to one metre below natural ground level Backfilling with subsoil/topsoil and contouring Removal of alien/invasive plant species Vegetation establishment or alternative depending upon final land use Final performance assessment and application for closure In accordance with the requirements of the Mine Health and Safety Act 1996, the following will be required:

- Application of Mandatory Codes of Practice, (COP‟s) including mobile trackless machinery, minimum standards of fitness, noise induced hearing loss, occupational health surveillance, exposure to airborne pollutants, cyanide management and mine residue deposits - Safe work procedures (COP‟s) based upon baseline risk assessments for each activity associated with demolition/rehabilitation activities planned - Appointment of contractor(s) as subordinate managers in accordance with regulation 2.6.1 of the Mines and Works Act.

3.12.3.6 Evaporation/storage dams

The Plaatjiesvlei area covers an extent of 52 hectares, which has been severely impacted upon as a result of its utilization over the life of mine as an evaporation dam. In assessing the rehabilitation requirements for this area, it has been assumed that contaminated soil to a minimum depth of one metre will have to be removed over an area of 28,6 hectares in the area of worst impact, transported to the top of the tailings dam, with topsoil from the dune sand reclamation area introduced to enhance vegetation establishment. For the remainder of the area, (approximately 23,4 hectares), due to the low rainfall in the area, leaching of sulphides and heavy metals which could improve natural vegetation succession over time is expected to extend in excess of thirty years and hence, provision has been made for amelioration of the area to promote natural vegetation establishment. The following is proposed: Application of compost at 100 tonnes/hectare Liming if the substrate proves to be acidic

3.12.3.7 Landfill sites

As a minimum, the minimum standards for landfill will need to be applied for the rehabilitation process, which essentially, will entail the following as summarized below. Description of closure objectives Summary of regulatory requirements and conditions for closure Summary of identified residual and latent impacts as captured in an environmental risk report Phase 1: The permitting requirements, i.e. registering the sites for closure

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Phase II: Rehabilitation of the landfill site (a step by step process) to be implemented to obtain closure Management and maintenance Monitoring Consultation with I & AP‟s Closure

3.12.3.8 Dune sand reclamation area at Swartberg

The dune sand reclamation area at Swartberg, is the source of feed material for the backfill plant. The area has to a large extent been rehabilitated concurrent with reclamation activities. However, in the absence of periodic ongoing monitoring and performance assessments compliant with regulation 55(8) and (9) of the MPRDA 2002, the effectiveness and sustainability of the rehabilitation effected to date, cannot be substantiated. It is therefore imperative that this activity be incorporated into a structured and documented closure plan and the regular performance assessments be scheduled to assess the effectiveness of rehabilitation completed to date.

3.12.3.9 Concentrate pads

Concentrate storage pads are situated immediately south west of the concentrator plant and cover an area of approximately 1,6 hectares. Rehabilitation of the concentrate pads particularly at Gamsberg and outside the concentrator plant, is currently in progress. The total area of impact, inclusive of the above, extends to 2 hectares. A methodology similar to that for the Plaatjiesvlei area, which includes removal of contaminated soil and amelioration of the substrate, is recommended.

3.12.3.10 Overland conveyors

Overland conveyor structures have been installed to feed ore from Deeps/Broken Hill shafts to the concentrator plant. The strategy as expounded in Section 3.12.3.5 above to be applied for the requisite demolition and rehabilitation requirements.

3.12.3.11 Hostel complexes and training centre

There are two hostel complexes on the property, the partially demolished hostel No 1 (North West of Broken Hill shaft) currently utilized as a contractors camp, and the No 2 hostel complex east of Broken Hill shaft. The training centre is situated to the north east of No 2 hostel. In the closure plan it has been assumed that both hostels and the training centre will be demolished.

3.12.3.12 Workshops/stores/salvage yard

This area essentially comprises the following infrastructure: The main mine workshop complex The mine store area The associated salvage yard A small shopping complex

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Contractor office/workshop areas for:  Jowels Transport (concentrate transporting contractor)  SPH (materials haulage contractor)  Sandvic/Tamrock (drilling contractors)  Estac  Steinweld  Transcape Steel

This infrastructure is considered to be so closely related to mining operations so as to negate any potential future sustainable utilization post-closure. The only exception could be the main workshop complex/store area and contractor workshops/offices which could potentially be integrated into a sustainable social development plan for the area. Demolition of all of the structures and final rehabilitation is recommended within the following parameters. Conduct detailed assessment to confirm status quo in respect of state and condition of buildings and infrastructure Assess/evaluate options For structures to be demolished the following procedure will be followed:  Undertake survey to determine scope and extent of demolition and rehabilitating required  Identify and quantify all waste and waste arisings  Perform waste categorization to determine disposal options  List and describe disposal option  Demolish superstructures and remove foundations to one metre below natural ground level  Backfill with subsoil/topsoil and contour  Remove alien/invasive plant species  Establish vegetation or alternative depending upon final land use determined

Quarries and open pits in the mining area have essentially been divided into the following main two components: Quarries for whom the rehabilitation and closure liabilities are vested with Black Mountain in terms of its Environmental Management Programme/Closure Plan. Quarries within the mining area, on Black Mountain freehold but which are deemed to be the liability of the National Roads Department. (Quarries at Lemoenplaas). Only the quarries deemed to be the responsibility of Black Mountain have been incorporated into the quantum assessment. These include the following:  Quarries 1, 2 and 3 east of Aggeneys Village  Quarry north-east of the slimes dam For the quarries at Lemoenplaas it is recommended that Black Mountain as landowner engage with the National Roads Department and formalize a contractual agreement with them to either rehabilitate the quarries, or alternatively, should they require them in future, accepting the liability transfer provided for in MPRDA section 43(2).

For quarries which are the responsibility of BMM the following is proposed: Quarries to be backfilled with rubble generated from the demolition of mining infrastructure Quarries to be filled with 300mm topsoil and contoured

3.12.3.13 Explosive magazines

The explosive magazine area at Black Mountain is situated north of the mine security complex and east of Deeps shaft. Additionally, there is also a designated explosives destruction area south-west of the slimes dam. The following strategy should be followed for the demolition and rehabilitation activities associated with explosive magazine and incorporated into a detailed closure plan:

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Explosive magazines should be made safe prior to commencing demolition activities in accordance with applicable requirements of the Explosives Act 2003 and regulations as well as regulations published in terms of the Mine Health and Safety Act, 1996 Subsequent to making safe, a detailed site assessment should be conducted to identify and quantify all wastes and waste arisings as well as disposal options for re-usable infrastructure Dismantling and removal of saleable infrastructure Demolition of buildings and foundations and removal of rubble to identified designated disposal site Backfilling with subsoil/topsoil and contouring Vegetation establishment or alternative depending upon land use

3.12.3.14 Rehabilitation of open surface areas

A detailed report “Estimated closure costs for effective biodiversity rehabilitation at Black Mountain Mine” was prepared by Chrizette Kleynhans, Biodiversity Manager, in 2007. This report aims to address the surface rehabilitation of a total of 920 hectares of disturbed areas, within three definitive biodiversity priority zones, determined on the basis of specific biophysical priority criteria. Depending upon whether this area has a high, medium or low biodiversity priority, different re-seeding rates per hectare are applied, and the use of topsoil is integrated in most instances; R19,00/m³ for Black Mountain and R32,00/m³ for Gamsberg, extracted from the current dune reclamation area. Applying the above criteria, as well as additional rates as per the rate schedule, the total cost for the rehabilitation has been calculated at R67 414 649 at an average rate of R73 277,00/hectare. This is considered to be an accurate estimate taking into account environmental sensitivity of the area as well as other factors.

The estimate takes into account, that with the exception of access roads, the Gamsberg and Big Syncline prospecting areas, the slimes dam, Deeps shaft and the explosive magazines, the following areas will require topsoil: Swartberg areas affected by mining (18 hectares) Aggregate quarries (3 hectares) Tony‟s dam (5 hectares) Gamsberg areas affected by mining (220 hectares) Plaatjiesvlei, (40 hectares) Concentrate pads (2 hectares) Broken Hill areas affected by mining (384 hectares) Security (6 hectares) Hostels and training centre (10 hectares)

The total cost associated with providing topsoil over this area has been calculated at R60 457 000 to rehabilitate a total surface area of 688 hectares. The total topsoil requirement will be in the region of 2 617 500m³ at an average of R23,09 per m³. However, taking account of the fact that MPRDA 2002 and regulations make provision for efficient and cost-effective closure, applying topsoil over the surface area in extent of 688 hectares will not be feasible for the following reasons:  Sourcing 2 617 500m³ of topsoil to remediate disturbed areas will result in disturbance of as yet, undisturbed areas as it is not deemed possible to source all of the material from the dune sand reclamation area, taking into account backfill requirements over life of mine.

It is therefore recommended that the use of topsoil be limited to and/or optimized within the following areas where pollution of the surface is considered to be most significant Contaminated areas within the Concentrator Plant Plaatjiesvlei – estimated 28,6 hectares

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The concentrate pads Tony‟s dam Aggregate quarries With respect to rehabilitation of open surface areas, the closure plan also takes account of the following rehabilitation activities although limited, associated with open surface areas.  Removal of alien/invasive plant species  Removal of redundant water pipes and power lines including concrete plinths  Leveling of man made stormwater walls  River diversions at the Concentrator Plant and Tony‟s dam

3.12.3.15 Prospecting areas

Prospecting areas that require final rehabilitation are essentially the Big Syncline and Gamsberg areas. Historical prospecting activities at Big Syncline are however included in this quantum assessment. Prospecting activities cover an extent of approximately 3 135 hectares of which approximately 32 hectares will require rehabilitation.

3.12.3.16 Residential areas

The main residential complex is the Aggeneys Village with associated amenities and recreation facilities. The village complex is situated outside of the current mining area and it can be debated whether as such, financial provision will need to be made in terms of MPRDA requirements for demolition and final rehabilitation. Nonetheless, and irrespective of potential MPRDA 2002 encumbrances, a vested liability for the complex remains with Black Mountain in terms of the National Environmental Management Act 1998, Act 107 of 1998 (NEMA 98). For this reason it has been considered expedient to reflect this potential liability as a component of the quantum assessment. Two options are proposed for the village complex.

Option 1 Given the remote location, the current total dependence of the community on continued mining activity for sustaining the village complex, the continued sustainable utilization of the village post mining is questionable. Option 1, by no means the preferred option, even negating financial considerations, is for the entire village complex to be demolished.

Option 2 Is for the village to be integrated into the applicable local/area economic development plan and for such then to be utilized in a sustainable manner beyond life of mine. The challenge is for the village to be successfully integrated into the social development plan for Black Mountain probably including the No 2 hostel and training centre. Demolition and rehabilitation costs will then be zero, but, to protect itself, it is imperative that Black Mountain apply the liability transfer mechanism (MPRDA Section 43(2)) and sell/cede the village and probably the associated freehold to a competent third party who will then have the obligation to ensure sustainable future utilization.

3.12.3.17 Loop Ten siding

Although outside of the mining area and probably also outside the ambit of the MPRDA, Black Mountain will have the responsibility to rehabilitate Loop 10 siding.

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3.12.3.18 Saldanha Transfer complex

The same as for Loop Ten siding will apply although there is opportunity to sell the infrastructure at the complex, belonging to Black Mountain to Portnet as the infrastructure is situated on Portnet property and may be of continued use to them.

3.12.3.19 Water Pumping infrastructure

Integral to the continued existence of Aggeneys Village is the retention of the current water pumping infrastructure. It is however the property of the Pella Water Board and where situated within the Black Mountain mining area, the liability transfer mechanism should be deployed to transfer the liability to the Pella Water Board.

3.12.3.20 Conservation area south of the mine

This area is to a large extent totally undisturbed with limited rehabilitation required in some areas. Rehabilitation activities required are confined to the removal of concrete slabs and foundations over an area of approximately 1 hectare.

3.12.3.21 Rehabilitation of gravel access roads on mine property

A total of 33km of gravel roads will require rehabilitation which in essence will be confined to ripping up the compacted surfaces to enhance vegetation establishment. This excludes the gravel road along the Pella Water Board line which will in all probability be required “post-closure”.

3.12.3.22 Post-closure monitoring and management

Provision is made in this closure plan, for post closure monitoring and management of all disturbed but rehabilitated areas. Post closure monitoring and management will essentially involve the following: Vegetation succession monitoring and management Erosion monitoring and management Groundwater quality monitoring Surface run-off monitoring Monitoring and management of pollution control facilities, i.e. slimes dam paddocks, cut-off trenches etc.

3.12.3.23 LONG-TERM MANAGEMENT AND MAINTENANCE

Potential latent liabilities that may manifest themselves well beyond closure are extremely difficult to predict and or quantify in terms of financial implications. It could however, be safely assumed that most latent liabilities will be associated with the decommissioned and closed tailings dam, the Black Mountain rock dumps and the Plaatjiesvlei evaporation dam.

For assessing the financial impact a risk assessment methodology is proposed and it is also recommended that such will be incorporated into the company risk profile and provided for by means of insurance cover, or other appropriate methods of risk financing.

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4 PUBLIC PARTICIPATION

As this is an existing operation where an existing EMPR is being amended, the Interested and Affected Parties (I&APs) have already been identified and consulted with regarding the original project. Instead, this section will provide a description of the ongoing consultation with the public, including reference to any recent comments / concerns received by the mine and an indication as where they are addressed in this report. Please note that no public meetings will be held as the mine has on-going communication with the neighbouring communities as described below. 4.1 Consultation Process

4.1.1 Background Information Document

The Department of Minerals Resources (DMR) was consulted regarding the expansion of the plant and BMM was directed to carry out the public participation process. The Background Information Documents (BID) were produced and provided to the IAPs on the existing database (Appendix H). The BID was in English and Afrikaans. The purpose of a BID document was to provide IAPs with basic background information pertaining to the expansion of the plant and the amendment of the existing EMPR. It further provided members of the public interested in the project with the opportunity to register as I&APs, by completing the registration sheet included in the BID. This ensured that their names and contact details would be captured on the database and that they would receive all project-related information and invitations to forum meetings. A comment sheet was also provided to enable I&APs to furnish the consultants with written comments.

4.1.2 Key Issues Identified

Even though reminders were send to I&APs, only comments from the Department of Water Affairs (DWA) were received indicating areas of interests as being listed water use activities. These included the following: Taking water from a river; Storing of water (storage dams); Disposal of waste water (sludge, pollution dams); and River crossings. Their area of concern was on water retention system that should be checked for capacity if necessary. More information was requested for the upgrade of the plant. A letter was sent to Department of Water Affairs (DWA) clarifying all the above. 4.2 Ongoing Communication Black Mountain mine management will be responsible for ensuring that the I&APs are kept informed of environmental developments on the mine property. Regular (recommended to be twice yearly) meetings will be held with I&APs at the mine. These meetings will permit mine management to report back on environmental issues, answer queries, and identify possible areas of concern.

4.2.1 Complaints

The mine maintains a record of all complaints received from I&APs, recording the following information: The complaint; The corrective action implemented (if any) and ; Appropriate dates.

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4.2.2 List of Interested and Affected Parties

The following I&APs categories were identified for Black Mountain Mine: Conservation bodies and NGOs; Community Forums and community; Companies; Farmers; and Government Departments and Municipalities. A list of I&APs identified and consulted with during the public participation process is provided in Appendix I.

Black Mountain mine management will be responsible for ensuring that the I&APs are kept informed of environmental developments on the mine property. Regular (recommended to be twice yearly) meetings will be held with I&APs at the mine. These meetings will permit mine management to report back on environmental issues, answer queries, and identify possible areas of concern.

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5 METHODS USED TO UNDERTAKE THE IMPACT ASSESSMENT

5.1 Legal Requirements The ranking system developed to identify the significance of the impacts created as a result of the mining operations has been developed to take cognisance of the requirements of the Mineral and Petroleum Resources Act (MPRDA). For the purpose of this report, the significance of impacts will be determined through the implementation of the following impact assessment model: This system procedure assesses the impact potential of current activities, products and/or services and also takes into account the possibility of previous practices causing impact now, or in the future. Impact on the environment comprises pollution and the use of resources, legal and regulatory requirements, material damage, reputation / social / community (RSC) impacts. Environmental risk can change considerably under different operating conditions and circumstances. Therefore, to provide control at all times this system procedure considers the significance of environmental aspects under: Normal operating conditions; Abnormal situations involving some change from normal conditions (start up / close off); and Potential emergency situations. This procedure produces a list of the high risks to manage and indicate significant aspects to indicate their relative importance to the environment and the organization. The significant aspects identified are used to update operating procedures and to establish objectives and targets for environmental improvement during annual review. 5.2 Definitions The terms environment, activity, aspect and impact, will be used technically throughout this document, and so it is important to explain what is meant by each term in the context of the EIA. Environment (as defined in NEMA): The surroundings within which humans exist and that are made up of: o the land, water and atmosphere of the earth; o micro-organisms, plant and animal life; o any part or combination of the above, and the interrelationships among and between them; and o the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and wellbeing; Activity: A specific deed, action or function, that takes place at the BMM (as described in Section 1 of this report), such as; o Drilling and blasting. o Flotation. o Waste management. Environmental Aspect: Element of an organization‟s activities, products or services that can interact with the environment. Significant environmental aspect: An environmental aspect that has or can have a significant environmental impact on the environment. Environmental Impact: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization‟s activities, products or services. Risk: Risk is defined as the uncertainty or expectation of an event‟s outcome that could impact on business objectives. Risk Management: Risk Management is a management system designed to help line managers identify, understand and manage risks, for the purpose of improving decisions and ensuring business objectives are achieved. Review Cycle: AAWR: “As and when required”.

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5.2.1 Criteria to Consider when Determining Severity of impacts

The ranking of impacts / determination of significance is estimated using two criteria, namely Consequence and Probability. These consider the contributing factors / criteria listed in the legislation. The definitions of each are provided below. The Consequence of an impact resulting from an aspect is expressed as a combination of: Nature of impact: An indication of the extent of the damage (negative impacts) or benefit (positive impacts) the impact inflicts on natural, cultural, and/or social functions (environment). Extent of impact: A spatial indication of the area impacted (i.e. how far from activity the impact is realised). Duration of impact: A temporal indication of the how long the effects of the impact will persist, assuming the activity creating the impact ceases. For example, the impact of noise is short lived (impact ceases when activity ceases) whereas the impact of removing topsoil exists for a much longer period of time. Frequency of the impact occurring: An indication of how often an aspect, as a result of a particular activity, is likely to occur. Note that this does not assess how often the impact occurs. It applies only to the aspect. For example blasting takes place monthly and haulage daily while the resultant frequency of the impacts occurring will vary based on a number of factors. 5.3 Explanation of Impact Rating

5.3.1 Probability and Likelihood

The Probability of an impact resulting from an aspect is expressed as: Probability of impact occurring: An estimated indication of the potential for an impact to occur. Scores are assigned to each the criteria, as outlined in Table 5-1. The scoring range in Table 5-2 has been selected to represent the scale in which varying impacts can occur. The combination of scores is then used to determine the Consequence and Probability, as shown below.

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Table 5-1: Scoring for environment impact assessment criteria.

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The Significance of an impact: Significance is an indication of how serious a negative impact is anticipated to be and how beneficial a positive impact may be. Significance is considered to be Extremely High, High, Medium, or Low (as in the Impact Significance in Table Error! Reference source not found. below). The actions are allocated for each classification below and focus on the need for mitigation or management. Table 5-2: Impact Significance

Significance:

Colour Descriptor Action Sign-off

Eliminate, avoid, immediate Ex – Extremely High GM – Risk Owner action

H – High Proactively manage HOD – Risk Manager

Section manager – Team M – Medium Actively manage member

L – Low Ensure levels of controls Supervisor – Team member

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6 IMPACT ASSESSMENT

This section provides a summary of the impacts evaluated for each of the various activities presented in Section 1. When considering the impact assessment in this section, it must be stressed that the significance ranking is calculated assuming NO management measures have been implemented. 6.1 Impact Assessment of Mining Process The impact assessment is presented in tabular format per impact of concern.

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6.1.1 Impact assessment during Exploration drilling surface

IMPACT IMPACT ANALYSIS ASSESSMENT RATING ACTIVITY or PROCESS or

SERVICE

Input

Output Impact ity

(Normal – Abnormal – Emergency)

Sever Probability Raw Impact estimation Site identification Vehicles driving in veld to access the Biodiversity Physical disturbance of natural veld and damage to B G H proposed drill site vegetation

Site identification Carbon emissions due to internal combustion Air Contribution to climate change D J H of fuel

Site establishment Vehicles driving in veld to access the Land Extended Footprint B H H proposed drill site

Site establishment Vehicles driving in veld to access the Biodiversity Biodiversity Loss B I Ex proposed drill site

Site establishment Vehicles having to cross undisturbed veld Biodiversity Biodiversity loss B F M area due to emergency evacuation

Site establishment Sudden abnormal high rain event cause Soil and land Potential erosions B G H erosion of road

Site establishment Sudden abnormal high rain event cause Land (P) Drilling sludge isolated from natural system B F M flooding of sumps

Site establishment Clearing of vegetation to establish drill site Biodiversity Biodiversity loss C J H

Site establishment Topsoil removed from sump area is replaced Soil and land (P) Topsoil replaced for rehabilitation D F L

Site establishment and Drilling Drill mud is lost to ground water during Ground water Ground Water Contamination B G H

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IMPACT IMPACT ANALYSIS ASSESSMENT RATING ACTIVITY or PROCESS or

SERVICE

Input

Output Impact ity

(Normal – Abnormal – Emergency)

Sever Probability Raw Impact estimation drilling

Site establishment People work and operate in area for Environment Environmental pollution D H M prolonged periods

Site access and drilling Materials such as drilling mud etc. is used Environment Environmental pollution D G L operation

Drilling Use of drilling mud during drilling operations Water Under ground water pollution B H H

Storage of fuel and lubricants Holing of oil, grease and fuel drums/cans Water Water Contamination B I Ex for drill rigs

Operation of drill rigs Mechanical failure of equipment Water Water Contamination B G H

Refuelling and applying Spills during refueling operations Soil and land Residual impact on soil due to hydrocarbons when C H H lubricants water is pumped to Plaatjiesvlei

Operation of drill rigs Resource use Use of resource B H H

Combustion of fuel in internal Emission of combustion gasses Air Air pollution D j M combustion engine and drill drives

Combustion of fuel in internal Combustion cause heat release Air Air pollution D J M combustion engine and drill drives

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IMPACT IMPACT ANALYSIS ASSESSMENT RATING ACTIVITY or PROCESS or

SERVICE

Input

Output Impact ity

(Normal – Abnormal – Emergency)

Sever Probability Raw Impact estimation Drilling Generation of noise during drilling Air Air pollution C J H

Drilling Operation Use of water during drilling Consumption of resource B H H

Drilling Drill cores removed during drilling Exposure of mineralised rock to oxygen with potential B H H for heavy metal release

Operation of drill rigs Oil mix with water during drilling Water Contamination of water reticulation B H H

Storage of fuel and lubricants Failure of storage capacity Water Water Contamination B I Ex for drill rigs

Pumping drilling water to Water Environment Contamination of surrounding environment B H H sump

Pumping drilling water to water Soil and land Erosion of topsoil due to water flow C H H sump

Failure of drill sludge sludge Environment Contamination of surrounding environment B I Ex isolation system (cement furrows and dams)

Failure of drill sludge sludge Soil and land Chemical and structural changes to ground B I Ex isolation system (cement furrows and dams) Decommissioning of Drill Site drill Biodiversity Disturbance of animal life D J H

6.1.2 Impact Assessment for Underground Mining

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IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Face Preparations Use of machinery Noise Environmental nuisance C F M Face Preparations Use of machinery Carbon emissions Air pollution C J H Face Preparations Use of machinery Heat Fossil fuel consumption D J H Face Preparations Breakdown of machinery Oil spills Water contamination D J H Face Preparations Use of machinery Dust Air pollution D I M Face Preparations Washing of face Waste Water Water contamination D J H Waste brushes / Face Preparations Face marking General waste accumulation C J H containers Face Preparations Face marking Paint spillage Water contamination D J H Face Preparations Use or transport vehicles Oil spills Water contamination D J H Face Preparations Use of transport vehicles Carbon emissions Air pollution D J H Face Preparations Use of transport vehicles Noise Environmental nuisance D J H Drilling Use of drilling machines Noise Environmental nuisance C F M Drilling Breakdown of machinery Oil spills Water contamination D J H Drilling Use of drilling machines Dust Air pollution D J H Drilling Drilling of face Waste drill bits Waste accumulation D J H Drilling Drilling of face Old drill steel Waste accumulation D J H Drilling Drilling of face Drill steel Salvageable materials D J H Drilling Use of drilling machines Old hoses Waste accumulation D J H Drilling Drilling operation Waste water Water contamination D J H Drilling Use of compressed air Noise Environmental nuisance C F M Drilling Use of compressed air Dust Air pollution D J H Raise bore Drilling of raise bore holes Oil spills Water contamination D J H Explosive Charging up and Blasting Charging operations Waste accumulation D J H Packaging Washing of old explosives to remove Redundant Charging up and Blasting Water contamination D J H ammonium nitrate with diesel base. Explosives Redundant Accumulation of redundant explosives out of Charging up and Blasting Misfires and/or old stock underground. D G L Explosives procedure and in areas not demarcated for it.

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IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Contaminated Underground water enter mine workings and Charging up and Blasting Charging and blasting operations C F M groundwater becomes contaminated with exposed ore. Shock and Charging up and Blasting Blasting operations Earth tremors. D F L vibrations Charging up and Blasting Blasting operations Dust Air and Water contamination D J H Charging up and Blasting Blasting operations release nitrous fumes Gases & Fumes Air pollution D J H Charging up and Blasting Use of machinery Fumes Air pollution D J H Charging up and Blasting Use of machinery Heat Fossil fuel consumption D J H Charging up and Blasting Breakdown of machinery Oil spills Water contamination D J H Charging up and Blasting Use of machinery Dust Air pollution D J H Charging up and Blasting Blasting Operations Ore Ore Generation A J Ex Making Safe and Loading Use of machinery Oil spills Water contamination D J H Making Safe and Loading Use of machinery Noise Environmental nuisance D J H Heat and Resource Making Safe and Loading Use of machinery Fossil fuel consumption D J H use Making Safe and Loading Use of machinery Dust Air pollution D J H Making Safe and Loading Use of machinery Carbon Emissions Air pollution D J H Making Safe and Loading Loading and tipping operations Ore Dust Air and soil pollution D J H Breakdown of machinery Loss of natural resource not used for processing Making Safe and Loading Ore Spills D F L Malfunction of equipment and product. Making Safe and Loading Waste packing and handling operations Waste Rock Piles Waste material underground D H M Making Safe and Loading Waste packing and handling operations Waste Air pollution affecting third party passing by D J H Cleaning Use of tools and equipment Scrap Waste Waste accumulation at Black Mountain. D F L Cleaning Face cleaning result in waste produced. Waste Rock Piles Water and Water contamination. D H M Cleaning Waste packing and handling operations Dust Air pollution affecting third party passing by. D J H Ore faces cleaned / loaded and ore is Water and Water contamination. Cleaning Ore A J Ex released for tipping Natural resource not used for processing and product. Breakdown of machinery Loss of natural resource not used for processing Cleaning Ore Spills D F L Malfunction of equipment and product.

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IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Cleaning Use of electricity Heat Fossil fuel consumption D J H Cleaning Use of machinery Noise Environmental nuisance D J H Cleaning Use of machinery Carbon emissions Air pollution D J H Heat and Resource Cleaning Use of machinery Fossil fuel consumption D J H use Cleaning Breakdown of machinery Oil spills Water contamination D J H Cleaning Use of machinery Dust Air pollution D J H Tipping Use of machinery Carbon emissions Air pollution D J H Tramming Use of machinery Resource Use Resource consumption D J H Tramming Use of machinery Noise Environmental Nuisance D J H Tramming Use of machinery Heat Environmental nuisance D J H Tramming Storage of fuel underground Diesel Spill Soil & water contamination B J Ex Tramming Refuelling of equipment Diesel Spill Soil & water contamination C J H Tramming Equipment failure Oil spills Soil & water contamination C J H Breakdown of machinery Loss of natural resource not used for processing Tramming Ore Spills D F L Malfunction of equipment and product. Use of machinery Tipping Ore dust Air pollution D J H Tipping operations Water and Water contamination. Natural resource not Tipping Tipping operations Ore D F L used for processing and product. Water and Water contamination. Natural resource Tipping Breakdown of machinery Ore Spills D F L not used for processing and product. Tipping Waste packing and handling operations Waste Rock Piles Water and Water contamination. D F L Use of machinery Tipping Dust Air pollution D J H Tipping operations Tipping Use of electricity for fans Heat Fossil fuel consumption D J H Tipping Use of machinery Noise Environmental nuisance D J H Tipping Use of machinery Dust Air pollution. Environmental nuisance. D J H

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6.1.3 Impact assessment during ore handling Deeps Underground, Surface Conveyors, Waste Rock Dump & Tony’s dam

Impact Assessment IMPACT ANALYSIS

Rating

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Heat and resource Rock Breaking Use of Machinery Fossil fuel consumption. Localised heat released. D J H consumption Rock Breaking Generation of noise with machines operating Noise Environmental Nuisance D F L Rock Breaking Oil Spills during transporting Oil spills Contaminated Soil D F L Oil Spills cleaned up as detected during Rock Breaking Hazardous waste Soil and Water contamination D H M normal use of transport vehicle Rock Breaking Generation of dust with rock breaking Dust Third party impact D J H Rock Breaking Generation of dust with rock breaking Dust Air pollution and environmental nuisance D J H ore rock underground has limited impact except for ore rock generated with rock breaking from Rock Breaking Ore Rock possible acidification of water if groundwater interacts C G M blasted stopes with exposed ore rock with high sulphate composition. ore rock generated with rock breaking from Rock Breaking Ore Rock Possible housekeeping incidents C H H blasted stopes Crushing Use of Machinery Heat Fossil fuel consumption. Localised heat released. D J H Crushing Generation of noise with machines operating Noise Environmental Nuisance D F L Crushing Oil Spills during crushing Oil spills Contaminated Soil D J H Oil Spills cleaned up as detected during Crushing Hazardous waste Contaminated Waste on site D J H normal use of crusher Crushing Generation of dust with rock breaking Dust Third party impact D J H Crushing Generation of dust with rock breaking Dust Air pollution and environmental nuisance D J H ore rock underground has limited impact except for ore rock generated with rock breaking from Crushing Ore Rock possible acidification of water if groundwater interacts C G M blasted stopes with exposed ore rock with high sulphate composition. ore rock generated with rock breaking from Crushing Ore Rock Possible housekeeping incidents C H H blasted stopes Dust from conveying and ore rock fall-out at Conveying Dust Third party impact D J H conveyor. Conveying Dust from conveying and ore rock fall-out at Dust Air pollution and environmental nuisance D J H

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Impact Assessment IMPACT ANALYSIS

Rating

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw conveyor. Waste conveyor belts from belt repairs Land capability reduced with equipment waste Conveying Waste belt C G M and maintenance material and accumulation on site Waste parts from belt repairs and Land capability reduced with equipment waste Conveying Scrap Metal C F M maintenance material and accumulation on site Dust from conveying and ore rock fall-out at Housekeeping issues that can result in other safety, Conveying ore Rock Spillage D J H conveyor. health, environmental incidents ore rock spillage from conveyor Housekeeping issues that can result in other Conveying ore Rock Spillage D J H breakdown safety, health, environmental incidents Heat and resource Conveying Electricity used for conveying Fossil fuel consumption. Localised heat released. D J H consumption Conveying Generation of noise with conveyor operating Noise Environmental Nuisance D F H Spills or leaks from conveyor running and Continual small spills resulting in accumulated Conveying Oil spills D J H grease heating up and spilling. soil contamination underground Spills from conveyor drive motor Conveying Oil spills Soil contamination D J H breakdown, repairs and maintenance Underground staff could have increased dust levels Hoisting Dust generated from hoisting Dust underground if windblown dust from hoisting enters C I H ventilation shafts. Third parties could be affected by dust on Deeps Hoisting Dust generated from hoisting Dust D H M platform and office area. Hoisting Waste dust from hauling ore by winder Dust Dust mixing with topsoil causing change in soil quality C H H Hoisting Generation of noise with Hoisting ore rock Noise Environmental Nuisance D F H Ore spills on surface, mixing with topsoil and causing Hoisting Ore spills occur during hauling and tipping. ore Rock Spillage C J H change in soil quality Hoisting Noise from winder operating Noise Environmental Nuisance D F L Rope grease spills with normal operating of Hoisting Grease spills Contaminated Soil D G L winder Hoisting Transformer oil leakage from transformers. Oil spills Contaminated Soil D F L Hoisting Transformer oil leakage from transformers. Oil spills Hazardous waste produced on site. C H H

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Impact Assessment IMPACT ANALYSIS

Rating

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Hoisting Transformer oil leakage from transformers. Oil spills Hazardous waste produced on site. D H M Resource Consumption of electricity causing greenhouse gas Hoisting Resource Consumption C J H consumption emissions at Eskom Overland Dust from conveying and ore rock fall-out at Soil structure and composition changes with impact Fine ore C J H Conveying conveyor. on future rehabilitation and land capability Overland Dust from conveying and ore rock fall-out at Soil structure and composition changes with impact ore Rock fall-out C G M Conveying conveyor. on future rehabilitation and land capability Overland Waste conveyor belts from belt repairs Land capability reduced with equipment waste Waste belt C F M Conveying and maintenance material and accumulation on site Overland Waste parts from belt repairs and Land capability reduced with equipment waste Scrap Metal D J H Conveying maintenance material and accumulation on site Overland Dust from conveying and ore rock fall-out at Housekeeping issues that can result in other safety, ore Rock Spillage D J H Conveying conveyor. health, environmental incidents Overland Electricity used for conveying Heat Fossil fuel consumption. Localised heat released. D J H Conveying Overland Generation of noise with conveyor operating Noise Environmental Nuisance D J H Conveying Overland Spills or leaks from conveyor running and Continual small spills resulting in accumulated Oil spills D J H Conveying grease heating up and spilling. soil contamination underground Overland Spills from conveyor drive motor Oil spills Soil contamination D J H Conveying breakdown, repairs and maintenance Impact on road infrastructure and extension of ore Ore Stock piling ore Rock dump wall failure Stockpiled ore B F M rock footprint Ore Stock piling Ore stockpiled for production of concentrate Ore Rock Ore for plant to process B J Ex Legal non compliance of MPDRA which does not Ore rock used for construction outside Ore Stock piling Ore Rock allow any material with acid rock drainage B J Ex demarcated ore rock areas. potential to be used for construction Oil Spills during operating of machines Contaminated ore rock with possible seepage to Ore Stock piling Oil spills D J H on ore rock dump surface and ground water

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Impact Assessment IMPACT ANALYSIS

Rating

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Ore rock beyond minimum hydrocarbon standard Oil Spills during operating of machines Ore Stock piling Oil spills will prevent its use as rock cladding of tailings C H H on waste rock dump dam at closure. Oil Spills cleaned up as detected during Ore Stock piling Oil spills Contaminated ore on site D J H normal use of crusher Ore Stock piling Use of Machinery Carbon emissions Fossil fuel consumption. Localised heat released. D J H Ore Stock piling Generation of noise with machines operating Noise Environmental Nuisance D J H Ore Stock piling Generation of dust with rock breaking Dust Third party impact D J H Ore Stock piling Generation of dust with rock breaking Dust Air pollution and environmental nuisance D J H Scrap metal lost from machinery with Land capability reduced with equipment ore Ore Stock piling Scrap metal C F M breakdown on ore rock dump. material and accumulation on site Surface water pollution and soil acidification that Rain water running over ore rock dump Ore Stock piling Dirty water could affect land capability. Local public concern by B H H surface. landowners affected. Ground water pollution because of acidification. Local Rain water running over ore rock dump Ore Stock piling Dirty water to regional public concern where more than one B H H surface and seepage to groundwater. landowner could be affected. Ore Stock piling Windblown dust from ore rock dump Dust Soil contamination C G M Establishment and extension of ore rock Ore Stock piling Ore rock on surface Biodiversity loss B J Ex dump Establishment and extension of ore rock Ore Stock piling Ore rock on surface Footprint extension B J Ex dump ore delivered to ore rock dump by Housekeeping issues that can result in other safety, Ore Stock piling Mixed waste D J H contracting or permanent staff health, environmental incidents Reduced acid rock drainage from rainwater mixing Ore Stock piling Building rubble delivered to waste rock dump Waste Cement D F L with building rubble. Dewatering Water contain suspended solids Process water Siltation of dams D J H Overflow water from UG dams flow down Dewatering Silt & Mud Silting of dams C H H decline and erode decline.

6.2 Impact Assessment for Crushing

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IMPACT Impact Analysis ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output IMPACT

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Receiving ore tripper car and Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H conveyor Receiving ore tripper car and Generation of noise with machines operating Noise Environmental Nuisance D G L conveyor Receiving ore tripper car and Waste equipment generated with Land capability reduced with equipment waste Equipment waste D J H conveyor maintenance of machines material and accumulation on site Air pollution because of air borne particles. by 9% Receiving ore tripper car and Ore dust from handling, transporting , Ore Dust lead, 4% zinc, 0.5% Copper of random sample taken B H H conveyor processing ore and environmental nuisance. Soil Contamination Receiving ore tripper car Breakdown of machinery, Malfunction of Ore Spillage Soil Contamination, Housekeeping D F L and conveyor equipment

Receiving ore tripper car Used lubricating oil generated during Land capability reduced with hazardous waste Used oil C H H and conveyor maintenance material on site

Receiving ore tripper car Used lubricating oil generated during Used oil Depletion of non-renewable natural resources D I M and conveyor maintenance Oil contaminated Waste generated during Receiving ore tripper car Oil contaminated Land capability reduced with hazardous waste removal and application of oil/grease with C G M and conveyor Waste material on site maintenance Receiving ore tripper car Waste Conveyor Land capability reduced with waste material on Conveyor Belt Break down D I M and conveyor Belts site Receiving ore tripper car and Ore contaminated with mixed waste (plastic, wood, Scrap imported from underground mining Scrap in ore C J H conveyor PPE, steel) Coarse ore storage Use of Electricity for level indicators Heat Fossil fuel consumption. Localised heat released. D J H Air pollution by 9% lead, 4% zinc, 0.5% Copper of Coarse ore storage Ore dust from ore dumping into the silo Ore Dust random sample taken and environmental nuisance. B G H Soil Contamination Waste Conveyor Land capability reduced with waste material on Ore conveying Conveyor Belt Break down D I M Belts site

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IMPACT Impact Analysis ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output IMPACT

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Ore conveying Use of Electricity for level indicators Heat Fossil fuel consumption. Localised heat released. D J H Air pollution by 9% lead, 4% zinc, 0.5% Copper of Ore conveying Ore dust from conveying Ore Dust random sample taken and environmental nuisance. B G H Soil Contamination Ore conveying Generation of noise with machines operating Noise Environmental Nuisance D G L Waste equipment generated with Land capability reduced with equipment waste Ore conveying Equipment waste D J H maintenance of machines material and accumulation on site Oil contaminated Waste generated during Oil contaminated Land capability reduced with hazardous waste Ore conveying removal and application of oil/grease with C G M Waste material on site maintenance Used lubricating oil generated during Land capability reduced with hazardous waste Ore conveying Used oil C H H maintenance material on site Used lubricating oil generated during Ore conveying Used oil Depletion of non-renewable natural resources D I M maintenance Oil contaminated Waste generated during Oil contaminated Land capability reduced with hazardous waste Ore conveying removal and application of oil/grease with C G M Waste material on site maintenance Ore contaminated with mixed waste (plastic, wood, Ore conveying Scrap imported from underground mining Scrap in ore C J H PPE, steel) Crushing & Lubricating Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H Crushing & Lubricating Generation of noise with machines operating Noise Environmental Nuisance D G L Waste equipment generated with Land capability reduced with equipment waste Crushing & Lubricating Equipment waste D J H maintenance of machines material and accumulation on site Air pollution by 9% lead, 4% zinc, 0.5% Copper of Ore dust from handling, transporting, Crushing & Lubricating Ore Dust random sample taken and environmental B H H processing ore nuisance. Soil Contamination Breakdown of machinery, Malfunction of Crushing & Lubricating Ore Spillage Soil Contamination, Housekeeping D F L equipment

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IMPACT Impact Analysis ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output IMPACT

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Used lubricating oil generated during Land capability reduced with hazardous waste Crushing & Lubricating Used oil C H H maintenance material on site Used lubricating oil generated during Crushing & Lubricating Used oil Depletion of non-renewable natural resources D I M maintenance Oil contaminated Waste generated during Oil contaminated Land capability reduced with hazardous waste Crushing & Lubricating removal and application of oil/grease with C G M Waste material on site maintenance Oil spillage on ore due to lubrication Ore contamination in closed system. Only Crushing & Lubricating pump flow rates too high, oil leaks or Oil Spillage D F L affecting float results equipment damage Ore contaminated with mixed waste (plastic, wood, Crushing & Lubricating Scrap imported from underground mining Scrap in ore C J H PPE, steel) Used lubricating oil generated during Crushing & Lubricating Recycled oil Depletion of non-renewable natural resources D I M maintenance put through oil separator Produced with oil separator functioning at Land capability reduced with hazardous waste Crushing & Lubricating Hazardous Waste D G L workshop material and accumulation on site. Produced with oil separator functioning at Crushing & Lubricating Separated water Polluted water D G L workshop Produced with oil separator functioning at Soil pollution. Loss of topsoil. Increased Crushing & Lubricating Contaminated Silt D F L workshop hazardous waste on site Degreasers used in cleaning workshop Land capability reduced with hazardous waste Crushing & Lubricating Hazardous Waste D F L equipment material on site Fine ore storage Use of Electricity for level indicators Heat Fossil fuel consumption. Localised heat released. D J H Air pollution by 9% lead, 4% zinc, 0.5% Copper of Fine ore storage Ore dust from ore dumping into the silo Ore Dust random sample taken and environmental nuisance. B I Ex Soil Contamination

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6.3 Impact Assessment for Milling and Aeration

IMPACT IMPACT ANALYSIS ASSESSMENT

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Raw Fine Ore Conveying Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H Air pollution and environmental nuisance. Soil Fine Ore Conveying Ore dust from transferring and conveying Ore dust B H H Contamination Breakdown of machinery, Malfunction of Fine Ore Conveying Ore Spillage Housekeeping D H M equipment Breakdown of machinery, Malfunction of Fine Ore Conveying Ore Spillage Soil Contamination, C F M equipment Fine Ore Conveying Waste Water released during cleaning Waste water Water resources use. D J H Oil Spills during transport of oil and Fine Ore Conveying Oil spills Contaminated Soil D F L application Oil contaminated Waste generated during Oil contaminated Land capability reduced with hazardous waste Fine Ore Conveying removal and application of oil/grease with C H H Waste material on site maintenance Fine Ore Conveying Generation of noise with machines operating Noise Environmental Nuisance D G L Waste equipment generated with Land capability reduced with equipment waste Fine Ore Conveying Equipment waste D J H maintenance of machines material and accumulation on site Waste equipment generated with Land capability reduced with equipment waste Fine Ore Conveying Scrap Waste D J H maintenance of machines material and accumulation on site Milling and Lubrication Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H Hazardous Waste Generated with lime Land capability reduced with hazardous waste Milling and Lubrication Chemical Waste D F L handling and processing material on site Oil contaminated Waste generated during Oil contaminated Land capability reduced with hazardous waste Milling and Lubrication removal and application of oil/grease with C H H Waste material on site maintenance Waste Water Release during Milling and Milling and Lubrication Waste water Reduced water quality of available water D J H Gland Service Milling and Lubrication Waste Water Release during Milling and Waste water Waste Water accumulation on site D F L

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IMPACT IMPACT ANALYSIS ASSESSMENT

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Raw Gland Service Used lubricating oil generated during Land capability reduced with hazardous waste Milling and Lubrication Used oil D G L maintenance material on site Used lubricating oil generated during Milling and Lubrication Used oil Depletion of non-renewable natural resources D I M maintenance Girth gear dressing waste generated Land capability reduced with hazardous waste Milling and Lubrication Grease D G L while lubricating gears. material on site Waste equipment generated with Land capability reduced with equipment waste Milling and Lubrication Equipment waste D J H maintenance of machines material and accumulation on site Milling and Lubrication Generation of noise with machines operating Noise Environmental Nuisance D G L Air pollution and environmental nuisance. Soil Milling and Lubrication Ore dust from transferring and conveying Ore dust B H H Contamination Breakdown of machinery, Malfunction of Milling and Lubrication Ore Spillage Housekeeping D H M equipment Breakdown of machinery, Malfunction of Milling and Lubrication Ore Spillage Soil Contamination, C F M equipment Slurry spillage causing contaminated soil / water / Milling and Lubrication Cyclone feed produced after Milling Cyclone feed D F L biodiversity loss. Milling and Lubrication Normal operating of mass flow meters Radioactive Source Localised radiation impact on third parties B G H Waste equipment generated with Land capability reduced with equipment waste Cycloning Scrap Waste D J H maintenance of machines material and accumulation on site Waste water produced with washing work Cycloning Waste water Reduced water quality of available water D J H areas. Slurry spillage causing contaminated soil / water / Cycloning Flotation feed from cyclone overflow Flotation feed D F L biodiversity loss. Breakdown of machinery, Malfunction of Cycloning Ore Spillage Housekeeping D H M equipment Cycloning Breakdown of machinery, Malfunction of Ore Spillage Soil Contamination, C F M

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IMPACT IMPACT ANALYSIS ASSESSMENT

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Raw equipment Cycloning Normal operating of mass flow meters Radioactive Source Localised radiation impact on third parties B G H Cycloning Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H Magnetic Separation Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H Slurry spillage causing contaminated soil / water / Magnetic Separation Flotation feed from cyclone overflow Flotation feed D F L biodiversity loss. Magnetic Separation Normal operating of mass flow meters Radioactive Source Localised radiation impact on third parties B G H Magnetic Separation Waste Water Release as part of process Waste water Water quality reduced. D F L Magnetic Separation Waste Water Release as part of process Waste water Waste Water accumulation on site B F M Waste equipment generated with Land capability reduced with equipment waste Magnetic Separation Equipment waste D J H maintenance of machines material and accumulation on site Slurry spillage due to pipeline failure & Magnetic Separation Slurry Slurry contaminated clean storm water area B F M flotation process Slurry spillage due to pipeline failure & Biodiversity Loss, Topsoil loss / Soil Magnetic Separation Slurry B F M flotation process contamination. Slurry spillage due to pipeline failure & Magnetic Separation Slurry Slurry seepage to ground water A F H flotation process Magnetic Separation Noise from compressed air Noise Environmental Nuisance D J H Replacement of covered steel during Polyurethane Unsalvageable equipment waste. Accumulation Magnetic Separation D J H maintenance covered steel on site Aeration Noise from compressed air Noise Environmental Nuisance D J H Aeration Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H Replacement of covered steel during Polyurethane Unsalvageable equipment waste. Accumulation Aeration D J H maintenance covered steel on site Aeration Normal operating of mass flow meters Radioactive Source Localised radiation impact on third parties B G H

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6.4 Impact Assessment for Flotation, Thickening and Filtration

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Flotation Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H Radiation generated when courier analyser Flotation Radiation (X-Ray) Radiation on ecosystem functioning and people B G H is used Flotation Noise from compressed air. Noise Environmental Nuisance D F L Flotation Breakage of air piping. Noise Environmental Nuisance B F M Slurry spillage resulting in biodiversity loss, Flotation Slurry from processing Slurry contaminated soil, topsoil loss, storm water mixing, B F M seepage to ground water Waste water from washing floors and dilution Flotation Waste Water Water quality reduced C I H / spray water use. Waste water from washing floors and dilution Flotation Waste Water Waste Water accumulation on site C H H / spray water use. Oil contaminated Waste generated during Oil contaminated Land capability reduced with hazardous waste Flotation C H H application Waste material on site Waste equipment generated with Land capability reduced with equipment waste Flotation Equipment Waste C F M maintenance of machines material and accumulation on site Spills generated during servicing and/or Petrochemical Flotation Contaminated Soil & Waste D J H failure of courier analyser Spills Waste Water spillage due to pipeline Flotation Waste Water Contaminated clean storm water area B F M failure Waste Water spillage due to pipeline Flotation Waste Water Biodiversity Loss B F M failure Oil Spills during transport of oil and Flotation Oil Spills Contaminated Soil D F L application Environmental Emergency due to Flotation Reagent Spills Toxic material release to ecosystem and people A F H operational or system failure Flotation Slurry spillage due to pipeline failure Slurry Slurry contaminated clean storm water area B F M

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 113

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Flotation Slurry spillage due to pipeline failure Slurry Biodiversity Loss B F M Flotation Slurry spillage due to pipeline failure Slurry Slurry seepage to ground water A F H Thickening Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H Oil contaminated Waste generated during Oil contaminated Land capability reduced with hazardous waste Thickening C H H application Waste material on site Waste equipment generated with Land capability reduced with equipment waste Thickening Equipment Waste D J H maintenance of machines material and accumulation on site Oil Spills during transport of oil and Thickening Oil Spills Contaminated Soil D F L application Thickener overflow Thickening Waste Water Release as part of process Reduced water quality of available water C F M water Thickener overflow Thickening Waste Water Release as part of process Waste Water accumulation on site C J H water Thickening Product to filters. Concentrate liquid Soil contamination as a result of spillage D H M Filtration Use of Electricity Heat Fossil fuel consumption. Localised heat released. D J H Filtration Compressed Air & Air release. Noise Environmental nuisance D F L During processing & concentrate Concentrate Filtration Soil contamination D J H handling Spillage Waste equipment generated with Land capability reduced with equipment waste Filtration Equipment Waste D J H maintenance of machines material and accumulation on site Breaking of cones valves and pipelines Concentrate Filtration Soil contamination B F M and strainer boxes. Spillage Oil Spills during transport of oil and Filtration Oil Spills Contaminated Soil D F L application Oil contaminated Waste generated during Oil contaminated Land capability reduced with hazardous waste Filtration C H H application Waste material on site Used lubricating oil generated during Land capability reduced with hazardous waste Filtration Used oil C H H maintenance material on site Filtration Used lubricating oil generated during Used oil Depletion of non-renewable natural resources D J H

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 114

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw maintenance

6.5 Impact Assessment for Tailings Dam

IMPACT ANALYSIS IMPACT ASSESSMENT RATING

ACTIVITY or PROCESS or Input SERVICE Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Slurry deposition Slurry spillage due to pipeline failure Slurry spills Slurry contaminated clean storm water area B H H Slurry deposition Slurry spillage due to pipeline failure Slurry spills Biodiversity Loss B H H Slurry deposition Slurry spillage due to pipeline failure Slurry spills Slurry seepage to ground water A H Ex Slurry and clean topsoil mixed during Soil contamination and reduced land capability for Slurry deposition Contaminated Soil C H H spillage future use by plants Slurry deposition Windblown slurry dust from tailings dam Slurry dust when dry Air pollution. D J H Slurry deposition Windblown slurry dust from tailings dam Slurry dust when dry Dust as environmental nuisance D J H Slurry deposition Windblown slurry dust from tailings dam Slurry dust when dry Third party passing by persons affected B J Ex Natural veldt outside tailings dam area dust laden Slurry deposition Windblown slurry dust from tailings dam Slurry dust when dry B J Ex causing soil contamination Slurry deposition Generation of dust with machines operating Slurry dust when dry Air pollution and environmental nuisance D G L Natural veldt outside tailings dam area dust laden Slurry deposition Windblown slurry dust from old spillages Contaminated Soil C J H causing soil contamination Seepage to Slurry deposition Tailings dam facility is unlined Ground water pollution A G H Groundwater Supply pipelines, pizometers and fittings Slurry deposition Scrap Waste Salvageable materials on site D J H redundant during use. Supply pipelines, pizometers and fittings Unsalvageable equipment waste. Accumulation on Slurry deposition Scrap Waste D J H redundant during use. site Slurry deposition Oil Spills during transporting Oil spills Contaminated Soil D I M

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 115

IMPACT ANALYSIS IMPACT ASSESSMENT RATING

ACTIVITY or PROCESS or Input SERVICE Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Slurry deposition Fumes from vehicles Carbon emissions Air pollution by greenhouse gasses D J H Process water collected on top of tailings Overflow of collection water on tailings dam run off Slurry deposition Process water A F H dam at penstock outside tailings dam. Process water deposited at wall of tailings Slurry deposition Process water Process water causing erosion B F M dam Soil contamination and reduced land capability for Slurry deposition Site spills at Tailings dam Contaminated Soil C I H future use by plants Slurry to Backfill Slurry spillage due to pipeline failure Slurry spills Slurry contaminated clean storm water area B G H Slurry to Backfill Slurry spillage due to pipeline failure Slurry spills Biodiversity Loss B G H Slurry to Backfill Slurry spillage due to pipeline failure Slurry spills Slurry seepage to ground water A G H Slurry and clean topsoil mixed during Soil contamination and reduced land capability for Slurry to Backfill Contaminated Soil B H H spillage future use by plants Natural veldt outside tailings dam area dust laden Slurry deposition Windblown slurry dust from old spillages Contaminated Soil B H H causing soil contamination Slurry spillage left and filtered into Seepage to Slurry deposition Ground water pollution B H H natural storm water system Groundwater Supply pipelines, pizometers and fittings Slurry to Backfill Scrap Waste Salvageable materials on site D J H redundant during use. Supply pipelines, pizometers and fittings Unsalvageable equipment waste. Accumulation on Slurry to Backfill Scrap Waste D J H redundant during use. site Mixing with fresh water system with Drained process Tailings dam Drainage Storm water contamination B F M overflow of trenches water Drainage to ground water from unlined Drained process Tailings dam Drainage Ground water pollution A G H trenches water Tailings dam Drainage Cleaning of trenches Contaminated Soil Contaminated soil outside tailings dam D J H Tailings dam Drainage Dumping trench residue on topsoil Contaminated Soil Soil contamination D J H Tailings dam Drainage Dumping trench residue on topsoil Contaminated Soil Biodiversity loss D J H Seepage to Ground Ageing Pond Seepage from Ageing pond Ground water pollution. D I M Water Seepage to Ground Ageing Pond Seepage from Ageing pond Reduced re-use and capability of groundwater source D I M Water

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IMPACT ANALYSIS IMPACT ASSESSMENT RATING

ACTIVITY or PROCESS or Input SERVICE Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Ageing Pond Overflow of ageing pond Process water Overflow into natural system B H H Illegal access of persons to ageing pond - Ageing Pond Process water Third party affected B F M health risk Process water collected on top of tailings Re-used water to plant Process Water Overflow of collection water on tailings dam B F M dam at penstock Process water deposited at wall of tailings Process water causing erosion and runoff on outside Re-used water to plant Process Water D H M dam of tailings dam Re-used water to plant Spillage due to pipeline or pump failure Process Water Reduced water quality of available water B F M Re-used water to plant Spillage due to pipeline or pump failure Process Water Waste Water accumulation on site B F M Re-used water to plant Spillage due to pipeline or pump failure Process Water Waste Water accumulation on site B F M Re-used water to plant Spillage due to pipeline or pump failure Process Water Contaminated clean storm water area B F M Re-used water to plant Spillage due to pipeline or pump failure Process Water Biodiversity Loss B F M Process water collected on top of tailings Re-used water to Backfill Process Water Overflow of collection water on tailings dam B F M dam at penstock Process water deposited at wall of tailings Process water causing erosion and runoff on outside Re-used water to Backfill Process Water D H M dam of tailings dam Re-used water to Backfill Spillage due to pipeline or pump failure Process Water Reduced water quality of available water B F M Re-used water to Backfill Spillage due to pipeline or pump failure Process Water Waste Water accumulation on site B F M Re-used water to Backfill Spillage due to pipeline or pump failure Process Water Waste Water accumulation on site B F M Re-used water to Backfill Spillage due to pipeline or pump failure Process Water Contaminated clean storm water area B H H Soil contamination and reduced land capability for Re-used water to Backfill Spillage due to pipeline or pump failure Process Water B G H future use by plants

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6.6 Impact Assessment for Backfill

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Stope Preparation & Dust created with machines preparing stopes Dust Air pollution, Environmental nuisance D J H construction Stope Preparation & Generation of noise with machines operating Noise Environmental Nuisance D G L construction Stope Preparation & Oil Spills cleaned up as detected during Contaminated soil Contaminated Waste D J H construction normal use of machines underground Stope Preparation & Oil Spills during machine operating Oil spills Contaminated Soil D J H construction Stope Preparation & Heat released with machine operating Heat Localised release of heat D J H construction Stope Preparation & Construction of bulkhead& Draintower Accumulation of materials on site. Housekeeping Backfilled Materials D J H construction require materials on site. issues can result because of poor storage. Stope Preparation & Leaking pipes Slurry Spillage Possible ground water pollution B J Ex construction Stope Preparation & Used Fill line supply Accumulation of materials on site. Housekeeping Unused scrap material D J H construction pipes & ropes issues can result because of poor storage. Stope Preparation & Accumulation of materials on site. Housekeeping Unused scrap material Backfilled Materials D J H construction issues can result because of poor storage. Stope Preparation & Used Drain line Accumulation of materials on site. Housekeeping Buried under waste ramp D J H construction pipes issues can result because of poor storage. Cement transfer from machine that could Soil contamination, Water contamination &Loss of Cement Storage & Transfer Oil spills D J H have accidental oil spills on site. bio-diversity Cement Storage & Transfer Fumes from vehicles Carbon emissions Air pollution by greenhouse gasses D J H Cement Storage & Transfer Cement storage procedure Cement dust Air pollution, Loss of biodiversity C J H Raw cement Cement Storage & Transfer Cement transfer Air pollution, Loss of biodiversity C J H spillage Cement Storage & Transfer Tipping points Raw cement Air pollution, Loss of bio diversity D J H

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IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw spillage Raw cement Cement Storage & Transfer Transporting via conveyor belts Air pollution, Loss of bio diversity D J H spillage Cement Storage & Transfer Compressed air used during transfer Noise Environmental nuisance B G H Cement Storage & Transfer Cement transfer Cement dust Air pollution, Loss of bio diversity D J H Cement Storage & Transfer Tipping points Cement dust Air pollution, Loss of bio diversity D J H Waste conveyor Accumulation of waste material, Loss of bio- Cement Storage & Transfer Damaged belts C G M belts diversity Slurry Storage & Transfer Pipe failure Waste pipelines Accumulation of waste material D J H Soil contamination, Water contamination &Loss of Slurry Storage & Transfer Pipe failure Slurry Spillage B J Ex bio-diversity Soil contamination, Water contamination &Loss of Slurry Storage & Transfer Leaking tank or pipe failure Slurry Spillage D J H bio-diversity Radiation. Nuclear waste. Localised radiation on 3rd Slurry Storage & Transfer Damaged meters Radioactive source B F M parties Instrumentation used with nuclear sources Radio- active Slurry Storage & Transfer (density meters / mass flow meters) used to Radiation on ecosystem functioning and people B G H release inspect Breakage of nuclear source Radio- active Slurry Storage & Transfer Radio-active waste on site A F H instrumentation release Breakage of nuclear source Radio- active Slurry Storage & Transfer Third party impact by radio-active release A F H instrumentation release Breakage of nuclear source Radio- active Slurry Storage & Transfer Radio-active release on ecosytem functioning A F H instrumentation release Accidental oil spillage from sand Soil contamination, Water contamination &Loss of Sand Storage & Transfer Oil spills D J H transporting vehicles bio-diversity Sand Storage & Transfer Fumes from vehicles Carbon emissions Air pollution by greenhouse gasses D J H Overfilled conveyor belts at transfer Sand Storage & Transfer Raw Sand Spillage Environmental nuisance D J H points

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 119

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw

Sand Storage & Transfer overfilled conveyor belts at transfer points Sand dust Environmental nuisance D J H Radioactive Accumulation of waste material, Loss of bio- Sand Storage & Transfer Damaged belts C G M source diversity Sand Storage & Transfer Overfilled conveyor belts Raw Sand Spillage Environmental nuisance D J H Sand Storage & Transfer Damaged belts Waste parts Accumulation of waste material C G M Radiation. Nuclear waste. Localised radiation on 3rd Slurry Storage & Transfer Damaged meters Radioactive source B F M parties Sand Storage & Transfer Trucks tipping at bunker Sand dust Environmental nuisance D J H Sand Storage& Transfer Trucks tipping at bunker Sand Spillage Environmental nuisance D J H Sand Waste Sand Storage & Transfer Compacted sand diverted Accumulation of compacted sand D J H Screened Sand Storage & Transfer Vibrating screen motor Noise Environmental nuisance D J H Sand Storage & Transfer Tipping onto conveyor belt Sand dust Environmental nuisance D J H Sand Storage & Transfer Tipping onto conveyor belt Sand Spillage Accumulation of sand D J H Profil 5000 Storage & Accidental oil spillage from profil Soil contamination, Water contamination &Loss of Oil spills D G L Transfer transporting vehicles bio-diversity Profil 5000 Storage & Transfer Normal use of machinery Carbon emissions Environmental nuisance D J H Profil 5000 Storage & Soil contamination, Water contamination &Loss of Leaking tanks, Improper filling Profil spillage D J H Transfer bio-diversity Profil 5000 Storage & Accumulation of waste material, Loss of bio- Broken/ damaged pipes Waste pipelines D J H Transfer diversity

Profil 5000 Storage & Soil contamination, Water contamination &Loss of Damaged pipe or valves Profil spillage D J H Transfer bio-diversity

Profil 5000 Storage & Soil contamination, Water contamination &Loss of Damaged pump Profil spillage D J H Transfer bio-diversity Profil 5000 Storage & Accumulation of waste material, Loss of bio- Damaged pipe or valves Equipment waste D J H Transfer diversity

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 120

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Reclaim Water Transfer Reclaim water is used for backfill but excess Reclaim water Re-use of water C J H & Storage water is discharged to Plaatjiesvlei Reclaim Water Transfer Reclaim Water Soil contamination, Water contamination &Loss of Damaged pipe or valves D J H & Storage Spillage bio-diversity Reclaim Water Transfer Reclaim Water Soil contamination, Water contamination &Loss of Leaking tank D J H & Storage Spillage bio-diversity First Stage Backfill Soil contamination, Water contamination &Loss of First Stage Mixing Damaged pipes or valves D J H Mix Spillage bio-diversity First Stage Backfill Soil contamination, Water contamination &Loss of First Stage Mixing Damaged seals D J H Mix Spillage bio-diversity First Stage Backfill Soil contamination, Water contamination &Loss of First Stage Mixing Leaking pumps D J H Mix Spillage bio-diversity First Stage Mixing Normal running of pumps Noise Environmental nuisance D J H Soil contamination, Water contamination &Loss of First Stage Mixing Damaged pipes or valves Equipment waste D H M bio-diversity Soil contamination, Water contamination &Loss of First Stage Mixing Damaged pipes Waste pipelines D J H bio-diversity First stage backfill Soil contamination, Water contamination &Loss of First Stage Mixing Leaking pumps or seals on tank D J H mix spillage bio-diversity First stage backfill First Stage Mixing Cleaning of strainer boxes Contaminated organic waste D J H mix spillage Contaminated First Stage Mixing Cleaning of strainer boxes Contaminated organic waste D J H organic waste Accumulation of waste material, Loss of bio- First Stage Mixing Maintenance and cleaning of boxes Equipment waste D J H diversity Second Stage Mixing & Buffer Transfer point of cement into 2nd stage tank Final backfill Air pollution, Loss of bio diversity, soil contamination C J H Tank

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IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Second Stage Mixing & Buffer Solidified Backfill Cleaning of 2nd stage tank Contaminated cement aggregate. Contaminated soil D J H Tank Mix Second Stage Mixing & Buffer Soil contamination, Water contamination &Loss of Leaking tank or pipe failure Backfill Slurry D J H Tank bio-diversity Second Stage Mixing & Buffer First stage backfill Soil contamination, Water contamination &Loss of Pipe failure or leaking pump D J H Tank mix spillage bio-diversity Second Stage Mixing & Buffer Contaminated Cleaning of strainer boxes Contaminated organic waste D J H Tank organic waste Second Stage Mixing & Buffer Maintenance and cleaning of boxes Equipment waste Accumulation of waste material, Loss of bio-diversity D J H Tank Second Stage Mixing & Buffer Soil contamination, Water contamination &Loss of Leaking tank, pumps or pipe failure Backfill Spillage D J H Tank bio-diversity Second Stage Mixing & Buffer Normal running of pumps Heat Environmental nuisance D J H Tank Second Stage Mixing & Buffer Maintenance and cleaning of Pumps Equipment waste Accumulation of waste material, Loss of bio-diversity D J H Tank Second Stage Mixing & Buffer Soil contamination, Water contamination &Loss of Damaged pipe lines Waste pipelines D J H Tank bio-diversity Second Stage Mixing & Buffer Soil contamination, Water contamination &Loss of Pipe failure Backfill Spillage D J H Tank bio-diversity Soil contamination, Water contamination &Loss of Overland Pumping Pump not working Backfill Spillage D H M bio-diversity Soil contamination, Water contamination &Loss of Overland Pumping Pump not working Reclaim Water D H M bio-diversity Soil contamination, Water contamination &Loss of Overland Pumping Pipe failure Waste pipelines B H H bio-diversity Soil contamination, Water contamination &Loss of Overland Pumping Pipe failure Backfil spillage B H H bio-diversity

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IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Soil contamination, Water contamination &Loss of Overland Pumping Blockage resulting in pipe failure Backfil spillage B G H bio-diversity Overland Pumping Normal running of pumps Noise Environmental nuisance D J H Overland Pumping Maintenance and cleaning of Pumps Equipment waste Accumulation of waste material, Loss of bio-diversity D J H Overland Pumping Normal traffic Compaction Approved route D G L Overland Pumping Replacement of plinths due to wear Waste Plinths Accumulation of waste material, Loss of bio-diversity D J H Overland Pumping Normal vehicle operations Heat Environmental nuisance D J H Overland Pumping Fumes from vehicles Carbon emissions Air pollution by greenhouse gasses D J H Overland Pumping Normal vehicle operations Noise Environmental nuisance D J H Soil contamination, Water contamination &Loss of Overland Pumping Machine breakdown Oil spills D H M bio-diversity Overland Pumping Normal vehicle operations Dust Environmental nuisance D J H Underground Transfer Pipe failures Waste pipelines Accumulation of waste material underground D J H Underground Transfer Pipe failures Backfil spillage Soil contamination & water contamination D J H Underground Transfer Improper sealing of bulkhead Backfil spillage Soil contamination & water contamination D J H Underground Transfer Pipe failures Waste pipelines Accumulation of waste material underground D J H Installed in area to be backfilled in order to Backfiled drain Stope Drainage Accumulation of waste material underground D J H drain water from fill tower Stope Drainage Pipe failures Waste pipelines Accumulation of waste material underground D J H Stope Drainage Improper sealing of drain tower Backfil spillage Soil contamination & water contamination D J H Stope Drainage Pipes left behind after completion of fill Backfilled Pipes Accumulation of waste material underground D G L Stope Drainage Draining process Backfill water Soil contamination & water contamination C J H Waste water back to Backfill Soil contamination, Water contamination &Loss of Damaged pipe lines Waste pipelines D J H plant bio-diversity Waste water back to Backfill Waste water Soil contamination, Water contamination &Loss of Damaged pipe lines D J H plant spillage bio-diversity Waste water back to Backfill Damaged pipe lines from backfill plant to Waste pipelines Soil contamination, Water contamination &Loss of B J Ex

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 123

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw plant outlet position into Plaatjies vlei drain bio-diversity Excess Water Overflow and Damaged pipe lines Waste pipelines Ground Water pollution D G L Storage Excess Water Overflow and Soil contamination, Water contamination &Loss of Normal pumping operations to Plaatjies vlei Waste water A J Ex Storage bio-diversity

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 124

6.7 Impact Assessment for Storage of finished products

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Fossil fuel consumption. Localised heat Concentrate Conveying Use of Electricity Heat D J H released. Waste equipment generated with Land capability reduced with equipment Concentrate Conveying Scrap Waste D J H maintenance of machines waste material and accumulation on site Concentrate Conveying Spillage during conveyance Concentrate Spillage Soil contamination. D H M Concentrate has high percentage Third party impact of air polluted with Concentrate Conveying water when stockpiled. Dust from Concentrate dust D G L concentrate dust handling concentrate. Waste equipment generated with Land capability reduced with equipment Concentrate Conveying Waste conveyor belts D J H maintenance of machines waste material and accumulation on site Waste equipment generated with Land capability reduced with equipment Concentrate Conveying Waste parts D J H maintenance of machines waste material and accumulation on site Fossil fuel consumption. Localised heat Concentrate Loading Front end loader operating. Heat D J H released. Spillage during loading of Concentrate Loading Concentrate Spillage Soil contamination. D F L concentrate. Concentrate has high percentage Third party impact of air polluted with Concentrate Loading water when stockpiled. Dust from Concentrate dust D G L concentrate dust handling concentrate. Front-end loader and truck Concentrate Loading Oil spills Contaminated Soil D F L spillage with operating. Concentrate Loading Fumes from vehicles Carbon emissions Air pollution by greenhouse gasses D J H Fossil fuel consumption. Localised heat Concentrate Storage Use of Electricity Heat D J H released. Waste equipment generated with Land capability reduced with equipment Concentrate Storage Scrap Waste D J H maintenance of machines waste material and accumulation on site Lead Concentrate Soil contamination. Surface water and Concentrate Storage Stored in shed only. A F H Stockpile possible ground water pollution.

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 125

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw When moisture content is below 5% Concentrate Storage Lead Concentrate dust Air pollution by lead concentrate D F L dust can be released. Zinc Concentrate Soil contamination. Surface water and Concentrate Storage Stored in shed A F H Stockpile possible ground water pollution. Zinc Concentrate Soil contamination. Surface water and Concentrate Storage Stored in storage pad A F H Stockpile possible ground water pollution. Storage pad in Tony's dam when Zinc Concentrate Concentrate Storage plant capacity is exceeded to Soil contamination. D F L Stockpile store in demarcated plant area. Storage pad in Tony's dam when Zinc Concentrate Concentrate Storage plant capacity is exceeded to Surface water D F L Stockpile store in demarcated plant area. Storage pad in Tony's dam when Zinc Concentrate Concentrate Storage plant capacity is exceeded to Possible ground water pollution. D F L Stockpile store in demarcated plant area. When moisture content is below 5% Zinc Concentrate Concentrate Storage Air pollution by lead concentrate D F L dust can be released. Stockpile When moisture content is below 5% Concentrate Storage Zinc Concentrate dust Air pollution by lead concentrate D F L dust can be released. When moisture content is below 5% Concentrate Storage Copper Concentrate dust Air pollution by lead concentrate D F L dust can be released. Copper Concentrate Soil contamination. Surface water and Concentrate Storage Stored in shed A F H Stockpile possible ground water pollution. Stored in storage pad when Copper Concentrate Soil contamination. Surface water and Concentrate Storage Gamsberg processing takes place A F H Stockpile possible ground water pollution. and shed capacity is limited. Stored in storage pad when Copper Concentrate Greater exposure of copper stockpile Concentrate Storage communication and capacity for D H M Stockpile outside than inside shed. transporting is not coordinated. Concentrate Storage Front-end loader and truck Oil spills Contaminated Soil D F L

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 126

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw spillage with operating. Concentrate Storage Fumes from vehicles Carbon emissions Air pollution by greenhouse gasses D J H

6.8 Impact Assessment for Dispatch of Products from Site

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Use of Electricity by train to transport Fossil fuel consumption. Localised heat Concentrate Transporting Heat B F M to Saldanha released Salveable waste from tyre burst of Scrap Waste generation on site and on Concentrate Transporting Salvageable waste D H M truck road Spillage during transporting of Third party impact of soil pollution with Concentrate Transporting Concentrate Spillage B G H concentrate by truck. concentrate. Spillage during transporting of Third party impact of soil polluted with Concentrate Transporting Concentrate Spillage B G H concentrate by train. concentrate. Spillage during transporting of Third party impact of sea water polluted Concentrate Transporting Concentrate Spillage B F M concentrate by ship. with concentrate. Spillage during transportation of concentrate. Specifically when wind Third party impact of air polluted with Concentrate Transporting Concentrate dust B G H blows while transporting of concentrate dust concentrate by trucks. Spillage during transportation of concentrate. Specifically when Third party impact of air polluted with Concentrate Transporting Concentrate dust B G H wind blows while transporting of concentrate dust concentrate by rail wagons. Concentrate Transporting Truck and train spillage with Oil spills Contamination of soil B G H

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 127

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw operating. Concentrate Transporting Ship spillage with operating. Oil spills Contamination of water B F M Fumes from vehicles, trucks and Concentrate Transporting Carbon emissions Air pollution by greenhouse gasses B G H ships Generation of noise with machines Concentrate Off Loading Noise Environmental Nuisance D G L operating Fossil fuel consumption. Localised heat Concentrate Off Loading Locomotive and Scraper operating. Heat B F M released. Spillage during off loading of Concentrate Off Loading Concentrate Spillage Soil contamination. B F M concentrate. Spillage during off loading of Third party impact of air polluted with Concentrate Off Loading concentrate. Specifically when wind Concentrate dust B F M concentrate dust blows while off loading trucks. Spillage during loading of Third party impact of air polluted with Concentrate Off Loading concentrate. Specifically when wind Concentrate dust B F M concentrate dust blows while loading train trucks. Front-end loader, truck and Concentrate Off Loading Oil spills Contaminated Soil B F M Scraper spillage while operating. Concentrate Off Loading Locomotive Hydrocarbon spills Contaminated Soil D H M Fumes from Trucks, Locomotives and Concentrate Off Loading Carbon emissions Air pollution by greenhouse gasses B F M Front end loader Concentrate Storage Electricity for lighting Heat Localised heat released. D J H Fossil fuel consumption. Localised heat Concentrate Storage Vehicles and machines running. Heat B F M released. Waste equipment generated with Land capability reduced with equipment Concentrate Storage Scrap Waste C H H maintenance of machines waste material and accumulation on site Lead Concentrate Soil contamination. Surface water and Concentrate Storage Stored in shed only. B F M Stockpile possible ground water pollution. Soil contamination. Surface water and Concentrate Storage Stored in shed Zinc Concentrate Stockpile B F M possible ground water pollution.

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 128

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Copper Concentrate Soil contamination. Surface water and Concentrate Storage Stored in shed B F M Stockpile possible ground water pollution. Exposure of third party to asbestos Concentrate Storage particles when sheets replace or Asbestos Health risk to third party B G H maintenance takes place Exposure of third party to asbestos Concentrate Storage Asbestos Health risk to third party B G H particles of shed. Generation of noise with machines Concentrate Loading Noise Environmental Nuisance D G L operating Front end loader and Funky Fossil fuel consumption. Localised heat Concentrate Loading Heat B F M operating. released. Spillage during loading of Concentrate Loading Concentrate Spillage Soil contamination. B F M concentrate. Spillage during loading of Third party impact of air polluted with Concentrate Loading concentrate. Specifically when wind Concentrate Dust B G H concentrate dust blows while loading train trucks. Spillage during loading of Concentrate Loading concentrate. Specifically when wind Concentrate Dust Soil contamination. B G H blows while loading train wagons. Front-end loader and Funky Concentrate Loading Oil Spills Contaminated Soil B F M spillage with operating. Concentrate Loading Locomotive Hydrocarbon Spills Contaminated Soil B F M Fumes from front-end loader, funky, Concentrate Loading Carbon emissions Air pollution by greenhouse gasses B H H trucks

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 129

6.9 Impact Assessment for Waste Rock

IMPACT ASSESSMENT IMPACT ANALYSIS RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Heat and resource Fossil fuel consumption. Localised heat Rock Breaking Use of Machinery D J H consumption released. Generation of noise with machines Rock Breaking Noise Environmental Nuisance D J H operating Rock Breaking Oil Spills during transporting Oil spills Water Contamination D J H Oil Spills cleaned up as detected Rock Breaking during normal use of transport Hazardous waste Soil and Water contamination D H M vehicle Rock Breaking Generation of dust with rock breaking Dust Third party impact D J H Rock Breaking Generation of dust with rock breaking Dust Air pollution and environmental nuisance D J H Waste rock underground has limited impact Waste rock generated with rock except for possible acidification of water if Rock Breaking Waste Rock C G M breaking from blasted stopes groundwater interacts with exposed waste rock with high sulphate composition. Waste rock generated with rock Rock Breaking Waste Rock Possible housekeeping incidents C H H breaking from blasted stopes Heat and resource Fossil fuel consumption. Localised heat Crushing Use of Machinery D J H consumption released. Generation of noise with machines Crushing Noise Environmental Nuisance D J H operating Crushing Oil Spills during crushing Oil spills Contaminated Soil D J H Oil Spills cleaned up as detected Crushing Oil spills Contaminated Waste on site D J H during normal use of crusher Crushing Generation of dust with rock breaking Dust Third party impact D J H Crushing Generation of dust with rock breaking Dust Air pollution and environmental nuisance D J H

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 130

Waste rock underground has limited impact Waste rock generated with rock except for possible acidification of water if Crushing Waste Rock C G M breaking from blasted stopes groundwater interacts with exposed waste rock with high sulphate composition. Waste rock generated with rock Crushing Waste Rock Possible housekeeping incidents C H H breaking from blasted stopes Dust from conveying and waste rock Conveying Dust Third party impact D J H fall-out at conveyor. Dust from conveying and waste rock Housekeeping issues that can result in other Trucking Waste Rock Spillage D G L fall-out at conveyor. safety, health, environmental incidents Housekeeping issues that can result in Waste rock spillage from conveyor Trucking Waste Rock Spillage other safety, health, environmental D G H breakdown incidents Fossil fuel consumption. Localised heat Trucking Fuel consumption Carbon emissions D J H released. Trucking Truck noise Noise Environmental Nuisance D J H Spills or leaks from conveyor Continual small spills resulting in Trucking running and grease heating up and Oil spills accumulated water contamination D J H spilling. underground Spills from conveyor drive motor Trucking breakdown, repairs and Oil spills Water Contamination D J H maintenance

6.10 Supporting Services and Activities 6.10.1 Impact assessment during maintenance

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or

SERVICE Input

Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Planned maintenance inspections Use of Electricity for light & starting Heat Fossil fuel consumption. Localised heat D J H released. Planned maintenance inspections General Waste produced as part of General Waste General waste accumulation on site D J H administration at offices causing reduced land capability, extending

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 131

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or

SERVICE Input

Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw footprint of waste site Planned maintenance inspections Paper Waste produced as part of Paper General waste accumulation on site D I M checklist causing reduced land capability, extending footprint of waste site Planned maintenance Electronic Waste produced with e-Waste Land capability reduced with D I M inspections maintenance, replacement of unsalvageable electronic waste material laptops used by technicians on site Planned maintenance Oil Spills during transporting of Oil Spills Contaminated Soil D G L inspections persons to site. Planned maintenance inspections Fumes from transport vehicles Fumes Air pollution by greenhouse gasses D J H Planned maintenance inspections Scrap waste generated when Scrap Waste Waste accumulation on site. Affecting land D H M inspection materials become capability. redundant Planned maintenance inspections Rope inspections require cleaning of Hyrdocarbons Greased ropes are running winder system, C J H ropes with paraffin. causing possible soil and water contamination. Planned maintenance Possible oil spillage if paraiffin Hydrocarbon spills Soil pollution and surface water C J H inspections container is overturned. pollution. Planned maintenance Possible fire from spillage of Fire Air pollution, waste generated because B F M inspections flammable substance ignited. of burnt infrastructure. Planned maintenance inspections Compressed air used to dry and clean Noise Environmental nuisance D J H ropes for inspections Planned maintenance inspections Cylinder gas used to cut off bolts to Noise Environmental nuisance D J H inspect certain areas difficult to access. Planned maintenance inspections Cylinder gas used to cut off bolts to Heat Localised heat released. D J H inspect certain areas difficult to access. Planned maintenance inspections Cleaning of platforms to gain access Waste Water Waste water accumulation underground,. D J H and inspect them. Possible ground water polllution.

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 132

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or

SERVICE Input

Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Underground waste water pumped to surface evaporation dam with possible seepage to ground water. Planned maintenance Florescent tubes that become Waste tubes Hazardous waste on site, reduced land C F M inspections redundant is replaced and waste capability. tubes generated. Planned maintenance Bursting of flourescent tubes. Waste Tubes Air pollution. Third party impact. C F M inspections Planned maintenance Salvageable waste generated with Salvageable waste Accumulated waste on site of possible D J H inspections instrumentation breakdown and recycable materials. redundant equipment. Planned maintenance Salvageable waste generated with E Waste Accumulated hazardous waste on site C J H inspections instrumentation breakdown and of possible recyclable materials. redundant equipment. Planned maintenance Salvageable waste generated with Equipment Waste Accumulated waste on site of possible D J H inspections instrumentation breakdown and recyclable materials. redundant equipment. Planned maintenance Rags contaminated by oil & grease Hazardous Waste Soil & water pollution D G L inspections Planned maintenance Batteries become redundant with Hazardous Waste Accumulated hazardous waste on site C J H inspections use to inspect areas for of possible recyclable materials. maintenance Planned maintenance inspections Instrumentation used with nuclear Radio- active release Radiation on ecosystem functioning and B G H sources (density meters / mass flow people meters) used to inspect Planned maintenance Breakage of nuclear source Radio- active release Radio active waste on site A F H inspections instrumentation Planned maintenance Breakage of nuclear source Radio- active release Third party impact by radio active A F H inspections instrumentation release.

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 133

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or

SERVICE Input

Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Planned maintenance Redundant nuclear instrumentation Radio- active release Third party impact by radio active A F H inspections stored on site until disposal can release. take place. Planned maintenance Breakage of nuclear source Radio- active release Radio active release on ecosytem A F H inspections instrumentation functioning. Create work order Paper Waste produced as part of Paper General waste accumulation on site D I M checklist causing reduced land capability, extending footprint of waste site Investigation & Planning Paper Waste produced as part of Paper General waste accumulation on site D I M checklist causing reduced land capability, extending footprint of waste site Investigation & Planning Electronic Waste produced with Waste - Electronic Land capability reduced with D I M maintenance, replacement of IT unsalvageable electronic waste material equipment on site Investigation & Planning Hazardous Waste produced as part of Empty Ink Cartridges Land capability reduced with hazardous C I H administration at offices waste material and accumulation on site. Material on site Oil Spills during transporting of Oil Spills Contaminated Soil D G L persons to site. Material on site Fumes from transport vehicles Fumes Air pollution by greenhouse gasses D J H Material on site Vehicles access natural veldt for Compaction Footprint extension, soil compaction and D J H turning points or to reach possible biodiversity loss. maintenance area. Material on site Preparation for maintenance. Materials and Tools on site Footprint extension of materials packed in D J H Materials brought on site. areas in recovery. Material on site Preparation for maintenance. Hydrocarbon materials on Footprint extension of hazardous materials D J H Materials brought on site. site packed in areas in recovery.

Material on site Spillage from hydrocarbon materials Oil Spills Soil contamination. Surface water D J M overturned on site contamination Material on site Gas on site for maintenance can Gas Acetylene causing air pollution. C F M

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 134

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or

SERVICE Input

Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw leak on site

Material on site Gas bottle explode due to handling / Explosion Ecosystem disturbance B F M storage at maintenance Material on site Defunct gas bottle because of wear Gas Acetylene causing air pollution. C F M and tear resulting in gas leakage.

Material on site Preparation for maintenance. Chemicals on site Footprint extension of hazardous materials B F M Materials brought on site. packed in areas in recovery.

Material on site Spillage from chemical materials Chemical Spills Soil contamination. Surface water D H M overturned on site contamination

Complete HIRA Paper Waste produced as part of Paper General waste accumulation on site D I M checklist causing reduced land capability, extending footprint of waste site Complete HIRA Electronic Waste produced with Waste - Electronic Land capability reduced with D I M maintenance, replacement of IT unsalvageable electronic waste material equipment on site Complete HIRA Hazardous Waste produced as part of Empty Ink Cartridges Land capability reduced with hazardous C I H administration at offices waste material and accumulation on site.

Execute Maintenance Used oil generated during Used Oil Land capability reduced with hazardous B H H breakdown waste material on site Execute Maintenance Used oil generated during Used Oil Depletion of non-renewable natural B H H breakdown resources Execute Maintenance Oil Spillage on unbunded areas Contaminated Soil Soil pollution. Loss of topsoil. B H H during breakdown Increased hazardous waste on site

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 135

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or

SERVICE Input

Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Execute Maintenance Oil contaminated Waste generated Waste - Oil Land capability reduced with hazardous B H H during removal and application of contaminated waste material on site oil/grease with breakdown Execute Maintenance Waste equipment generated with Scrap Waste Land capability reduced with equipment C H H breakdown of compressors waste material and accumulation on site Execute Maintenance Waste equipment generated with Scrap Waste Land capability reduced with equipment C H H breakdown of compressors waste material and accumulation on site Execute Maintenance Use of Electricity for light, test starting Heat Fossil fuel consumption. Localised heat D J H & operation of tools released. Execute Maintenance Cylinder gas used to cut off bolts & Heat Localised heat released. D J H steel for maintenance. Execute Maintenance Waste generated during General Waste General waste accumulation on site D I M maintenance causing reduced land capability, extending footprint of waste site Execute Maintenance Paper waste as part of job cards Paper General waste accumulation on site D I M (maintenance) causing reduced land capability, extending footprint of waste site Execute Maintenance Hazardous Waste produced as part of Empty Ink Cartridges Land capability reduced with hazardous C I H administration at offices waste material and accumulation on site. Execute Maintenance Electronic Waste produced with e-Waste Land capability reduced with D I M maintenance, replacement of IT unsalvageable electronic waste material equipment on site Execute Maintenance Oil Spills during transporting of Oil Spills Contaminated Soil B I M persons to machines to do maintenance. Execute Maintenance Driver error or poor road Oil Spills Contaminated Soil B I M conditions causing damage to vehicle and oil spill Execute Maintenance Oil spills during draining & filling Oil Spills Contaminated Soil B G H of oil compartments of equipment.

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 136

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or

SERVICE Input

Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Execute Maintenance Fumes from transport vehicles Fumes Air pollution by greenhouse gasses D J H Execute Maintenance Material waste produced as part of Material Waste Material waste accumulation on site D J H maintenance. causing reduced land capability, extending footprint of waste site & possible ground water & soil pollution Execute Maintenance Spillage from chemical materials Chemical Spills Soil contamination. Surface water D I M overturned on site contamination Execute Maintenance Possible oil spills and pollution Empty Containers Contaminated Soil C H H Execute Maintenance Compressed air used to dry and clean Noise Environmental nuisance D J H ropes & drive tools for maintenance Execute Maintenance Cylinder gas used to cut off bolts & Noise Environmental nuisance D J H steels to maintain certain areas difficult to access. Execute Maintenance Cleaning of platforms to gain access Waste Water Waste water accumulation underground,. D J H and inspect them. Possible ground water pollution. Underground waste water pumped to surface evaporation dam with possible seepage to ground water. Execute Maintenance Florescent tubes that become Waste tubes Hazardous waste on site, reduced land C F M redundant is replaced and waste capability. tubes generated. Execute Maintenance Scrap compressor parts generating Scrap compressor parts Possible pollution of soil and water due to D J H during maintenance contaminated parts Execute Maintenance Scrap generator parts generating Scrap generator parts Possible pollution of soil and water due to D J H during maintenance contaminated parts Execute Maintenance Scrap winder parts generating during Scrap winder parts Possible pollution of soil and water due to D J H maintenance contaminated parts Execute Maintenance Scrap crusher parts generating during Scrap Crusher parts Possible pollution of soil and water due to D J H maintenance contaminated parts

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 137

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or

SERVICE Input

Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw Impact Impact Raw Execute Maintenance Scrap conveyor belt parts generating Broken Conveyor belts Possible pollution of soil and water due to D J H during maintenance contaminated parts Execute Maintenance Scrap fan parts generating during Scrap fan parts Possible pollution of soil and water due to D J H maintenance contaminated parts Execute Maintenance Salvageable waste generated Salvageable waste Accumulated waste on site of possible D J H during maintenance. recyclable materials. Execute Maintenance Salvageable waste generated Equipment Waste Accumulated waste on site of possible D J H during maintenance. recyclable materials. Execute Maintenance Hazardous Waste produced as part of Hazardous Waste Land capability reduced with hazardous C I H maintenance activity. waste material and accumulation on site. Site Clearance Leaving Salvageable waste on site Salvageable waste Accumulated waste on site of possible C H H recyclable materials reduce land capability Site Clearance Leaving Equipment Waste on site Equipment Waste Accumulated equipment waste on site C H H reduce land capability Site Clearance Leaving hazardous Waste on site Hazardous Waste Land capability reduced with hazardous C H H waste material and accumulation on site. Site Clearance Leaving General Waste on Site General Waste General waste accumulation on site C H H causing reduced land capability, extending footprint of waste site

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 138

6.10.2 Impact Assessment for Office Operations

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Office Use of electricity to power equipment Illumination Carbon emissions from electricity supplier C J H operation & lights Used up and/or redundant office Accumulation of waste on site and reduced Office Cleaning Scrap Waste D J H equipment from office cleaning. land capability. Accumulation of waste on site and Office Cleaning Equipment breakdown. Scrap Waste D J H reduced land capability. Office Cleaning Illegal dumping of scrap waste Domestic Waste Biodiversity loss C G M Office Cleaning Illegal dumping of scrap waste Domestic Waste Ecological disturbance C G M Third party health impact by uninformed Office Cleaning Spilling of cleaning chemicals Hazardous Waste persons slipping or touching hazardous D J H chemicals Office Cleaning Spilling of cleaning chemicals Hazardous Waste Soil contamination D J H General waste accumulation on site Used up and/or redundant kitchen Office Cleaning Domestic Waste causing reduced land capability, extending D J H equipment from office cleaning. footprint of waste site Cleaning out of dust bins in office Waste Accumulation on site reducing land Office Cleaning Domestic Waste C J H block capability. Office Cleaning Use of electricity Heat Resource Consumption D J H Used up fluorescent tubes needs Hazardous material on site affecting Equipment Start up Waste tubes D H M replacement land capability Electronic Waste produced with Land capability reduced with Equipment Start up maintenance, replacement of IT e-Waste unsalvageable electronic waste material C F M equipment on site Re-use of resources not done. Data Processing Incorrect Waste separation General Waste Accumulation of waste on waste site C J H affecting land capability Re-use of resources not done. Data Processing Waste paper from unwanted printouts Paper D J H Accumulation of waste on waste site

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 139

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw affecting land capability Soil Contamination by leaching of Data Processing Incorrect disposal of cartridges Empty Ink Cartridges hazardous materials in domestic waste D H M site Air pollution by toxic fumes from ink Data Processing Incorrect disposal of cartridges Empty Ink Cartridges cartridges burned in domestic waste D H M site. Electronic Waste produced with Land capability reduced with Data Processing maintenance, replacement of IT e-Waste unsalvageable electronic waste material C F M equipment on site Used up and/or redundant office Accumulation of waste on site and Data Processing Scrap Waste C I H equipment from data processing reduced land capability. Used up batteries from battery Data Processing powered tools & equipment in Waste Batteries Soil Contamination B G H domestic waste Used up batteries from battery Accumulation of hazardous waste on site Data Processing Waste Batteries B G H powered tools & equipment and reduced land capability. Spilling of Ammonium Hydroxide Ammonium Hydroxide Harmful contamination of air on Data Processing D F L solution Vapours evaporation Data Processing Sewage Pipe burst Sewage Water contamination D J H Re-use of resources not done. Filing Incorrect Waste seperation General Waste Accumulation of waste on waste site C J H affecting land capability Re-use of resources not done. Filing Waste paper from unwanted printouts Paper Waste Accumulation of waste on waste site D J H affecting land capability

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 140

6.10.3 Impact Assessment for Water Supply and Storm Water

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw

General waste accumulation on site causing Paper Waste produced as part of Check pumps Paper reduced land capability, extending footprint D I M checklist of waste site Oil Spills during transporting of Check pumps Oil Contaminated Soil D G L persons to pumps to do pre-check Driver error or poor road Check pumps conditions causing damage to Oil spills Contaminated Soil D H M vehicle and oil spill Check pumps Fumes from transport vehicles Oil spills Air pollution by greenhouse gasses D J H Fossil fuel consumption. Localised heat Run pumps Use of Electricity for pumps Carbon emissions D J H released. Large volumes of waste water released, Run pumps Gland service packing burns. Waste Water C F M more than gland service normal use. Waste Water Release from gland Run pumps Waste Water Reduced water quality of available water D J H service Waste Water Release from gland Run pumps Waste Water Waste Water accumulation on site D J H service Waste Water Release from gland Run pumps Waste Water Natural resource use D J H service Run pumps Noise from pump running Noise Environmental Nuisance D F L Rainwater entering pump bund wall Surface water pollution. Overflow of bund Run pumps Dirty Run-off storm water C F M area wall water in uncontained area. Rainwater entering pump bund wall Surface water pollution. Overflow of bund Run pumps Dirty Run-off storm water C F M area wall water in uncontained area. Oil Spill / Grease spills with barrel Run pumps Oil spills Contaminated Soil D F L seals leaking Run pumps Oily sludge and materials collecting in Oil contaminated waste Land capability reduced with hazardous D G L

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 141

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw

bund wall of pumps waste material on site General waste accumulation on site causing Paper Waste produced as part of Inspections Paper reduced land capability, extending footprint D I M checklist of waste site Fossil fuel consumption. Localised heat Inspections Use of Electricity for light Heat D J H released. Oil Spills during transporting of Inspections persons to compressor to do pre- Oil spills Contaminated Soil D G L check Inspections Fumes from transport vehicles Carbon emissions Air pollution by greenhouse gasses D J H Oil Spills during transporting of Inspections persons to pumps to do Oil spills Contaminated Soil D G L inspections Resource use risks and allocations Wrong data collected because flow meter Flow meters not managed. Incorrect water Resource use data D H M not maintained balance. Resource use risks and allocations Wrong data collected because flow meter Flow meters not managed. Incorrect water Resource use data C J H not calibrated balance. Resource use risks and allocations Data not collected because persons not Flow meters not managed. Incorrect water Resource use data D F L available balance. Resource use risks and allocations Data not collected because flow meter not Flow meters not managed. Incorrect water Resource use data C J H installed balance.

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6.10.4 Power / Electricity; Use of Generators

IMPACT IMPACT ANALYSIS ASSESSMENTAL RATING

ACTIVITY or PROCESS or

SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw

General waste accumulation on site Paper Waste produced as part of Pre-check Generators Paper causing reduced land capability, extending D I M checklist footprint of waste site Fossil fuel consumption. Localised heat Pre-check Generators Use of Electricity for light & starting Heat D J H released. Use of Electricity for pre-heating Fossil fuel consumption. Localised heat Run Generators Heat D J H generators released. Use of diesel for generation of Fossil fuel consumption. Localised heat Run Generators Heat D J H electricity released. Run Generators Noise from Generators operating Noise Environmental Nuisance D G L Oil Spills with normal operating of Run Generators Oil Spills Contaminated Soil D F L Generators Gasses released to atmosphere. NOX Run Generators Diesel exhaust gas Gasses C H H pollution of air. General waste accumulation on site Paper Waste produced as part of Inspections Paper causing reduced land capability, extending D I M checklist footprint of waste site Fossil fuel consumption. Localised heat Inspections Use of Electricity for light Heat D J H released.

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 143

6.10.5 Impact Assessment for Hazardous waste

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS

or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Supply waste Overheating of vehicles that transmit heat into Heat Air pollution by greenhouse gasses D G L infrastructure and Goods environment through convection and radiation Supply waste Fumes from vehicles Carbon Emissions Air pollution by greenhouse gasses D J H infrastructure and Goods Supply waste Noise pollution from transportation Noise Disturbance on animals D J H infrastructure and Goods Supply waste Oil spill from vehicles due to poor Oil Spills during transporting Contaminated Soil & Waste C I M infrastructure and Goods maintenance Overflow of sewage water into natural veldt. Supply waste Honey sucker spillage on collecting sewage Sewage Spills Environmental nuisance from smells. E. coli C H H infrastructure and Goods from septic tanks impact on third parties Supply waste Vehicle movement on sites Compaction Compaction of soils D J H infrastructure and Goods Supply waste Dust from vehicle Dust Air pollution by dust E I M infrastructure and Goods Supply waste Oil Spills during normal use of transport Oil Spills Contaminated Soil & Waste D H M infrastructure and Goods vehicle Supply waste Affecting people and nature Carbon Emissions Air pollution by greenhouse gasses D I M infrastructure and Goods Supply waste Generation of salvageable waste from Scrap Waste Rust on ground- Soil Contamination C G M infrastructure and Goods Township engineering Littering accumulated in veldt, reduced land Supply waste Windblown littering from domestic waste site Windblown Waste capability and quality of life, affecting third B F M infrastructure and Goods into veldt. parties - farmer next door. Supply waste Overflowing or spillage of liquids e.g. Waste Seepage to Ground water Ground water contamination B H H infrastructure and Goods water or Oil

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 144

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS

or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Air pollution by fire smoke drawn down into Supply waste Combustion form materials in organic waste Smoke underground mine affecting employees A H Ex infrastructure and Goods site underground Supply waste General waste generated by town and mining Land capability reduced. Expansion of Compacted General Waste A J Ex infrastructure and Goods area waste area footprint. Land capability reduced. Expansion of Supply waste Hazardous waste generated by town and waste area footprint. Hazardous material infrastructure and mining area. Hazardous waste on Compacted Hazardous Waste B H H lost to waste site. Hazardous material Goods domestic waste site. leaching to ground water over time. Supply waste General building rubble generated by town Land capability reduced. Expansion of Compacted Building Rubble C G M infrastructure and Goods and mining area waste area footprint. Supply waste Generation of salvageable waste from Compacted Salvageable Waste Salvageable materials on site E I M infrastructure and Goods Township engineering Supply waste Waste pipes generated by town and mining Land capability reduced. Expansion of Waste pipelines E G L infrastructure and Goods area waste area footprint. Supply waste Salination of soils. Biodiversity loss over Water Spillage because of poor management Water Spill D H M infrastructure and Goods time. Soil structure affected. Supply waste Solid waste sewage spillage in natural veld Solid waste too superficially buried coming Sewage Spill B H H infrastructure and Goods because of poor management to surface. E. coli waste on surface. Supply waste Waste water pumped out with swimming pool Waste water to sewage pond. Fresh water Waste Water Spill B H H infrastructure and Goods maintenance. wasted Supply waste Overflowing or spillage of liquids e.g. Waste Seepage to Ground water Ground water contamination D H M infrastructure and Goods water or Oil Supply waste Financial losses due to spilling Overflow of Dams Overflow of sewage water into natural veld C G M infrastructure and Goods Littering accumulated in streets, parks Supply waste recreation areas and veld, reduced land General waste pollution Waste Spillage C J H infrastructure and Goods capability and quality of life, affecting third parties

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 145

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS

or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Garden waste into domestic waste because Unnecessary use of domestic waste site for Supply waste residence mix organic waste with domestic Mixed waste organic material. Mine has organic waste C H H infrastructure and Goods waste bags. site. Waste collection and Overheating of vehicles that transmit heat into Heat Air pollution by greenhouse gasses D G L handling environment through convection and radiation Waste collection and Fumes from vehicles Carbon Emissions Air pollution by greenhouse gasses D J H handling Waste collection and Noise pollution from transportation Noise Disturbance on animals D J H handling Waste collection and Oil spill from vehicles due to poor Oil Spills during transporting Soil and groundwater contamination D H H handling maintenance Overflow of sewage water into natural veldt. Waste collection and Honey sucker spillage on collecting sewage Sewage Spills Environmental nuisance from smells. E. coli C H H handling from septic tanks impact on third parties Waste collection and Vehicle movement on sites Compaction Compaction of soils D J H handling Waste collection and Dust from vehicle Dust Air pollution by dust E I M handling Waste collection and Oil spill from vehicles Oil Spills Contaminated Soil & Waste D H M handling Waste collection and Odours from vehicles while collecting waste Fumes Air pollution due to noxious smells D I M handling Waste collection and Generation of salvageable waste from Scrap Waste Rust on ground- Soil Contamination C G M handling Township engineering Waste collection and Noise pollution from transportation Noise Disturbance on animals D J H handling Littering accumulated in veld, reduced land General waste blown off or falling of from Waste Disposal Domestic Waste Spills capability and quality of life, affecting third C I H transport vehicle parties

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 146

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS

or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Waste Disposal Fumes from transporting vehicles Carbon Emissions Air pollution by greenhouse gasses D J H Domestic Waste generated by town and Land capability reduced. Expansion of Waste Disposal Domestic Waste on site A J Ex mining area waste area footprint. Electronic waste generated by town and Land capability reduced. Expansion of Waste Disposal mining area. Electronic waste on domestic Electronic Waste waste area footprint. Salvageable material B G H waste site. lost to waste site. Hazardous waste generated by town and Waste Disposal Hazardous Waste Poisoning of humans C J H mining area. Generation of organic waste from mine and Waste Disposal Organic Waste Natural resource available for re-use. C J H town gardens Littering accumulated in veldt, reduced land Windblown littering from domestic waste site Waste Disposal Domestic Waste into veldt capability and quality of life, affecting third B F M into veld parties - farmer next door. Air pollution by fire smoke drawn down into Combustion from materials in organic waste Waste Disposal Garden Waste Fire underground mine affecting employees A H Ex site underground Waste water pumped out with swimming pool Waste water to sewage pond. Fresh water Waste Disposal Waste Water Spill B H H maintenance. wasted Overflowing or spillage of liquids e.g. Waste Waste Disposal Seepage to Ground water Ground water contamination D H M water or Oil Waste Site Overheating of vehicles that transmit heat into Heat Air pollution by greenhouse gasses D G L Management environment through convection and radiation Waste Site Noise pollution from transportation Noise Disturbance on animals D J H Management Waste Site Oil spill from vehicles Oil Spills during transporting Contaminated Soil & Waste D H M Management Overflow of sewage water into natural Waste Site Honey sucker spillage due to vehicle Sewage Spills veldt. Environmental nuisance from C H H Management accident smells. E. coli impact on third parties

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 147

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS

or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Waste Site Vehicle movement on sites Compaction Compaction of soils D J H Management Waste Site Dust from vehicle Dust Air pollution by dust E I M Management Waste Site Oil spill from vehicles Oil Spills Contaminated Soil & Waste D H M Management Waste Site Fumes from transporting vehicles Carbon Emissions Air pollution by greenhouse gasses D J H Management Waste Site Generation of salvageable waste from Scrap Waste Rust on ground- Soil Contamination C G M Management Township engineering Littering accumulated in veldt, reduced land Waste Site Windblown littering from domestic waste site Windblown Waste capability and quality of life, affecting third B F M Management into veldt. parties - farmer next door. Waste Site Overflowing or spillage of liquids e.g. Waste Seepage to Ground water Ground water contamination D H M Management water or Oil Air pollution by fire smoke drawn down into Waste Site Combustion form materials in organic waste Smoke underground mine affecting employees A H Ex Management site underground Waste Site General waste generated by town and mining Land capability reduced. Expansion of Compacted General Waste A J Ex Management area waste area footprint. Land capability reduced. Expansion of Hazardous waste generated by town and Waste Site waste area footprint. Hazardous material mining area. Hazardous waste on domestic Compacted Hazardous Waste B H H Management lost to waste site. Hazardous material waste site. leaching to ground water over time. Waste Site General building rubble generated by town Land capability reduced. Expansion of Compacted Building Rubble C G M Management and mining area waste area footprint. Waste Site Generation of salvageable waste from Compacted Salvageable Waste Salvageable materials on site E I M Management Township engineering Waste Site Overflowing or spillage of liquids eg. Waste Seepage to Ground water Ground water contamination D H M

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 148

IMPACT IMPACT ANALYSIS ASSESSMENT RATING

ACTIVITY or PROCESS

or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Management water or Oil Land capability reduced. Expansion of Hazardous waste generated by town and Waste Site waste area footprint. Hazardous material mining area. Hazardous waste on domestic Compacted Hazardous Waste B H H Management lost to waste site. Hazardous material waste site. leaching to ground water over time. Waste Site Waste pipes generated by town and mining Land capability reduced. Expansion of Waste pipelines E G L Management area waste area footprint. Waste Site Salination of soils. Biodiversity loss over Water Spillage because of poor management Water Spill D H M Management time. Soil structure affected. Waste Site Solid waste sewage spillage in natural veld Solid waste too superficially buried coming Sewage Spill B H H Management because of poor management to surface. E. coli waste on surface. Waste Site Waste water pumped out with swimming pool Waste water to sewage pond. Fresh water Waste Water Spill B H H Management maintenance. wasted Waste Site Spillage because of poor supervision from Overflow of Dams Overflow of sewage water into natural veldt C G M Management contractor Littering accumulated in streets, parks Waste Site Waste dumped by residents in streets, parks, recreation areas and veld, reduced land Waste Spillage C J H Management recreation areas and veld capability and quality of life, affecting third parties Garden waste into domestic waste because Unnecessary use of domestic waste site for Waste Site residence mix organic waste with domestic Mixed waste organic material. Mine has organic waste C H H Management waste bags. site.

Black Mountain Mining (Pty) Ltd – EMPR May 2013 Page | 149

6.11 Impact Assessment for concurrent rehabilitation

IMPACT IMPACT ASSESSMENT RATING:

ACTIVITY or PROCESS

Input tion or SERVICE Output Impact

(Normal – Abnormal – Emergency)

Severity

estima

Probability Raw impact impact Raw Oil Spills during normal use of transport Geological Survey Hydrocarbon spills Contaminated Soil D H M vehicle Geological Survey Fumes from vehicles Carbon emissions Air pollution D F L Generation of dust with transport vehicles in Geological Survey Dust Air pollution and environmental nuisance D J H veld Generation of noise with machines operating Geological Survey Noise Environmental Nuisance D J H and vehicles driving Geological Survey Wind during windy season on exposed soil Carbon emissions Environmental nuisance. D J H Geological Survey Wind during windy season on exposed soil Windblown sand Loss of sand on surface C H H Geological Survey Wind during windy season on exposed soil Windblown sand Loss of topsoil B H H Fossil fuel consumption. Localised heat Topsoil Removal Use of machinery Emissions to atmosphere D J H released. Generation of noise with machines Topsoil Removal Environmental Nuisance Noise D J H operating Generation of dust with machines Topsoil Removal Air pollution and environmental nuisance Dust D J H operating Oil Spills with machine breakdown or Topsoil Removal Contaminated Soil Compactions D H M leakage Soil structure breakdown, ecological Machine Working areas, driving in veldt, Topsoil Removal Compaction B J Ex processes interrupted, Loss of biodiversity. gravel roads Topsoil Removal Air pollution Scarred landscape Fumes from machines D F L Topsoil Removal Soil structure breakdown Scarred landscape Topsoil removed and area mined B J Ex Topsoil Removal Ecological processes interrupted, Scarred landscape Topsoil removed and area mined B J Ex Topsoil Removal Loss of biodiversity. Topsoil Stockpile Topsoil removed and area mined A J Ex Topsoil Removal Soil structure breakdown, ecological Scarred landscape Topsoil removed and area mined D J H

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processes interrupted, Loss of biodiversity. Soil structure breakdown, ecological Topsoil Removal Diesel Topsoil removed and area mined D J H processes interrupted, Loss of biodiversity. Establish Mining Face Earth moving machines operating Heat Resource consumption D J H Establish Mining Face Earth moving machines operating Carbon emissions Localised heat from machines D J H Establish Mining Face Earth moving machines operating Oil spills Air pollution D J H Establish Mining Face Earth moving machines operating Noise Nuisance D J H Establish Mining Face E Machine Breakdown Oil spills Soil contamination D J H Repeated driving of machines over working Soil structure breakdown, ecological Establish Mining Face Compactions D J H area. processes interrupted, Loss of biodiversity. Establish Mining Face Earth moving machines operating Dust Nuisance D J H Excavating Earth moving machines operating Diesel Resource consumption D J H Excavating Earth moving machines operating Heat Localised heat from machines D J H Excavating Earth moving machines operating Carbon emissions Air pollution D J H Excavating Earth moving machines operating Noise Nuisance D J H Excavating E Machine Breakdown Oil spills Soil contamination D J H Machine Working areas, Driving in veld, Excavating Compactions Soil contamination D J H Gravel roads Excavating Earth moving machines operating Dust Nuisance D J H Natural Resource removed / depletion out Excavating Excavation of sand resource for backfilling Mined Sand D J H of natural system Excavating Excavation of sand resource for backfilling Mined Sand Biodiversity loss C J H Exposed earth result in excessive dust and Excavating Excavation of sand resource for backfilling Mined Sand B J Ex runoff. Excavating Excavation with major rain event. Mined Sand Soil erosion. A J Ex Screening Use of electricity Heat Nuisance/Fossil fuel D J H Screening Use of vibrating screens Carbon emissions Air pollution D J H Screening Use of vibrating screens Noise Nuisance D J H Screening E Machine Breakdown Oil spills Soil contamination D J H Machine Working areas, Driving in veldt, Soil structure breakdown, ecological Screening Compactions D J H Gravel roads processes interrupted, Loss of biodiversity. Screening Use of vibrating screens Dust Nuisance D J H Screening Use of vibrating screens Heat Nuisance/Fossil fuel D J H Screening Use of vibrating screens Carbon emissions Air pollution D J H Screening Use of vibrating screens Noise Nuisance D J H Screening E Machine Breakdown Oil spills Soil contamination D J H

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Screening Use of vibrating screens Dust Nuisance D J H Screening Backfill sand is put underground Backfill Sand Loss of sand resource C G M Soil structure breakdown, ecological Screening Wind during windy season on exposed soil Waste sand D J H processes interrupted, Loss of biodiversity. Loading & Trucking Operating of trucks and excavator / loader Heat Localised heat from machines D J H Loading & Trucking Operating of trucks and excavator / loader Carbon emissions Air pollution D J H Loading & Trucking Operating of trucks and excavator / loader Noise Nuisance D J H Loading & Trucking Machine Breakdown Oil spills Soil contamination D J H Machine Working areas, Driving in veld, Soil structure breakdown, ecological Loading & Trucking Compactions D J H Gravel roads processes interrupted, Loss of biodiversity. Loading & Trucking Operating of trucks and excavator / loader Sand Spillage Loss of sand resource D J H Stockpiling E Machine Breakdown Oil spills Soil contamination D J H Stockpiling Operating of trucks and excavator / loader Carbon emissions Air pollution D J H Stockpiling Operating of trucks and excavator / loader Dust Air pollution & environmental nuisance D J H Landscaping Earth moving machines operating Heat Localised heat from machines D J H Landscaping Earth moving machines operating Carbon emissions Air pollution D J H Landscaping Earth moving machines operating Noise Nuisance D J H Landscaping E Machine Breakdown Oil spills Soil contamination D J H Machine Working areas, Driving in veld, Soil structure breakdown, ecological Landscaping Compactions D J H Gravel roads processes interrupted, Loss of biodiversity. Landscaping Earth moving machines operating Dust Nuisance D J H Soil structure breakdown, ecological Landscaping Earth moving machines operating Profiled Landscape D J H processes interrupted, Loss of biodiversity. Rehabilitation Use of electricity Heat Nuisance/Fossil fuel D J H Rehabilitation Use of vehicles Carbon emissions Air pollution D J H Rehabilitation Use of vehicles Noise Nuisance D J H Rehabilitation Machine Breakdown Oil spills Soil contamination D J H Machine Working areas, Driving in veldt, Soil structure breakdown, ecological Rehabilitation Compactions D J H Gravel roads processes interrupted, Loss of biodiversity. Rehabilitation Use of vehicles Dust Nuisance D J H Soil structure breakdown, ecological Rehabilitation Use of earth moving vehicles Replaced top soil D J H processes interrupted, Loss of biodiversity. Soil structure breakdown, ecological Rehabilitation Use of earth moving vehicles Rehabilitated D H M processes interrupted, Loss of biodiversity.

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6.12 Impacts Associated with Decommissioning and Closure

IMPACT ASSESSMENT IMPACT ANALYSIS

RATING:

ACTIVITY or PROCESS or SERVICE Input Output Impact

(Normal – Abnormal – Emergency)

Severity

estimation

Probability Raw impact impact Raw Desktop review of Inaccurate closure liability Updated closure quantum Quantified closure cost C G M closure liabilities In-depth review of Accurate closure quantum Updated closure quantum Quantified closure cost D F L current closure quantum Survey current Complete listing of infrastructure, quarries, Updated closure liability to include all infrastructure, impoundments, sand mining area, waste Increased liability funding gap new infrastructure and surface B H H roads and surface mining with rock dumps, ponds & developments quantified areas tailings dam. Reduced pollution impacts from defunct Rehabilitation planning Reduction in projected closure quantum Concurrent rehabilitation plan D F L areas Review estimated Complete listing of Updated closure liability to include all closure cost per item infrastructure, impoundments, More accurate closure liability new infrastructure and surface D F L against infrastructure roads and surface mining with developments register quantified areas Obtain Approval for DMR does not accept closure quantum as Approved/refused closure B H H quantum correct quantum Overshot funding figure due to incorrect Funding Increased funds in trust fund Availability of funds for closure B H H estimates Ensure closure funding Significant contribution necessary close to Mismanagement of closure fund Insufficient closure funding at closure B I Ex is managed correctly mine closure Deciding on bank Established closure Trust fund Funds available for final rehabilitation & Closure funds available for final guarantee quantum and registered and Bank guarantee B I Ex closure rehabilitation Trust fund obtained Annual closure fund Funds available for final rehabilitation & Funding within requirements as Sufficient funding available D I M budgeting closure per annual review

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7 ALTERNATIVE LAND USE AND DEVELOPMENTS CONSIDERED

In determining land use alternatives for the site, it must be noted that this is an already existing mine with the remaining life expectancy estimated to be five (5) years. Black Mountain Mine has an approved mining license and an approved EMPR. This environmental impact assessment report has been compiled for the amendment to the existing EMPR. As the intent of this section of the report is to determine if there are alternatives, for proposed operations, and not existing operation, it is not applicable for Black Mountain Mine. Additional motivations of why alternatives to mining have not been considered are presented below: 7.1 Land-use / development Alternatives Considered This environmental impact assessment report has been developed for an existing mine, which will make use of existing infrastructure. To date the mine has proved to be economically profitable with approximately 804 direct employment opportunities and 577 opportunities for contractors. No other land- use alternatives have been considered for this existing mine. 7.2 Alternative Mining Methods The current mining method as described in Section 3 has been developed over the years. No other mining method is being considered. 7.3 Consequences of Not Continuing with the Mine Should this existing mine stop the consequences would be:

Loss of over 804 direct employment positions.

Loss of over 577 indirect employment positions through the employment of sub-contractors.

Loss of revenue for local goods and services

Loss of revenue for numerous suppliers.

Loss of community development projects supported by Black Mountain Mine.

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8 ENVIRONMENTAL GOALS AND OBJECTIVES

The primary objective of any mining operation is to make a profit. Without a profit, it is not possible for the mine to continue operating or have the funds available to meet the environmental or socio-economic goals and objectives set out in this section of the report. 8.1 Environmental Goals and Objectives The following section details the overarching goals and objectives that Black Mountain Mine will aim to achieve. It includes both a commitment to ensure legal compliance and then highlights the goals and objective for those impacts which are deemed most significant for the mine.

8.1.1 Environmental Legislation

For the mining operation as a whole, the mine‟s goal is to comply with all environmental legislation. Specific aspects to be adhered to from environmental legislation include; National Environmental Management Act, Act 107 of 1998 (NEMA) As the NEMA is the cornerstone of all environmental legislation, the management measures implemented by the mine will strive to adhere to the principles of NEMA. The specific principles which Black Mountain Mine feels are most relevant to their environmental goals and objectives have been listed below (the reference numbers provided are the same as those in the legislation): (4)(a) Sustainable development requires the consideration of all relevant factors including the following: I. That the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied; II. that pollution and degradation of the environment are avoided, or, where they cannot be altogether avoided, are minimised and remedied; III. that the disturbance of landscapes and sites that constitute the nations cultural heritage is avoided, or where it cannot be altogether avoided, is minimised and remedied; IV. that waste is avoided, or where it cannot be altogether avoided, minimised and reused or recycled where possible and otherwise disposed of in a responsible manner; V. that the use and exploitation of non-renewable natural resources is responsible and equitable, and takes into account the consequences of the depletion of the resource; VI. that a risk averse and cautious approach is applied, which takes into account the limits of current knowledge about the consequences of decisions and actions; and VII. that negative impacts on the environment and on people’s environmental rights be anticipated and prevented, and where they cannot be altogether prevented, are minimised and remedied. (b) Environmental management must be integrated, acknowledging that all elements of the environment are linked and interrelated, and it must take into account the effects of decisions on all aspects of the environment and all people in the environment by pursuing the selection of the best practicable environmental option. (c) Environmental justice must be pursued so that adverse environmental impacts shall not be distributed in such a manner as to unfairly discriminate against any person, particularly vulnerable and disadvantaged persons. (d) Equitable access to environmental resources, benefits and services to meet basic human needs and ensure human wellbeing must be pursued and special measures may be taken to ensure access thereto by categories of persons disadvantaged by unfair discrimination.

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(e) Responsibility for the environmental health and safety consequences of a policy, programme, project, product, process, service or activity exists throughout its life cycle. (f) The participation of all interested and affected parties in environmental governance must be promoted, and all people must have the opportunity to develop the understanding, skills and capacity necessary for achieving equitable and effective participation, and participation by vulnerable and disadvantaged persons must be ensured. (g) Decisions must take into account the interests, needs and values of all interested and affected parties, and this includes recognising all forms of knowledge, including traditional and ordinary knowledge. (h) Community wellbeing and empowerment must be promoted through environmental education, the raising of environmental awareness, the sharing of knowledge and experience and other appropriate means. (i) The social, economic and environmental impacts of activities, including disadvantages and benefits, must be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment. (k) Decisions must be taken in an open and transparent manner, and access to information must be provided in accordance with the law. (o) The environment is held in public trust for the people, the beneficial use of environmental resources must serve the public interest and the environment must be protected as the people’s common heritage. (p) The costs of remedying pollution, environmental degradation and consequent adverse health effects and of preventing, controlling or minimising further pollution, environmental damage or adverse health effects must be paid for by those responsible for harming the environment.

All of the above principles have been considered when developing the environmental management measures for the Black Mountain Mine, documented in Section 9. Minerals and Petroleum Resources Development Act, Act 28 of 2002 (MPRDA) In the spirit of the MPRDA, the mine‟s objective is to change their attitude from one of compliance with environmental legislation to one of maximising the benefits of compliance. This will not be an instantaneous change and will only be realised through the commitment of all staff members. It is hoped that over time, personnel will be able to take the environmental concepts learned in the work place to their place of residence and /or home. National Water Act, Act36 of 1998 (NWA) Given that water is such a precious resource in South Africa, it is the mines objective to comply with the requirements and spirit of the NWA, through ensuring legal compliance. 8.2 Water Pollution The potential impact associated with water pollution has been considered for different activities of the operation hence compliance with the NWA is of particular importance. As the mine recognises the potential negative impacts associated with polluted water, it is their objective that no water polluted by mining activities will be used for domestic purposes or flow off the site. Using the water quality monitoring results and adhering to water use license (WULA), the mine will be able to determine if they are meeting their goal regarding water quality (i.e. compliance with the DWAF Water Quality Guidelines), viz. Conservation of Agricultural Resources Act, Act No. 43 of 1983 (CARA) Although many aspects of CARA are not applicable to mining operations, there are two aspects that are very applicable for which goals and objectives have been established, viz.:

Erosion control:

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- It is the mine‟s objective to minimise the loss of the topsoil resource in order to ensure an adequate supply of natural site soil for use in reclamation after mining operations have ceased. - In order to meet this objective, it is the mine‟s goal to ensure that areas where erosion has occurred in the past are managed in such a way that future erosion is prevented.

Alien vegetation control: - It is the mine‟s objective to prevent the spread of alien vegetation. - In order to meet this objective, it is the mine‟s goal to remove alien vegetation from the mining site and re-vegetate the cleared areas with indigenous vegetation. 8.3 Dust It is the mine‟s objective to control dust emissions from the activities of the operation through the implementation of management measures. In order to ensure that the management measures being implemented are successful (in order to achieve the objective), the mine will monitor dust fallout rates and compare the results with the SANS 19293. Using the results of this monitoring, the mine will be able to determine if they are meeting their goals regarding dust fallout (i.e. compliance with the SANS 19293), viz.

Source Based Goals: - Crushing operation: The absence of a visible dust plume from the crushers and screening operations.

Receptor Based Goals: - Off-site dustfall rates of <600mg/m2/day. - Boundary dustfall rates of <1 200 mg/m2/day. 8.4 Noise The mine‟s objective is to control noise emissions from the activities of the operation through the implementation of management measures. In order to determine if the mine is meeting their objective (by successfully implementing the management measures), boundary and off-site noise monitoring will be undertaken. Monitoring will aid in determining if the mine is achieving their goal - ensuring that boundary and off-site noise levels comply with the SANS 10103. 8.5 Blasting The mine‟s objective will be to ensure that blasting within the mining area does not cause any damage to off-site structures. In order to ensure that this is achieved, the mine‟s goal will be to ensure that airblast and vibrations caused by blasting are within the USBM acceptable limits. 8.6 Waste Management No matter how responsibly waste is disposed; there will always be potential for pollution. The only way to limit this pollution potential is to either improve the handling and disposal of waste (discussed below) or to minimise waste generation. In order to achieve this, the mine‟s objective is to minimise the volume of waste that has to be disposed. In order to achieve this objective, the mine‟s goals will be to:

Minimise the waste generation (in accordance with Waste Act -16(a)).

Reduction, re-use, recycling and recovery of waste where possible (in accordance with Waste Act - 17).

3 SANS 1929: Ambient Air Quality – Limits for Common Pollutants.

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Pollution is often associated with the incorrect handling and storage of waste. Therefore, the mine‟s objective is to avoid the generation of pollution associated with incorrect waste handling and storage. In order to achieve this, their goals will be to:

Manage waste in accordance with the National Environmental Management: Waste Act 2008.

Dispose of all waste in an environmentally responsible manner. 8.7 Rehabilitation Black Mountain Mine recognises that there are potential environmental impacts associated with un- rehabilitated areas, such as defunct and abandoned surface areas. The three main objectives for conducting concurrent rehabilitation are:

To ensure that the biodiversity and environment on the site is protected.

Reduce the closure rehabilitation liability both work load related and financially.

To make sure that the following commitments will be achieved as a minimum: - The site will be made safe for both humans and animals, - The site will be rehabilitated to be physically, chemically and biologically stable - The residual impacts will be managed to acceptable levels and will not deteriorate over time 8.8 Environmental Awareness Training The mine recognises that there are potential environmental impacts associated with human ignorance. Therefore, it is Black Mountain Mine‟s objective to educate their staff with regards to the environmental impacts associated with their job. The goal is then to reduce the number of environmental incidents as a result of human error through implementing the site specific environmental awareness training. 8.9 Socio-economic Goals and Objectives The social economic goals and objectives of the Black Mountain Mine presented in this section are taken directly from the Social and Labour Plan of Black Mountain Mine as follows:

8.9.1 Skills Development

The primary objective of the Human Resource Development Programme is to ensure the availability of mining skills and competencies of the workforce, as well as providing employees with portable skills that can be utilised outside of the mine, should the mine close. The operation therefore commits to fully implement the requirements of the Skills Development Act, and to the implementation of skills development programmes in accordance with the standards of the Mining Qualifications Authority (MQA).

8.9.2 Local Economic Development

The primary objective of the Company‟s Local Economic Development (LED) programme is to ensure the mine‟s commitment to the continued implementation and evaluation of an appropriate Local Economic Development Plan with the focus on sustainable development initiatives in local communities, based on impacts of the organization. This programme includes sustainable projects that the Company supports financially or otherwise in conjunction with the local municipality. Typical examples of projects supported or initiated by the operation in an effort to achieve the above objectives would be:

Economic growth: Development of local small businesses, including establishment of BEE businesses

Poverty alleviation: Job opportunities available to local residents through local recruitment program.

Human wellbeing – Community HIV/AIDS Initiatives, provision of Primary Health care providers and facilities.

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Human Resource Development – Additional teachers at the Primary and High Schools, and career guidance for High School learners.

Ensuring a safe environment – Support of Community Policing Forum.

Donation of land to government for the purposes of building the Police station at Aggeneys.

Conservation of natural environment – Support of the Bushmanland Conservation Initiative and Succulent Karoo Eco-system Project, and formal participation at forums associated with the environment and studies associated with conservation.

8.9.3 Black Economic Empowerment and Small, Micro and Medium Enterprises

The company supports the development of small business, especially those from the ranks of previously disadvantaged South Africans. This goal is driven through the Procurement Department through its procurement of capital goods, consumables and services, and the outsourcing of non-core activities to historically disadvantaged employees and assisting with the establishment of companies; to date four companies have been formed via this method. Black Mountain Mine – specific HDSA procurement targets (goals) for the last five (5) years were as follows: Figure 8-1: The black mountain HDSA/BEE spend targets (BMM SLP, 2009) YEAR TARGET TARGET ACTUAL/FORECAST 2008 22% of Discretionary Spend 47% 2009 24 % of Discretionary Spend 51% 2010 26% of Discretionary Spend 56% 2011 28% of Discretionary Spend 58% 2012 30% of Discretionary Spend 60%

8.10 Heritage Goals and Objectives Given that heritage resources have been observed on the property, it is the mines objective to comply with the requirements of the National Heritage Resources Act, No. 25 of 1999, through ensuring legal compliance. 8.11 Closure Goals and Objectives According to current planning, the Mine has five years‟ operational life remaining as closure is expected in 2018. Since the mine only has five years operating, a detailed Social Closure Plan (SCP) has been formulated in 2009 which will be implemented during closure. However this document should be regarded as a living document, which will continuously be refined and built upon in order to provide BMM a clear indication of how sustainable closure will be ensured. Closure Objectives for BMM are therefore as follows:

to make the area safe;

to stabilise the area against wind and water erosion;

to prevent air and water pollution;

to establish stable vegetation cover; and

to limit the area which may have to be environmentally managed to as small an area as is practical.

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9 ENVIRONMENTAL MANAGEMENT AND MONITORING

The potential impacts associated with the proposed mining operation have been outlined and evaluated in Section 6 of this report. This section of the report provides a description of the management measure to be implemented to prevent / minimise / mitigate / manage the identified impacts (taking cognisance of the principals of NEMA). In order to facilitate the review process and the implementation of the management programme, this section of the report has been set out in the same sequence as the Process Description in Section 1 and the Impact Assessment in Section 6, providing management measures for impacts ranked as having a MEDIUM to Extremely HIGH significance ranking. In some cases, management measures have also been proposed for impacts of LOW significance, in order to ensure that the significance of these impacts do not increase with time. The presentation of the management measures / the Management Programme has been set out providing the following information in order to meet the requirements of the MPRDA:

The goals and objectives that may be applicable to that activity (if any).

The significance ranking of the impact.

The action plans / management measures that must be implemented.

The time frames for implementation. 9.1 Environmental Management for Topography Table 9-1: Environmental Management for Topography IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON Maximise the packing of waste material back in the On-going Mining Section Manager stopes and minimise the haulage of waste to the surface waste dump. Regular bulletins should be produced to the Six monthly Mining Section Manager Authorities indicating targets and milestones achieved in this regard. This will necessitate the detailed scheduling of waste and ore development as a major component of the mine planning process. 9.2 Environmental Management for Geology Table 9-2: Environmental Management for Geology IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON Habitat destruction and disturbance: On-going Environmental Manager Close site supervision must be maintained during construction of operations upgrades or maintenance and must adhere to sound environmental management as advised by BMM EMPr. Minimal disturbance to vegetation where such vegetation does not interfere directly with the construction or maintenance operations of BMM. Severe contractual fines must be imposed and immediate dismissal on any contract employee who is found attempting to snare or otherwise harm wild animals. No animals should be intentionally killed or destroyed and poaching and hunting should not

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IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON be permitted on the site. Consideration could be given to rescuing the burrowing animals where there burrows are found in advance of any mine activity. Alien Vegetation Clearing; mesquite (Prosopis Five years Environmental Manager spp.): All alien vegetation should be eradicated. Invasive species Prosopis spp. and Gomphocarphus fruiticosus (Asclepias) should be a priority. The Department of Water Affairs (DWA) provides assistance to the private sector for alien clearance work. It is strongly encouraged that the DWA should endorse the implementation programme for alien vegetation clearance and control. Plant indigenous tree for every alien removed Monitor of clearing operation Follow-up and assessment of quality of work Land Rehabilitation: Ongoing Environmental Manager Revegetation needs to take place with topsoil that has the surrounding vegetation seedbanks. Badly damaged areas shall be fenced in to enhance rehabilitation. Areas to be rehabilitated must be planted with a mixture of local pioneer species indigenous to the area, as soon as the new growing season starts. To get the best results in a specific area, it is a good idea to consult with a vegetation specialist or the local extension officer of the Dept of Agriculture. Seed distributors can also give valuable advice as to the mixtures and amount of seed necessary to seed a certain area. Re-seeding, as well as fencing in of badly damaged areas, will always be at the discretion of the Environmental Control Officer and in compliance with BMM‟s EMPr. Stormwater Management, Effluent Discharge Immediately Environmental Manager Control: Integrated water and waste management (IWWMP) plan be commissioned and a stormwater management plan by upgraded and updated. This IWWMP must include an Integrated Water Quality Management Plan (IWQMP).

9.3 Environmental Management for Ground Water Table 9-3: Environmental Management for Ground Water TIME FRAME RESPONSIBLE PERSON IMPACT: MANAGEMENT & MITIGATION

The mine water-balance should be revised and On-going Environmental Manager water should be recycled to minimize disposal of excess water. Plant run-off should be managed effectively. On-going Processing Section Manager Chemicals gathered in the oil trap system should be

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taken to a suitable registered place of disposal.

Further growth of the slimes dam should be vertical On-going Processing Section Manager and not lateral. This will minimize groundwater infiltration from the slimes dam pond. The slimes are in general 2 – 3 orders less permeable than the sand. Liming of plant water should continue. Processing Section Manager 9.4 Environmental management for heritage resources Table 9-4: Environmental Management for heritage resources IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON With respect to heritage sites: Ongoing Environmental Manager should be maintained according to a minimum standard and procedure prescribed by the heritage resources authorities; and to obtain a permit for any alteration to, damage, destruction, relocation, subdivision or changing of planning status of such a site; In relation to protected areas or heritage areas: When necessary Environmental Manager to consult the relevant heritage resources authority before damaging, disfiguring, altering or in any way developing any part of a protected area; and to obtain the consent of the relevant local authority for any alteration or development affecting a heritage area In relation to provisionally protected places or When necessary Environmental Manager objects (if such should exist): to obtain a permit from the relevant heritage resources authority or local authority before damaging, disfiguring, altering or in any way developing any part of a provisionally protected place or object; and to obtain the consent of the relevant local authority for altering or developing or affecting a place listed on a provincial heritage register In relation to graves or burial grounds: ongoing Environmental Manager to obtain a permit from the relevant heritage resources authority before destroying, damaging, altering, exhuming or removing from its original position or otherwise disturbing, the grave of a victim of conflict or any burial ground which contains graves of victims of conflict; and to obtain a permit before destroying, damaging, altering, exhuming, or removing from its original position or otherwise disturbing any grave or burial ground that is older than 60 and which is situated outside a formal cemetery And otherwise: When necessary Environmental Manager to notify the heritage resources authority before undertaking a development of the kind named in SAHRA, and in certain circumstances submit an impact assessment report to the heritage resources authority; to obtain a permit before destroying, damaging,

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IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON excavating, altering, defacing or otherwise disturbing or removing from its original position or dealing with any archaeological or palaeontological site or meteorite or using any excavating equipment at an archaeological or palaeontological site; to obtain a permit from the provincial resources authority before altering or demolishing any structure or part of a structure that is older than 60 years; and to report the finding of any archaeological or palaeontological object or material or meteorite to the relevant heritage resources authority. In relation to heritage objects: When necessary Environmental Manager to inform SAHRA of dealings in respect of such objects; to obtain a permit from SAHRA before carrying out restoration work or repair on a heritage object listed in Part 2 of the heritage register; and to obtain a permit before destroying, damaging, disfiguring or altering any heritage object Internal capacity, organizational structures and Annually Training Manager and co-operative governance: Environmental Manager to It is desirable that environmental management staff approve training at Black Mountain Mining should be sensitized concerning heritage resources and be equipped to exercise basic oversight in this sphere. Compile general procedures and guidelines for Immediately Environmental Manager heritage management (refer to Chapter 5 of the heritage study undertaken in March 2013 for what needs to go into the guidelines) Non-spatial heritage management priorities: Within five years Training Manager and Existing environmental management staff need Environmental Manager to to be sensitized to the needs of heritage and approve training heritage site management. Training for relevant environmental management personnel is recommended to enhance their capacity to implement heritage management. Making heritage an integral part of the work of people whose primary responsibility might be in other spheres of mining and development activity or nature conservation. BMM heritage management should focus on establishing and strengthening stakeholder engagement in heritage resource management and that this be focused on proactive approaches. There are many ways in which stakeholders can be engaged in heritage resource management planning, ranging from providing information, representation on committees and consultation through participation, to full engagement through partnerships and co-management agreements.

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IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON Heritage resources, their significance, interpretation and management may become the subjects of dispute and contestation. It is therefore important to anticipate such potential disputes in planned approaches to stakeholder engagement in heritage resource management. Databases being developed on an ongoing basis that will need to be integrated into BMM management include Developing sustainable relationships and data- sharing agreements with data suppliers. This may include universities, research institutes, museums, and interest groups. Identifying “orphan” databases and ensuring that this information is not lost to society: There are cases where an individual/group may gather valuable information about a particular resource. As interest rather than legislation or mandate drives such processes, it is essential that these are identified and recorded before being lost. An example may be a private collection of stories or oral histories. It is essential that BMM management should engage Boswa, SAHRA and other management bodies developing heritage resource inventories on the issue of compatibility and integration. SAHRA has already established and formalized heritage inventory standards by way of SAHRIS Engage the relevant interest group/s and jointly implement a project to research and gather the information. The following are priorities: i) Archaeological sites. The known distribution of archaeological sites in BMM properties is almost certainly not a true reflection of the total archaeological resources of BMM. Further archaeological research/survey must be undertaken in areas not systematically investigated thus far. This is imperative in areas of increased mining and development, before potential sites are negatively impacted. ii) Indigenous knowledge systems. It is not known to what extent indigenous knowledge survives in the vicinity of BMM with respect to sites and natural resources. Research is needed on this. iii) Audit of structures older than 60 years old. Probably very few structures on BMM property are older than 60 years. Some might have significance and others not. The results of such an audit should be captured on the heritage inventory and used to inform operational management. iv) Cultural landscapes. Cultural landscapes are receiving more attention in heritage management in South Africa and are particularly pertinent in BMM in relation to

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IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON the history of the last independent Khoisan people of the area.

9.5 Environmental Management for Visual / aesthetic value Table 9-5: Environmental Management for visual/aesthetic value IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON Visual associated with the expansion of the tailings Ongoing Processing Section Manager and dam: Environmental unit The height of the tailings dam should not be increased beyond 1 ½ times its current height in order to reduce the potential for visual intrusion, Similar material to what was previously placed on the tailings dam should continue to be placed on it, in order to retain the colour and texture of the feature, and laterally in order not to create a new feature in the environment. Landscape the shaped upper perimeter and outer slopes of the tailings dam and associated infrastructure to blend into the surrounding landscape. Where applicable, encourage the establishment of native vegetation to „soften‟ the created landform. Material or vegetation should not be imported onto the ash dam if it were to provide a significant visual contrast with the surroundings (i.e. more so than that of the current tailings dam), as this would counteract the aim of blending the tailings dam in with the natural surroundings. As such vegetation indigenous to the area, and rock of a similar colour to the hills in the surrounds should be used for this purpose. Expansion Swartberg Waste Rock Dump and ongoing Mining Section Manager Broken Hill waste rock dump: The waste rock should continue to be dumped on the lower western slopes of the Swartberg Mountain and not be vertically raised. If building rubble is dumped on this waste rock dump, at closure (mine decommissioning) the mine operators should ensure that natural rock is placed on the outer surface of the dump to ensure that the dump appears similar in colour to the surrounding mountainside. Building rubble could create a visual contrast and thus should not be left visible.

9.6 Environmental Management during Underground Mining Table 9-6: Environmental Management during underground mining IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON Use of P.P.E. in noisy areas On-going Section Manager Carry out scheduled planned maintenance On-going Engineering Section Manager

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IMPACT: MANAGEMENT & MITIGATION TIME FRAME RESPONSIBLE PERSON Undertake energy use monitoring and keep records Monthly Environmental Manager and Engineering Section Manager Use pre-use checklist during oil spills inspections ongoing Section Manager Planned maintenance Ongoing Mining Section Manager and TMM Engineering Section Manager Construct settling systems Once off and as needed Engineering Section Manager Construct oil separation system and ensure it is well Once of and as needed Engineering Section Manager maintained Implement waste management procedure On-going Mining Section Manager Use only water based paint for face marking On-going Mining Section Manager Waste drill bits, old drill steel and old hoses: Ongoing Environmental Manager and Implement the waste management procedure and Commercial Section Manager ensure waste is disposed of appropriately Keep records of proof of disposal Oil spills: Ongoing Mining Section Manager Maintenance of raise bore Explosive Packaging: Ongoing Mining Section Manager Implement explosives procedure andrefer to explosive risk assessment form safety Redundant Explosives: Ongoing Mining Section Manager Implement the procedure for storage and destruction of old explosives Contaminated groundwater: Ongoing Chief Geologist Drilling contractor shall pickup ground water sources before blasting. Geological model of ore body is used to determine high potential areas. Apply plugging procedure to avoid groundwater pollution. Shock and vibrations: .On-going Mining section Manager Explosive volumes should be predetermined and loading accurately for stope only Gasses & Fumes: On-going Ventilation and Occupational Maintain ventilation system Health Manager Carbon Emissions and Fumes: Ongoing as per schedule Engineering Section Manager Planned maintenance Heat: Monthly Engineering Section Manager and Monitor energy use and report any drastic changes Environmental Manager Ore Spills: Daily Mining Section Manager Cover the ore during collection and avoid overloading. Dust suppression by watering around the ore and Daily Mining Section Manager waste rock piles. PPE required for all persons underground. 9.7 Environmental Management for Waste Management Table 9-7: Environmental Management for waste management IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Domestic Waste: Waste sorting: Annually Environmental Manager Maintain and update waste stream

There should be a dedicated waste management On-going Environmental Manager and contractor on site. Commercial Manager Investigate options of using different colour bags for On-going Environmental Manager household recycling

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Provide to household and co-ordinate waste On-going Environmental Manager sorting site in town and notify residents of process

Separate waste at end use to the following Ong-going Commercial Manager and waste waste streams: recycling company - Tins - Paper - Glass - Plastics - Electronic Waste Reduce volumes of hazardous waste disposed Ongoing Environmental Manager Store scrap wastes in the salvage yard. Dedicated Daily Mining Section Manager contractor should be appointed for the salvage yard maintenance. Evaluate alternative cost and effective ways of Once off Environmental Manager dealing with hazardous waste (e.g. reducing volumes of oily rags; reducing volumes of contaminated soils)

9.8 Environmental Management during Ore handling Deeps Underground, Surface Conveyors, Waste Rock Dump & Tony’s dam Table 9-8: Environmental Management for Ore handling IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON

Energy monitoring and reporting Monthly Engineering Section Manager and Environmental Manager Carry out scheduled planned maintenance On-going Mining Section Manager Pre-use checklists during inspections On-going Mining Section Manager

Hazardous Waste Management Procedure & On-going Mining Section Manager Incident Management Procedure All persons underground must wear PPE for dust. On-going Mining Section Manager There should be limited access to rock breaker by third parties. Install underground ventilation system On-going Ventilation and Occupational Health Manager Ore rock is temporarily stored at rock breaking and On-going Mining Section Manager then transported for re-used for backfilling purposes. Undertake noise measurements. Monthly Ventilation and Occupational Health Section Manager for noise measurements.

Undertake regular servicing of machines Monthly Engineering Section Manager for servicing of machines Salvaging or re-use of conveyor belts by dedicated When necessary Mining Section Manager contractor if possible or removal off site. Regular servicing of machines On-going Engineering Section Manager Implement waste management procedure and avail On-going Mining Section Manager spill kits. Down cast shaft dust is pulled into mine On-going Mining Section Manager Extended impact when wind conditions move dust. When required Mining Section Manager PPE not worn when dust not obviously visible or nuisance. Mining cleaning team should be notified of spillages During spillage Employees when required.

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Rope grease on Deeps platform. Picked up when Ongoing Engineering Section Manager required. Implement hazardous waste Management Procedure & Incident Management Procedure Place hazardous waste and hydrocarbons in Ongoing Mining Section Manager bunded area with gravel pit.

Undertake regular maintenance and planned On-going for Planned Engineering Section Manager and inspections. maintenance Mining Section Manager

Transformer oil should not be mixed with used oil When required Engineering Section Manager and tanks at main workshop. Used oil collecting Mining Section Manager company to take transformer oil for recycling.

Transformers should be placed in bunded area and Ongoing Engineering Section Manager and spill kits should be in place Mining Section Manager Salvaging or re-use of parts and sale of scrap metal When necessary Waste recycling contractor and by dedicated contractor. Commercial Manager Hazardous Waste Management Procedure & On-going Engineering Section Manager and Incident Management Procedure Mining Section Manager Clean dirty water management at Broken hill only. As per project plan Environmental Manager Implement the Integrated water management project Ground water monitoring of Swartberg and Broken Quarterly Environmental Manager Hill ore rock dump

9.9 Environmental Management during Crushing Table 9-9: Environmental Management for crushing IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Energy monitoring and reporting Monthly Engineering Section Manager and Environmental Manager Undertake noise measurements and regular On-going for Planned Engineering Section Manager and servicing of machines maintenance Mining Section Manager

Salvaging of equipment waste by dedicated Ongoing Environmental Manager contractor Implement dust control measures on the ore Daily Mining Section Manager The works order schedule should be followed and Daily Mining Section Manager planned maintenance schedule be implemented. On maintenance and breakdown spillage should be Daily Mining Section Manager picked up as part of work. Used oil collected, separated and sent for recycling Ongoing Environmental Manager Use Hazardous Waste Management Procedures Daily Engineering Section Manager and Mining Section Manager Conduct scheduled maintenance. Monthly Engineering Section Manager and Mining Section Manager Calibrate instrumentation and supervise the Quarterly Mining Section Manager patrolling of belts Belt picking and communicate with mining section Daily Engineering Section Manager and Mining Section Manager Installation of dust suppression system for Daily Engineering Section Manager treatment of the dust Energy monitoring and reporting Monthly Engineering Section Manager and Environmental Manager Salvaging of equipment waste should be Monthly Environmental Manager undertaken by dedicated contractor Hazardous Waste Management Procedure should Monthly Engineering Section Manager and

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IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON be followed Mining Section Manager Contaminated oil spillage should be contained in Monthly Engineering Section Manager and bunded walls Environmental Manager

Metal detector, belt picking on crusher discharge Daily Engineering Section Manager and conveyor and chute cleaning should be checked Mining Section Manager daily. Polluted water should be cycled in closed system to Daily Engineering Section Manager and tailings dam - not back to other water uses Mining Section Manager Hazardous Waste Procedure should be Monthly Engineering Section Manager and implemented and there should be no hazardous Mining Section Manager waste directly in contact with topsoil.

9.10 Environmental Management during during Milling and Aeration Table 9-10: Environmental Management for milling and aeration IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Energy monitoring and reporting Monthly Engineering Section Manager and Environmental Manager All spills should be contained on cement flooring When necessary Processing Section Manager and should be removed as required. Waste water used on contained cement area and Daily Processing Section Manager should be recycled back to process. Hazardous Waste Management Procedure & When necessary Processing Section Manager Incident Management Procedure should be implemented during spills Undertake noise measurements and there should Monthly Engineering Section Manager and be regular servicing of machines Mining Section Manager Salvaging of equipment waste by dedicated Monthly Environmental Manager contractor Lime waste should be re-used in processing as Daily Processing Section Manager lime is not hazardous. Used oil should be collected, separated and sent for When necessary Processing Section Manager and recycling Engineering Section Manager Girth gear oil should be sent away as general Monthly Processing Section Manager waste. All Magnetic separation waste water should be Daily Processing Section Manager reused in the process. Build an isolated cement and sump system at plant Daily Processing Section Manager to recycle all slurry spills back to Process Ear protection is compulsory in noisy areas. Daily Processing Section Manager Waste disposal procedure should be followed and Daily Waste collection contractor to registered waste site should be used and proof of collect and keep records of waste, disposal be available on records. Processing Section Manager to ensure procedure is followed 9.11 Environmental Management during flotation64, thickening and filtration Table 9-11: Environmental Management for flotation, thickening and filtration IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Monitor energy use and keep records Monthly Engineering Section Manager and Environmental Manager Maintenance and replacement of pipes should be On-going Plant Engineering Section undertaken Manager Slurry and waste water to be isolated, contained, On-going Processing Section Manager recycled back into process and/or tailings dam. Waste water should be reused. On-going Processing Section Manager

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IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Implement Hazardous Waste Management On-going Processing Section Manager Procedure Salvaging of equipment waste should be done by a On-going Waste recycling contractor dedicated contractor Isolated cement and sump system at plant to On-going Processing Section Manager recycle all slurry and waste water spills back to Tailings dam. Storm water outflows should be contained in Storm On-going Processing Section Manager Water Dam. Hazardous Waste should be contained in bunded / On-going Processing Section Manager cement area. There should be emergency preparedness and On-going Environmental Department, response procedures and staff should be trained. Training department during site induction, Processing Section Manager Isolated cement and sump system at plant to On-going Processing Section Manager recycle all slurry spills back to Tailings dam PPE is required to handle any spills On-going Processing Section Manager Used oil should be collected, separated and sent for On-going Plant Engineering Section recycling Manager, Processing Section Manager 9.12 Environmental Management for Tailings Table 9-12: Environmental Management for tailings IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON

Isolated cement slurry and sump system at plant to Daily Processing Section Manager recycle all slurry spills back to Tailings dam There should be bund walls around pipelines to Once off Processing Section Manager tailings dam to contain spillage. There should be limited exposure and machines to On-going Processing Section Manager people on tailings dam. An additional drain should be installed to prevent Ong-going Processing Section Manager and ground water pollution Environmental Manager There should be pre-use checklists during Weekly Processing Section Manager inspections,

Ensure there is planned maintenance, Monthly Processing Section Manager

The hazardous Waste Management Procedure for Daily Processing Section Manager the tailings should be followed

Incident Management Procedure should be Daily Processing Section Manager followed for the tailings.

Freeboard should be maintained, monitored and On-going Processing Section Manager deposition controlled according to legislation Inspection should be undertaken at tailings dam. Daily Operator Day shift deposition should be in limited areas. Night shift deposition should be in extended area and when piping secured. Spillage contained in tailings demarcated area Processing Section Manager except for pipelines in bund wall. Spillage removed to tailings dam paddocks. New tailings dams should be lined Once off Processing Section Manager

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Dust monitors should be in place on tailings. Annual Trenches should be lined Once off Processing Section Manager Ageing pond should be lined Once off Processing Section Manager Conduct Inspection schedule is the responsibilities Processing Section Manager of the operators, management Tailings dam should be fenced and locked for On-going Processing Section Manager access. No entry signs should be placed Waste water should be re-used On-going Processing Section Manager Isolated cement and sump system at plant to On-going Processing Section Manager recycle all spills back to Tailings dam except for certain storm water outflows

9.13 Environmental Management during Backfill Table 9-13: Environmental Management for backfill IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Implement dust control measures. Ong-going Backfill Section Manager Carry out noise measurements and regular servicing of machines. Implement Hazardous Waste Management Backfill Section Manager Procedure & Incident Management Procedure Ensure there are pre-use checklists, planned Backfill Section Manager maintenance, Hazardous Waste Management Procedure & Incident Management Procedure Monitor the backfill & report Backfill Section Manager

Undertake pre-fill checks & constant monitoring Backfill Section Manager Install filter system Backfill Section Manager Use PPEs, monitor & report Backfill Section Manager to enforce this Undertake planned maintenance. Backfill Section Manager Undertake ad-hoc monitoring and reporting Backfill Section Manager Undertake pre-use inspection and constant Backfill Section Manager monitoring Undertake planned inspections. Backfill Section Manager Undertake annual swab tests, Annual Nuclear waste box emptied by dedicated Hazardous waste contractor contractors Radio-active leakage tests should be done on all Annual Backfill Section Manager nuclear sources on site and monitoring equipment should be calibrated annually. The instrumentation should be isolated and Weekly Backfill Section Manager encased in lead with a lead shutter to isolate any release. The casing is designed to be fall proof. Lead compaction is likely to take place instead of breakage. Nuclear emergency procedure should be in place. Nuclear emergency procedure in place. All Annual Backfill Section Manager technicians trained in radiation and dosy metering to identify and treat such cases. All new employees are trained after permanent appointment. Backfill should be pushed into bunker by front end Monthly Backfill Section Manager to loader ensure that this is done Backfill screening should be undertaken at sand On-going Backfill Section Manager dune mining Profil is not a hazardous substance but should be Ong-going Backfill Section Manager placed on bunded cement area

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IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Salvaging equipment should be undertaken by On-going Waste recycling contractor to dedicated contractor. collect waste and Backfill Section Manager to ensure correct disposal in his/her section UG water should be recycled for Backfill On-going Backfill Section Manager Backfill should be stored in bunded area before On-going Backfill Section Manager disposal by backfill personnel Pre-use inspections and monitoring during fill On-going Backfill Section Manager to process ensure that this is done Backfill waste disposal should be through by means On-going Backfill Section Manager of a pumping system Planned maintenance should be undertaken On-going Backfill Section Manager There should be backfill system monitoring and Monthly Backfill Section Manager reporting Drive on approved roads only On-going Backfill Section Manager to ensure that this is done Load backfill spillage and tipped into old areas On-going Backfill Section Manager Where possible loaded backfill spillages normally On-going Backfill Section Manager will be covered with waste rock when constructing ramp for next lift Backfill pipes should be removed during next lift On-going Backfill Section Manager and backfilled in next stope Back fill waste water should gravitate via drain Backfill Section Manager holes to dams and pumped to surface Water drain into sump at Backfill plant and is When required Backfill Section Manager pumped to tailings dam

9.14 Environmental Management during Storage of finished products Table 9-14: Environmental Management for storage of finished products IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Carry out energy monitoring and report Environmental Manager and Engineering Section Manager Ensure there are cement paddocks underneath the Weekly Processing Section Manager conveyor system. Concentrate paddocks should be cleaned regularly. Stockpile should be enclosed and should have Om-going Processing Section Manager approximately 10% moisture. There should be a dedicated waste management Om-going contractor on site. Where loading takes place, the area should be Om-going cemented and contained PPE should be worn by all third parties passing by Om-going Processing Section Manager and there should be roll up doors to limit exposure. When oil mixes with dust on cement areas it should Om-going Processing Section Manager be washed off into spillage pumps to tailings dam. There should be pre-use checklists and planned Om-going Processing Section Manager maintenance Copper, Zinc and Lead should be contained in Om-going Processing Section Manager cemented enclosed shed. Dust should be contained in shed. Om-going Processing Section Manager Moisture content should be controlled before Om-going Processing Section Manager stockpiling to ensure high moisture content. Storage pad should be cemented. Spillage from Om-going Processing Section Manager cemented area is flushed to spillage sump and pumped to tailings dam.

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IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON

There should be periodic planning meetings. As per plan Processing Section Manager

9.15 Environmental Management during Dispatch of products Table 9-15: Environmental Management for dispatch of products IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Energy use should be monitored and reported Monthly Engineering Section Manager and Environmental Manager Ensure there are pre-use checklists, Before vehicle use Logistic Manager and concentrate transporting contractor Implement waste management SOP On-going Check the weight of concentrate load in trucks and Logistic Manager and concentrate keep records transporting contractor Ensure safety chain is in place to avoid flaps falling During each trip Logistic Manager and concentrate open and spill concentrate. Competent drivers transporting contractor should adhere to speed limits and truck trailers should be sealed at bottom. Regular maintenance of gravel road and implement Daily Road maintenance contractor dust control measures Concentrate should be sealed in bin. During each trip Logistic Manager and concentrate transporting contractor Trailer should be closed with tarpaulin and net. During each trip Logistic Manager and concentrate transporting contractor There should be planned maintenance As per vehicle Logistic Manager and concentrate maintenance transporting contractor Undertake regular servicing of machines As per vehicle Logistic Manager and concentrate maintenance transporting contractor Where off loading takes place the area should be On-going Logistic Manager and concentrate contained and cemented transporting contractor PPE should be worn by all third parties passing by On-going Logistic Manager The moisture should be maintaining above 5%. On-going Logistic Manager Wind breaker barriers should be in place and sliding doors should enclose the area and limit exposure. When oil mixes with dust on cement areas, these On-going Logistic Manager should be disposed of as per waste management procedure. Drip trays/pans should be in place below engine On-going Logistic Manager and at diesel tank transfer points.

Salvaging of equipment waste should be the On-going Waste recycling contractor responsibility of BMM salvage yard personnel Copper, Lead and Zinc should be contained in On-going Logistic Manager cemented enclosed shed. Asbestos sheets should be replaced by cement On-going Logistic Manager, Engineering sheets and broken edge of asbestos should be section Manager, Environmental sealed as per Asbestos OSHAS regulations and Manager, Safety Manager Waste handling procedure 40.

9.16 Envronmental Management for Waste Rock Table 9-16: Environmental Management for waste rock IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Extend the footprint of the waste rock as required Once off Mining Section Manager External verification of waste rock dump stability Every 2 years Mining Section Manager

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IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON should be undertaken. There should be access control - chain barricade Daily Mining Section Manager which is locked and only opened by security posted at decline entrance. All access is logged in security book by guard There should be monitoring checklists for the active Quarterly Mining Section Manager waste rock dumps Soil and Dust baseline and impact monitoring Annual Mining Section Manager should be undertaken. Ensure Stability of the dumps Ongoing Mining Section Manager Implement dumping management where which Ong-going Mining Section Manager material should be dumped. There should be designated dumping areas and signage. (Building rubble, waste rock, quartzite material) Carry out inspections and audits Weekly inspections and Mining Section Manager to carry annual audits out inspections and Environmental Manager to conduct audits Water should be contained on the surface in a series of small pools to assist in neutralizing acid released due to pyrite weathering in the dump and preventing storm water washing directly onto the off dump area before being neutralized Place one groundwater monitoring borehole near Quarterly Environmental Manager the mine property boundary to the west of the waste dump. The groundwater quality will be monitored periodically at this site in order to assess the effectiveness of the mitigation measures undertaken. The size of the waste dump at any one time should On-going Mining Section Manager and be maintained at a minimum by the scheduling of Environmental Manager mining operations to enable maximum waste development to be packed underground without haulage to the surface. Update original design with operational progress Annual Closure report to guide the closure designs Five years before closure Mining Section Manager, Engineering Section Manager, Environmental Manager

9.17 Environmental Management for Hydrocarbon Table 9-17: Environmental Management for hydrocarbon IMPACT: MANAGEMENT & MITIGATION TIME FRAMES RESPONSIBLE PERSON Equip 45 Level workshop with adequate oil Once off TMM Section Engineer separating units Install Oil separator at 34 Level workshop Once off TMM Section Engineer Commission Oil separator at 40 Level Workshop Once off TMM Section Engineer Change degreaser used underground from solvent Once off TMM Section Engineer based to water based in order to ensure oil separation effectiveness. Monitor effectiveness of 40L oil separator through Once off TMM Section Engineer sampling and testing. Reduce transport/material handling for reduced Once off TMM Section Engineer spillage Investigate the conveyance of old and new oil via Once off TMM Section Engineer the shaft.

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10 ENVIRONMENTAL AWARENESS PLAN

The information on this section is extracted from BMM‟s Environmental Communication and training standard operating procedure document. The main objectives of this document are to:

Identify environmental training and development needs as required by section 4.4.2 of the Environmental Management System standard ISO 14001; and

Ensure - Perceptual Awareness; - Knowledge transfer; - Environmental Ethic and - Skills and Action to implement environmental management mine wide.

10.1 Environmental Training and communication approach The Black Mountain environmental training approach is designed to achieve the environmental training aim and objectives of Black Mountain. The approach is Outcomes based and the outcomes to measure the effect of the training is:  A decrease and/or limit environmental incidents  Increase management and reaction of environmental incidents and audit results,  Achieve corporate environmental targets in all areas and levels of operation. Allocating the training according to training needs ensures that the training is proactively aligned with individual environmental responsibility.

Training is a line management function.

The training and communication syllabus includes, but is not limited to, specific environmental procedures applicable to Black Mountain mine wide (eSS 031).

10.1.1 Identification of training needs

Environmental training needs for each section should to be identified and addressed to ensure environmental management is part of day to day operations.

The environmental risk responsibilities guide the training requirements of each individual. The responsibility for each level of management according to the Integrated Risk Management and ISO14001 role descriptions are outlined in eSS 035.

Environmental training recommended for the different levels of management as set out in eSS 031 guide the training needs identification process. This is a minimum guideline and any additional training can be added where section specific issues or high risk items require training and awareness (for example, the Cyanide COP that is a high environmental risk issue, but only applicable to a small number of persons at the Plant)

It is the responsibility of the line manager to ensure environmental training needs for individual staff members are identified, agreed to, facilitated and tracked according to eBMF 051.

10.2 Induction

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Black Mountain Mine offers four types of induction: annual general induction, site specific induction, visitor‟s induction, visitor‟s on-site induction.

General Induction is presented at the Black Mountain training centre, visitor‟s induction is presented at the Black Mountain security office and on-site induction is facilitated by the section head and presented at the relevant section.

All employees attend annual induction training when initially employed and upon return from annual leave. All contractors attend BM induction training before commencing work and, should they remain on site, annually thereafter.

All employees are required to obtain specific on-site induction before work commence at a specific section that includes relevant environmental issues. This induction can also be repeated annually. On-site induction should be signed off and records kept at the section.

All visitors attend visitor‟s induction at security before accessing Black Mountain. The visitor‟s induction remains valid for the period specified by security. Re-entry by the same visitor will require attendance of visitor‟s induction if the validity period of the previous induction has expired. It is the responsibility of the person receiving visitors to ensure the persons have been inducted.

Visitor‟s on-site induction is conducted when and where required depending on the activities and areas that will be accessed by the visitor (for example, all visitors to Gamsberg receive onsite induction). The supervisor of the section decides whether or not on-site visitor‟s induction is required according to the activities and areas that will be accessed.

10.2.1 Environmental Procedure Training

All employees and business partners must be able to understand and apply ISO 14001 procedures relevant to them in their section (as listed in eSS 031)

It is the responsibility of the line manager to facilitate environmental procedure training either by allowing staff to attend training presented by the environmental unit, getting an external presenter; or using the procedures to train the staff him-/herself.

Records of training attendance should be kept at the section for tracking purposes

10.2.2 Training material development and review

Environmental Training register will be updated according to training presented by the environmental department for record keeping purpose.

The Environmental officer is responsible for develop and updating training material when changes to procedures, policy or legislation occur.

Updated training material should be distributed to Human Resources – training Centre and EMS members.

10.2.3 Training Assessment

The line managers at the sections are responsible for conducting a personal tasks observation (PTO) after training has been presented by the environmental officer at the specific sections.

The Environmental officer will verify the completed PTO`s at the specific sections and feedback will be given to the section line manager.

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10.3 Environmental Communication and Awareness Environmental communication and awareness is a mine wide responsibility that is facilitated by the environmental unit and line managers. The environmental unit compiles and ensures distribution of the following communications: - Daily environmental communication on the Toolbox talk; - Monthly discussion topics - Joint SHE presentations - EMS presentations every second month - SHE Representative training - Electronic correspondence to EMS members of specific issues

Line management facilitates knowledge transfer of the above communications to all employees by means of daily toolbox meetings, communication meetings or any other suitable means.

Line managers that facilitate or provide environmental communication and training should ensure that it is specific and that records of knowledge transfer can be tracked (for example by completing and signing eBMF 003).

Communication and awareness also takes place through the display of environmental topics and issues on display notice boards.

10.4 External Environmental Awareness Courses As the environmental awareness of employees is often carried out by Black Mountain Mine staff members, it is important to ensure that these staff members are able to provide employees with the necessary information and understanding. Therefore, Environmental Unit's personnel have attended the following courses:

Environmental Law short course at North West University

Water quality monitoring short course at North West University

Implementing ISO 14001 short course at North West University

Environmental Lead Auditor short course at North West University

Environmental Risk Assessment Management based on ISO 31000 short course at North West University

Carbon footprint analysis short course at Global Exchange

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11 FINANCIAL PROVISION ESTIMATION

The financial provision section is divided into 2, namely, the ongoing environmental management costs associated with the implementing of the management measures documented within this environmental management programme, and, the financial provision required for the final rehabilitation of the mine. 11.1 Quantum of Financial Provision [Regulation 54(1)] In order to calculate the Financial Provision, BMM, uses the DMR “Guideline Document for the Evaluation of the Quantum of Closure Related Financial Provision Provided by a Mine”, Revision 1.6, published in September 2004 (DME, 2004). Black Mountain Mine will make financial provision for rehabilitation in the manner envisaged in terms of Section 9 (5)e of the Minerals Act in order to meet the long-term liability of rehabilitation once the mine has ceased production. Black Mountain Mine makes contributions to the trust fund created in terms of Section 10 Para (cH) of the Income Tax Act No. 58 of 1962. The amount to be invested annually will be dependent on the required rehabilitation work that will still need to be done at the end of the mine‟s life, taking into account rehabilitation work completed concurrently while in operation. The extent and cost of this work will be estimated with reference to the life of mine plans. The annual contribution will be influenced by the estimated earnings to be made by the fund as well as the financial position of the mine. Budgets and forecasts will be used to project contributions for future years over the life of mine. Consideration also needs to be given to the value of assets available for disposal at the end of the life of the mine as realisation of these assets clearly would also go towards rehabilitation costs. All possible rehabilitation will be conducted concurrently with mining operations. Concurrent rehabilitation will be funded out of current earnings and will be a normal charge against profits. This year (2013), a bank guarantee of R20,000,000 was submitted to DMR and the trust fund balance is R85,336,364 (eighty five million three hundred and thirty six thousand, three hundred and sixty four Rands) has been set aside on BMM rehabilitation trust for the rehabilitation of the mine. This amount is updated on annual basis based on disturbance on the mine and is submitted to Department of Minerals Resources for approval.

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12 UNDERTAKING

I, [on behalf of Vedanta (Pty) Ltd, Black Mountain Mine] hereby declare that the above information is true, complete and correct. I undertake to implement the measures as described in Section 9 of the Environmental Management Programme. In addition to the implementation of the Environmental Management Programme, Black Mountain Mine will comply with the provisions indicated in the Minerals and Petroleum Resource Development Act, 2002 (Act 28 of 2002), National Environmental Management Act and the regulation thereto. I understand that this undertaking is legally binding and that failure to give effect hereto will render me liable for prosecution in terms of Section 98(b) and 99(1)(g) of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002). I am also aware that the Regional Manager may, at any time but after consultation with me, make such changes to this programme as he/she may deem necessary.

Signed on this day of , 20 at

Signature:

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13. Appendices: Supporting documents and reference list

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