ENVIRONMENTAL OVERVIEW AND MANAGEMENT PLAN FOR THE EXPLORATION ACTIVITIES OF BANNERMAN MINING RESOURCES (NAMIBIA) (PTY) LTD ON EXCLUSIVE PROSPECTING LICENCE 3345

AUGUST 2020

Compiled for: Bannerman Mining Resources (Namibia) (Pty) Ltd P.O. Box 2854 Swakopmund

Compiled by: A. Speiser Environmental Consultants cc / SLR Namibia (Pty) Ltd P O Box 40386 Windhoek

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TABLE OF CONTENTS

1 INTRODUCTION ...... 3 2 LOCATION OF EXCLUSIVE PROSPECTING LICENCE ...... 4 2.1 Historical exploration areas ...... 5 3 EXPLORATION AND REHABILITATION ...... 8 3.1 Day to day activities ...... 8 3.2 Rehabilitation of Moon landscape and viewpoints...... 9 4 PURPOSE OF THE ENVIRONMENTAL MANAGEMENT PLAN (EMP) ...... 10 5 LEGAL REQUIREMENTS ...... 11 5.1 Permits ...... 12 6 ENVIRONMENTAL OVERVIEW ...... 12 6.1 Climate ...... 13 6.1.1 Regional Precipitation and Evaporation ...... 13 6.1.2 Fog ...... 13 6.1.3 Ambient Air Temperature ...... 13 6.1.4 Solar Radiation ...... 14 6.1.5 Relative Humidity ...... 15 6.1.6 Regional Wind ...... 15 6.1.7 Data from Bannerman’s on-site weather station ...... 15 6.2 Landscape ...... 16 6.3 Geology ...... 16 6.4 Hydrology ...... 17 6.4.1 Surface Water ...... 17 6.4.2 Groundwater ...... 17 6.5 Biodiversity ...... 19 6.5.1 Habitats associated with EPL 3345 ...... 19 6.7 Archaeology and Cultural History ...... 23 6.7.1 Regional Setting ...... 23 6.7.2 Local Setting ...... 23 6.7.3 Bannerman’s EPL 3345 ...... 23 6.8 Namib Naukluft Park and Dorob National Park ...... 25 6.8.1 Administration ...... 25 6.8.2 Current visitor services in the northwestern part of the Namib Naukluft Park and Dorob National Park ...... 25 6.9 Socio-Economic ...... 25 7 EXPLORATION ACTIVITIES ...... 27 7.1 Non-invasive exploration activities – Phase 1 ...... 27 7.2 Invasive exploration activities – Phase 2 ...... 28 7.4 Workforce ...... 30 7.5 Water ...... 30 7.6 Environmental Monitoring and Rehabilitation ...... 30 7.7 Radiation safety Measures ...... 31 9 AFFECTED PARTIES ...... 31

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10 IDENTIFICATION OF POTENTIAL ENVIRONMENTAL IMPACTS ARISING FROM PHASE 1 AND 2 OF THE EXPLORATION ACTIVITIES AND PROPOSED MITIGATION MEASURES ...... 32 11 CONCLUSION...... 41 REFERENCES ...... 42

Appendix 1: Environmental Clearance Appendix 2: Permit – ‘Drill chip disposal at the Old Husab Mine’ Appendix 3: Details of the EPL as granted by the Ministry of Mines and Energy. Appendix 4: Rehabilitation Procedures 001 - 003

Figure 1: Regional overview of EPL 3345 and MDRL 3345 location ...... 6 Figure 2: Exploration target areas on EPL 3345 ...... 7 Figure 3: Illegal tracks at the moon landscape area along the D1991...... 10 Figure 4: Climatic data for the Erongo Region ...... 14 Figure 5: Topography of the Study Area ...... 16 Figure 6: Location of monitoring boreholes...... 18 Figure 7: Conservation Areas in Namibia, showing the Proposed Namib-Skeleton Coast National Park and its Linkages with Conservation Areas in South Africa and Angola ...... 19 Figure 8: Habitat Zones found in EPL 3345 ...... 20 Figure 9: EPL 3345 and MDRL 3345 showing the Sites found during the Survey ...... 24 Figure 10: RC and Diamond holes drilled between 2007 and 2020 ...... 29

Table 1: Details of Mineral Deposit Retention Licence holder ...... 4 Table 2: Corner coordinates for EPL 3345 ...... 5 Table 3: List of legislation relevant to uranium mining in Namibia ...... 11 Table 4: List of permits already awarded to Bannerman ...... 12 Table 5: Vegetation and Fauna Zones ...... 21 Table 6: General Aspects ...... 32 Table 7: Potential impacts arising from non-invasive exploration activities during Phase 1 .... 34 Table 8: Potential impacts arising from exploration activities during Phase 2 – drilling ...... 34

Photo 1: Examples of rehabilitation activities ...... 9 Photo 2: Area where illegal tracks have been removed with an example of the signs erected in the park to discourage further illegal off-road driving...... 10

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AUGUST 2020

ENVIRONMENTAL OVERVIEW AND MANAGEMENT PLAN FOR THE EXPLORATION ACTIVITIES OF BANNERMAN MINING RESOURCES (NAMIBIA) (PTY) LTD ON EXCLUSIVE PROSPECTING LICENCE 3345

1 INTRODUCTION Bannerman Mining Resources (Namibia) (Pty) Ltd (previously Turgi Investments (Pty) Ltd) are the holder of the nuclear fuel mineral rights to the Exclusive Prospecting Licence (EPL) 3345 and Mineral Deposit Retention Licence (MDRL) 3345 (see Figure 1). A. Speiser Environmental Consultants cc (ASEC) was commissioned in 2006 to compile an Environmental Overview (EO) and Environmental Management Plan (EMP) for the proposed prospecting / exploration activities on EPL 3345. The EO and EMP were consequently submitted to DEA and DWP and the Environmental Clearance was granted on the 28 July 2006 (Appendix 1). In September 2010 Bannerman applied to dispose the drill chips at the old Husab Mine, this was approved on 24 September 2010 (Appendix 2). In terms of the Environmental Management Act of 2007, Bannerman applied for a renewal of its 2006 Environmental Clearance for EPL3345 which was granted on the 11 February 2013. Due to the fact that Bannerman in its Exclusive Prospecting License renewal applications reduced the size of the EPL, Bannerman approached ASEC/SLR Namibia to revise the July 2006 EO and EMP, to ensure that all amendments of exploration activities to the existing Environmental Clearance Certificate had been adequately covered in the revised EO and EMP. Form 2 ‘Application for amendment of conditions of Environmental Clearance Certificate’ of the Environmental Impact Assessment Regulations: Environmental Management Act, 2007, was submitted with the revised EO and EMP in February 2013. The amended Environmental Clearance Certificate was received on the 18 March 2013. Subsequently, Bannerman built and operated a heap leach pilot facility on EPL 3345 during 2014 - 2016. The facility consists of four heap leach cribs, each being 2x2 meters in cross- section and 6 meters high. Each crib holds ~ 30t of agglomerated feed ore. The feed stock for the Pilot Plant was sourced from outcropping ore material which forms part of the future Etango Open Pit. Blasting, mining and crushing were completed within a 2 months period prior to commencing Heap Leach pilot activities. Uranium products in solution from the facility are stored in a fenced pond, from which the water can evaporate. As required solution has been transported to Rössing Uranium and discarded into their process. Should the full scale Etango Mine and Plant not go ahead the crib facility will be decommissioned and dismantled upon completion of all test-work and the area rehabilitated. Ripios (tailings) is currently stored on site but will be trucked to Rössing Uranium Mine or Langer Heinrich Mine for disposal on their tailings facility should the Etango Project not proceed. With the help of ASEC/SLR Namibia a detailed Environmental Impact Assessment and the Environmental Management Plan was conducted and an application for an Environmental Clearance Certificate lodged in July 2014. The Environmental Clearance was

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granted on the 17th September 2014. The renewal of this Environmental Clearance was granted on the 25th October 2017. Subsequent to the granting of the Environmental Clearance part of the Exclusive Prospecting Licence was zoned into a Mineral Deposit Retention Licence as shown in Figure 1. The MDRL area has the Heap Leach Pilot Facility located on it and a separate Eonvironmental Overview and Management Plan were formulated in 2018 for the MDRL. An Environmental Clearance Certificate was granted for the MDRL 3345 on the 12th July 2018. This Environmental Overview and Management Plan covers the EPL 3345 area only. Bannerman Mining Resources (Namibia) (Pty) Ltd (Bannerman) is 95% owned by Bannerman Resources Limited based in Perth, Australia listed on the Australian Stock Exchange (ASX:BMN). 5% is owned by the One Economy Foundation of Namibia a not-for-profit organisation. In April 2008, Bannerman listed on the Namibian Stock Exchange (NSX:BMN). Table 1 provides the details of the Exclusive Prospecting Licence holder as required. Appendix 3 provides details of EPL 3345 as granted by the Ministry of Mines and Energy.

Table 1: Details of Mineral Deposit Retention Licence holder Company Name Bannerman Mining Resources (Namibia) (Pty) Ltd Name of Holder Bannerman Mining Resources (Namibia) (Pty) Ltd Telephone, Fax, Email Tel.: + 264 64 416 200/ +264 61 226 621 Fax: +264 64 416 240 Email: [email protected] Postal address P.O. Box 2854, Swakopmund, Namibia Reference number of the Licence EPL 3345 Expiry date of EPL 26 April 2021 Registered names of land Namib Naukluft Park, Erongo Region, Karibib / Swakopmund District Minerals to be explored Nuclear Fuel, Base and Rare metals, Industrial Minerals and Precious Metals

2 LOCATION OF EXCLUSIVE PROSPECTING LICENCE EPL 3345 falls within the Dorob National Park (DNP) to the east- of Swakopmund. During the past 10 years Bannerman’s primary exploration target on EPL 3345 were - at Cheetah, Ombepo, R5 (adjacent to the Namib Lead Mine), Gohare and Rössingberg primarily for nuclear fuels. (see Figure 2). Following the granting of the amendment to explore for base and rare metals, industrial minerals and precious metals in December 2019 by the Ministry of Mines & Energy, exploration targets are now being identified to expand the exploration targets withing EPL 3345. The Swakop River lies immediately to the south of the EPL area. A number of smallholdings growing crops, typically olives, date palms or vegetables, are situated in the Swakop River valley, to the west of the smallholding of Goanikontes. The EPL 3345 covers an area of 6,323.34 ha. Table 2 provides the coordinates of the EPL.

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Table 2: Corner coordinates for EPL 3345 EPL Number Point No. Latitude Longitude EPL 3345 1 -22.67974493 14.82507706 2 -22.65468794 14.82878056 3 -22.61994806 14.83481698 4 -22.60695198 14.86096829 5 -22.54594503 14.92994151 6 -22.55808028 14.93768444 7 -22.58666844 14.91367756 8 -22.60659843 14.92152711 9 -22.61408404 14.90112311 10 -22.63991663 14.88346406 11 -22.65215018 14.88626786 12 -22.67941300 14.85850920 13 -22.67830891 14.85493602 14 -22.67834397 14.84859239 15 -22.67764326 14.84577939 16 -22.67771838 14.84327198 17 -22.67944634 14.83906323 18 -22.67952022 14.83544141 19 -22.68041865 14.82931121 20 -22.68015492 14.82641439

2.1 Historical exploration areas The main target area within EPL 3345 was the subject of previous exploration programmes and various studies including groundwork were undertaken to explore the area for uranium mineralisation. Trenches and grid lines were established and an extensive drilling programme, Percussion and Diamond drilling, were conducted in the mid-1970s and beginning of the 1980s. Rehabilitation of the area was only carried out rudimentary and trenches, tracks and drill sites are still visible.

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Figure 1: Regional overview of EPL 3345 and MDRL 3345 location

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Figure 2: Exploration target areas on EPL 3345

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3 EXPLORATION AND REHABILITATION Since mid-2007 Bannerman has conducted exploration activities on EPL 3345. Exploration activities only started after Bannerman received the Environmental Contract from MET (see Appendix 1). The application for the Environmental Contract included an environmental overview and a detailed environmental management plan for exploration activities. Bi-annual environmental audits are conducted, and the findings submitted to MET.

3.1 Day to day activities When Bannerman Resources started its exploration activities close to the Goanikontes Oasis in the Namib Naukluft National Park in 2006, it promised to rehabilitated areas disturbed from past exploration activities. In the 1970’s significant amount of uranium exploration was performed in the Erongo Region. 6.6 kilometres of trenches, exploration samples from 13,500m of drilling and other waste products were left behind on the exploration licenses and the cleaning up and rehabilitation of these areas was tackled and completed by the Bannerman team. Bannerman assisted with the formation of a rehabilitation company called Elga Enviro Rebab cc and contracted them to conduct all the clean-up and rehabilitation operations of the areas impacted by exploration activities. Together with Elga Environmental Rehabilitation, the Bannerman team removed 225 tonnes of waste products from these legacy exploration activities and re-established the environment as close as possible to what it must have looked like prior to any exploration activities ever having taken place there. Between one and two teams, each comprising 9 members were permanently in the field conducting clean-up and rehabilitation operations (e.g. raking, smoothing tyre tracks, distribution of pebbles to create traps for wind-blown seed) on drill sites and access tracks to drill sites (see Photo 1). Between April and December 2008, ASEC conducted fortnightly monitoring site visits to monitor the rehabilitation process and to provide guidance on how to rehabilitate different habitats. Photo 1 shows example of rehabilitation activities. Three procedures were established (Appendix 4): Procedure 0001: Disposal of RC coarse reject samples; Procedure 0002: Rehabilitation of diamond drill site sumps; Procedure 0003: Rehabilitation of tracks and drill sites.

The left photo shows the drill site just after RC drilling was completed, while the right photo shows the site after rehabilitation. The grey dust was collected in bags and disposed of at the old Husab Mine.

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Drill site access track before (left photo) and after (right photo) rehabilitation.

Clean up and rehabilitation of drill site (before and after) Photo 1: Examples of rehabilitation activities

3.2 Rehabilitation of Moon landscape and viewpoints At a workshop initiated between the Hospitality Association of Namibia and Bannerman Resources in May 2011, where the synergies between the tourism and mining industry were explored one project that was initiated at that time was the rehabilitation of the moon landscape viewpoints. The tourism sector wanted to enhance the experience of the tourist visiting the area and Bannerman Resources agreed to take on this project as it was close to its current exploration activities. After meeting with important stakeholders such as the Ministry of Environment and Tourism, the Coastal Tourist Association of Namibia and farm owners in the Swakop River near Goanikontes the project kicked off. The project took some three months to complete, employing the rehabilitation skills of the Bannerman Resources staff and the contractor Elga Environmental Rehabilitation as well as making up numerous signs to discourage future illegal off-road driving and directing tourists to rest areas at the Goanikontes Oasis. Over N$ 200,000 were invested in this exciting environmental activity and has received praise from various sectors of the community. Figure 3 indicates the illegal tracks rehabilitated around the moon landscape viewpoints. Over 30 km’s of tracks were rehabilitated. Photo 2 shows an area where illegal tracks have been removed and the new signs which have been erected.

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Figure 3: Illegal tracks at the moon landscape area along the D1991.

Photo 2: Area where illegal tracks have been removed with an example of the signs erected in the park to discourage further illegal off-road driving.

4 PURPOSE OF THE ENVIRONMENTAL MANAGEMENT PLAN (EMP)

The purpose of the EMP is: - ▪ To summarise the project activities that have the potential for adverse environmental impacts. ▪ To identify and outline the aspects of the environment which require management. ▪ To compile Project Environmental Specifications for inclusion in contract documents and enforcement on site. ▪ To set out the roles and responsibilities of all role-players with regard to environmental management. ▪ To specify rehabilitation requirements. ▪ To establish monitoring requirements to ensure that all staff members on site comply with the Environmental Specifications. One of the senior geological team members on site is

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designated by the Environmental Consultant to perform this function on a day-to-day basis.

5 LEGAL REQUIREMENTS Bannerman complies with all Namibian legislation, and where legislation is lacking will comply with the World Nuclear Association (WNA) principles outlined in their document entitled Sustaining Global Best-Practices in Uranium Mining and Processing. Table 3 provides a list of relevant legislation.

Table 3: List of legislation relevant to uranium mining in Namibia Year Name Current Namibian legislation 1990 Petroleum Products and Energy Act, No. 13 of 1990, as amended 1990 The Constitution of the Republic of Namibia, No. [ ] of 1990 1992 The Labour Act, No. 6 of 1992 1992 The Minerals (Prospecting and Mining) Act, No. 33 of 1992 1997 Regulations relating to the Health and Safety of Employees at Work (promulgated in terms of Section 101 of the Labour Act, No. 6 of 1992 (GN156, GG 1617 of 1 August 1997) 1998 Affirmative Action (Employment) Act, No. 29 of 1998 1998 The Health Act, No. 21 of 1998 2000 Petroleum Products regulations 2001 The Forestry Act, No. 12 of 2001 2004 Water Resources Management Act, No. [ ] of 2004 2004 National Heritage Act, No. 27 of 2004 2007 Labour Act, No. 11 of 2007 2005 Atomic Energy and Radiation Protection Act, No. 5 of 2005 2007 Environmental Management Act, No. 7 of 2007 2012 Commencement of the Environmental Management Act, List of Activities that may not be undertaken without Environmental Clearance Certificate and Environmental Impact Assessment Regulations: Environmental Management Act Former South African and SWA legislation still applicable in Namibia 1956 Water Act, No. 54 of 1956 1968 Regulations made under the provisions of the Mines, Works and Minerals ordinance, 1968 (Ordinance 20 of 1968) 1969 Soil Conservation Act, No. 76 of 1969 1975 Nature Conservation Ordinance No. 14 of 1975 1976 Atmospheric Pollution Prevention Ordinance No. 11 of 1976 Namibian policy 1994 Policy for the Conservation of Biotic Diversity and Habitat Protection

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Year Name 1995 Namibia's Environmental Assessment Policy for Sustainable Development and Environmental Conservation 1998 Draft White Paper on the Energy Policy of Namibia 1999 Policy for Prospecting and Mining in Protected Areas and National Monuments 2000 National Water Policy White Paper 2002 Minerals Policy for Namibia Other/best practice 1997 Namib Naukluft Park Regulations (original 1976 amended 1997) (No. 3556) World Nuclear Association (WNA) principles, outlined in their document entitled Sustaining Global Best-Practices in Uranium Mining and Processing Chamber of Mines of Namibia (CoM) – USC constitution 2010 Uranium Rush – Strategic Environmental Assessment – SAIEA, October 2010

5.1 Permits Before exploration did commence, Bannerman obtained the required permits and certificates. Table 4 lists the permits and certificates that Bannerman have acquired. The originals of these documents are kept at the Swakopmund town office. Table 4: List of permits already awarded to Bannerman Permit name Regulator Permit number Date of granting EPL 3345 MME 3345 26 April 2017 MDRL 3345 MME 3345 07 August 2017 Environmental Clearance for EPL 3345 MET n/a 28 July 2006 Permit to disposal drill chips at the Old MET n/a 24 September 2010 Husab Mine Environmental Clearance for EPL 3345 & MET n/a 11 February 2013 3346 Amendment to the Environmental MET n/a 18 March 2013 Clearance for EPL 3345 Environmental Clearance for EPL 3345 & MET n/a 19 September 2014 Proposed Pilot Plant Environmental Clearance for EPL 3345 & MET n/a 25 October 2017 Pilot Plant Environmantal Clearance for MDRL 3345 MET n/a 12 July 2018 Entry Permit to Game Park/Reserve NNNP MET n/a 3-monthly renewal

6 ENVIRONMENTAL OVERVIEW The information which was provided in the July 2006 EO & EMP report were updated using the specialist reports and findings of the ‘Etango Project Environmental and Social Impact Assessment’ (ASEC / ERM, April 2012).

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6.1 Climate 6.1.1 Regional Precipitation and Evaporation EPL 3345 falls within the west coast arid zone of Southern Africa. Historical meteorological data for the region is limited, with the Gobabeb Research Station (located ~65 km to the south of the MDRL area on the border with the Namib Desert) being the closest applicable meteorological station to the project site. According to the Digital Atlas of Namibia (Directorate of Environmental Affairs, MET), rainfall in the Erongo Region ranges between 0-50 mm at the coast to 400 mm in the northeast of the region. EPL 3345 falls within the 0-50 mm/year rainfall belt, as shown in Figure 4a. The variation in rainfall is also the highest at the coast (>100%) with rainfall variability decreasing rapidly towards the eastern part of the Erongo Region (http://209.88.21.36/Atlas/Atlas_web.htm). Annual average rainfall measured at Gobabeb over the period 1962-1967 is 23 mm. Historical records for Swakopmund dating as far back as 1899 indicate an annual average of 14 mm. More recent statistics for Swakopmund indicate the total annual rainfall for 2008 to be 30 mm (http://weather.namsearch.com). Rainfall in these semi-arid areas does, however, vary considerably, and high intensity rainfall events can occur. The highest daily total rainfall measured at Gobabeb is 16.5 mm, and 22 mm at Goanikontes, with Swakopmund receiving 153 mm in one day in 1934 (Goudie, 1972). Evaporation rates are between 2,400-3,400 mm per year, increasing from the coast inland. The EPL 3345 falls between the 3,000-3,200 mm per year evaporation contours (http://209.88.21.36/Atlas/Atlas_web.htm) (Figure 4b).

Potential / actual impacts • Flash floods

6.1.2 Fog Fog is a form of precipitation. Within the region, fog can extend up to 110 km inland. The average number of fog days per annum recorded at Gobabeb between 1964 and 1967 was 102 (Goudie, 1972). Swakopmund also has high incidences of fog, with more than 125 fog days per year (http://209.88.21.36/Atlas/Atlas_web.htm). The annual fog precipitation at Swakopmund was estimated to be 35-45 mm (Goudie, 1972). Figure 4c shows the regional fog index for the Erongo Region.

6.1.3 Ambient Air Temperature Historical data for the region indicates similar average monthly and annual temperatures along the Namib coast. The range between the coldest and warmest months is also small, being 9°C at both Swakopmund and Walvis Bay. Gobabeb indicates an annual temperature difference of 6.5°C, with daily periodic ranges of 16-18.5°C. Frost is not associated with the region but extreme temperatures of over 40°C have been associated with strong easterly ‘berg’ winds (Goudie, 1972). The annual average temperature map for the Erongo Region is provided in Figure 4d, with the Etango Project falling within the 19-20°C average temperature range (http://209.88.21.36/Atlas/Atlas_web.htm).

Potential / actual impacts • Dehydration of workforce • Sunburn risk • Exposure in extreme cold events

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The number of sunshine hours in the Erongo Region also increases rapidly from the coast towards the east, ranging from <5 hours per day at Swakopmund to >10 hours per day just a few kilometres inland (Figure 4e).

Figure 4: Climatic data for the Erongo Region

6.1.4 Solar Radiation Within the Erongo Region, solar radiation is on average <5.4 kWhr per m² per day at the coast and up to 5.8 kWhr per m² per day further east. The EPL 3345 falls within the 5.6-5.8 kWhr per m² per day category (Figure 4f).

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6.1.5 Relative Humidity Relative humidity for the Erongo Region varies between <10% during the least humid month to 70% for the most humid month. The relative humidity for the Erongo Region is highest along the coast and lowest inland (http://209.88.21.36/Atlas/Atlas_web.htm). Figure 4g and Figure 4h show the relative humidity for the least and most humid months, respectively. The average humidity recorded at Swakopmund in 2008 ranged between 22% and 96% (http://weather.namsearch.com).

6.1.6 Regional Wind The wind field for the region represents a combination of the synoptic-scale circulation and the local land-sea breeze circulation. The wind field varies significantly within the Erongo Region. Historical records for Gobabeb indicate a higher frequency of east and south winds during winter months, with mean wind velocities of up to 6 m/s. Winds of up to 14 m/s have also been associated with these winds. During the summer months, winds from the northwest are more prevalent and are associated with lower velocities (Goudie, 1972). The wind direction in the central northern part of the region between Karibib and the Rössing Uranium Mine indicates predominant north-easterly and south-westerly winds. The north- easterly winds are associated with higher wind velocities. The wind field changes slightly in the Etango Project and Husab areas, where northerly and north-westerly winds are more prevalent, but strong south-easterly winds still persist. The wind field at Gobabeb is frequently from the northwest and southwest. Wind data recorded at the Langer Heinrich Uranium Mine shows a strong east-west airflow, which is clearly influenced by the topography. Wind speeds recorded in the region vary, but most of the stations record wind speeds of between 0-10 m/s. Wind speeds between 13 m/s and 17 m/s have been recorded for short periods, with the highest wind speed of 22.5 m/s in 2008 recorded at Pelican Point (outside Walvis Bay). Inland, a maximum wind speed of 16.5 m/s was recorded at the Valencia Uranium Mine in 2008.

6.1.7 Data from Bannerman’s on-site weather station Bannerman operates a dust fallout network comprising of nine single dust fallout buckets. Data is available for dust fallout from March 2009 onwards, and for PM10 which was previously part of the on-site weather station for the period 25 February to 25 July 2011. The weather station was relocated to the Pilot Plant, which is on MDRL 3345 in 2014 just prior to the commissioning of the Heap Leach Demonstration Plant.

6.1.7.1 Existing Sources of Atmospheric Emissions in the Project Area A comprehensive particulate emissions inventory was compiled for the region in 2009 and 2010, as part of the Strategic Environmental Assessment (SEA) (Liebenberg-Enslin et al., 2010). The SEA considered likely sector-development scenarios and their implications (economical, social and environmental) for the region. Sources identified as possibly impacting on air quality in the region included, but are not limited to: • fugitive emissions from mining operations; • fugitive emissions from vehicles on mine and national unpaved roads; and • wind erosion of open areas.

As the SEA study focused on the potential dust impacts, it only covered particulates and not gaseous emissions from any combustion sources or vehicle tailpipe emissions.

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Potential / actual impacts • Wind erosion of disturbed soil surface and gravel roads • High wind speed will affect poorly managed waste disposal system

6.2 Landscape The exploration target area lies within the broad gravel peneplains (open outwash plains) with a low relief. These flat surfaces are traversed by poorly defined drainage lines (washes) and stormwater gullies, occasionally interrupted by elevated dykes and other intrusions, mostly of a low altitude. Towards the Swakop River, the terrain becomes hilly and rugged and the drainage lines join to form gorges as the land surface erodes. The topography of the study area is presented in Figure 5.

Figure 5: Topography of the Study Area

Potential / actual impacts • Visibility of infrastructure • Disturbance of soil cover leads to increased dust through wind erosion

6.3 Geology

The EPL area is underlain by the Abbabis metamorphic complex and the Swakop and Nosib Groups (Damara Sequence), which are made up of rocks of the Etusis, Khan, Rössing, Chuos, Karibib, Arandis and Kuiseb formations. These rocks were exposed to extensive folding, faulting and erosion before the deposition of sedimentary deposits of the Namib Group, followed by another period of erosion. Predominately mixtite and pebbly quartzite of the Chuos Formation overlying amphibolite of the Khan Formation occur, which was intruded by Ordovician uranium-bearing alaskite. The rocks are partly covered by Tertiary and Quaternary Namib Group deposits. The paleochannels intersected in the southern part of the project area comprise calcretised alluvial sediments of Miocene age.

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6.4 Hydrology 6.4.1 Surface Water The major hydrological feature of the project site is the Swakop River, which is one of the four major ephemeral river systems of the Central Namib, draining westwards into the Atlantic Ocean. The significant decrease in rainfall from east to west, combined with the erratic nature of runoff, and the increase in evaporation potential (from east to west) results in the highly episodic flow of all rivers in the Central Namib Desert. These rivers generally contain discharge for a brief period of time, following exceptionally heavy rainfall events in the catchment (BIWAC, 2010a from Ashton, 1991).

Potential / actual impacts Flash floods

6.4.2 Groundwater The project area is located within the Etango compartment of the Swakop River catchment, including the Swakop River channel between the Khan River confluence and Goanikontes. The groundwater of the downstream compartment is used by farmers for irrigation of small- scale vegetable and olive plantations. Locally, large variations in groundwater quality, both vertically and laterally, are observed within the alluvial aquifer of the Etango and downstream farming compartments. Localised salinity is the result of evaporation and evapo-transpiration in places where the water level is very shallow. Groundwater quality is generally better towards the active river channel and in the upper aquifer layers, as fresher water lenses occur on top of the brackish/saline groundwater layer. Small volumes of lateral inflow occur from the fractured basement aquifer at the base of the river channel. High salinity and most probably also high levels of uranium and other elements (e.g. strontium) are associated with these lateral inflows. Over-abstraction of groundwater has led to a water-level decline and increasing salinity. Water quality improves periodically during flood events (BIWAC, 2010a from CSIR, 1997). Water-quality information from 40 borehole locations in the Swakop River was obtained from the DWA groundwater database (GROWAS). As from 2007, Bannerman has also drilled a large number of exploration boreholes mostly on the southern side of the Swakop River where the Etango Uranium Project would be located. Most of these however are inclined and not sleeved, and sampling is therefore difficult or impossible. A total of 21 GAHD boreholes were drilled by Bannerman, while six WW boreholes (originally drilled by RUL) were taken over by Bannerman in 2010. Of the 21 GAHD boreholes, 15 are situated in basement rocks and four in paleochannels, while two of the GAHD and all of the six WW boreholes are located in the alluvium of the Swakop River (see Figure 6). Groundwater monitoring of water levels is undertaken monthly by Bannerman staff. Groundwater-quality monitoring was undertaken quarterly by BIWAC (now SLR Environmental Consulting Namibia) until July 2012 to establish a baseline. This groundwater-quality monitoring is now undertaken annually. Water samples are taken and analysed for the main ions and metals on an annual basis. Groundwater monitoring reports are provided to Bannerman by SLR. Detailed information can be obtained from the Bannerman office in Swakopmund or Chapter 6 of the ‘Etango Project Environmental and Social Impact Assessment” (Volume 1) (ASEC / ERM, April 2011).

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Figure 6: Location of monitoring boreholes.

Potential / actual impacts • None during exploration

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6.5 Biodiversity The EPL 3345 lies within the Dorob National Park (DNP). The DNP is part of the larger National Park, which extends from the Orange River in the south to the Kunene River in the north of the country. Additionally, the conservation status extends into South Africa (Richtersveld National Park) and Angola (Iona National Park), making this a trans-frontier conservation area (Figure 7). Bannerman’s EPL 3345 is situated in the Central Namib Desert. This broad zone has the ephemeral Ugab and Kuiseb Rivers as its northern and southern borders, respectively, and is bounded by the Atlantic Ocean in the west and the escarpment in the east. According to Rutherford & Westfall (1986), it forms part of the Desert Biome of Southern Africa. This is based primarily on vegetation. Irish (1994), who established biomes based on invertebrates, also places the Central Namib within the Desert Biome.

Note: the red triangle represents the approximate location of MDRL 3345. Figure 7: Conservation Areas in Namibia, showing the Proposed Namib-Skeleton Coast National Park and its Linkages with Conservation Areas in South Africa and Angola

6.5.1 Habitats associated with EPL 3345 EPL 3345 may be broadly divided into four zones (Figure 8). Overall, the EPL consists largely of sandy gravel plains dissected by ephemeral watercourses and washes that generally trend south-west. In the vicinity of the Swakop river, the plains (Zone A) tend to change gradually into gravelly undulating hills dissected by narrow sandy washes (Zone B), finally becoming a broad band of high mountainous ridges forming the Swakop River canyon,

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dissected by sandy washes of varying size and accessibility (Zone C) that demarcate the route of the Swakop River (Zone D). Zones B and C drain towards the Swakop River.

Figure 8: Habitat Zones found in EPL 3345

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The value of describing habitats is that they are clearly distinct components of the environment. Many plants and animals are habitat-restricted, thus identifying and conserving habitats helps one not only to protect the biota they support, but also to extrapolate, as similar habitats in surrounding areas are likely to support similar biodiversity.

Table 5 summarises the character of these zones, species of conservation concern and vegetation sensitivity, as well as any suggested mitigation measures. They are discussed in detail later. Table 5: Vegetation and Fauna Zones Species of Fauna description Conservation Suggested Concern (red = Zone Description Subdivision Mitigation high) and Measures Vegetation Sensitivity Borrowing animals (soil slightly compacted but None, sensitivity easily penetrated) such General, strict track 1 Plain low as ground-living control insects, scorpions & lizards. Shallow washes are functional miniature linear oases. Plain- dwelling animals, shelter, food & moisture in & around Zygophyllum the plants, ie stapfii, Arthraerua Drainage springbok, ostrich, Avoid large washes, leubnitziae, Sandy- 2 lines and seed-eating birds such maintain drainage Adenolobus A gravel washes as sandgrouse, where possible pechuelii, plains invertebrates sensitivity low concentrate where is shade, shelter from wind, and food. Scorpions, lizards & other predators feed on herbivores. Crevice-seeking lizards Avoid large marble Aloe asperifolia, and scorpions ridges in the Hoodia pedicellata Ombuga deposit if Rocky (mostly restricted possible. Plant 3 outcrops to large marble rescue and ridges), sensitivity relocation of Aloe medium and Hoodia, possibly others Aloe asperifolia, Crevice-seeking lizards Zygophyllum and scorpions stapfii, Arthraerua Gravelly- leubnitziae, Rescue and B gneiss Petalidium relocation of Aloe hillocks variabile, Adenolobus pechuelii, sensitivity low Commiphora Cervice-seeking oblanceolata, lizards, scorpions, Rescue and Mountain- Zygophyllum small mammals. Large relocation of C ous ridges stapfii, Arthraerua animals are dependent Commiphora (canyon) leubnitziae, on security & shelter Petalidium afforded by rock oblanceolata canescens, P. overhangs & shallow variabile, caves. Klipspringer,

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Species of Fauna description Conservation Suggested Concern (red = Zone Description Subdivision Mitigation high) and Measures Vegetation Sensitivity sensitivity medium rock dassie, rock rabbit & rock rat live here on a permanent basis, feeding on plants that grow on the slopes and also venturing into valleys where more vegetation is concentrated. Mountain zebra, kudu and gemsbok utilise rocky areas and valleys as well as adjacent plains. Given this food source, mammal predators such as spotted hyena and leopard are likely but probably rare or vagrant, and raptors (e.g. Black Eagle, Augur Buzzard) fill this role from the air. Acacia erioloba, Food resource to larger Euclea species of wildlife such pseudebenus, as gemsbok and Do not obstruct Swakop 1 Faidherbia albida, steenbok which feed access to the river River Petalidium on the leaves and or valleys canescens, pods. sensitivity low Trees provide permanent source of food & shelter, animals can enter the desert and survive in what would otherwise be an inhospitable terrain (Jacobson et al., Swakop 1995). Steenbok, kudu, River and porcupine, leguaan & D large platanna frog examples A. erioloba, of such animals. Large valleys that Euphorbia virosa, drain into it mammals such as Other large Zygophyllum kudu & gemsbok use valleys and stapfii, A. 2 riverbed during driest drainage leubnitziae, Codon part of the year lines royenii, Petalidium (October –January), variabile, when there is fodder sensitivity low from trees & pods & water sources at springs & gorras which gemsbok dig into the riverbed. No fixed ‘migration routes’. Trees in the river valleys also provide food & shelter for birds & smaller invertebrates & reptiles.

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Potential / actual impacts • Plant growth (lichens) will be affected by dust from the exploration activities • Uncontrolled off-road driving • Illegal plant and animal collecting • Disturbance of ground nesting birds

6.7 Archaeology and Cultural History 6.7.1 Regional Setting The Namib Desert has an archaeological sequence of almost one million years, which represents a globally important record of human responses to aridity and climatic fluctuation. The Central Namib Desert is particularly rich in archaeological remains, with well-preserved evidence of human adaptation to the highly arid conditions which prevailed in this area in the late Pleistocene and Holocene periods. Several thousand archaeological sites are known and there is a large literature based on their investigation.

6.7.2 Local Setting In the archaeological past, the Goanikontes area would not have permitted more than short- term occupation by small groups of semi-nomadic people. Previous surveys, conducted by QRS in the Namib, lead one to expect archaeological evidence of recent Holocene occupation (mainly dating to within the last 5,000 years), concentrated along drainage lines, as well as near inselbergs and minor outcrops on the gravel plains. The same areas might also have yielded evidence of late Pleistocene human occupation (especially dating to within the last 150,000 years), which is often associated with shallow endoreic basins on the gravel plains. Large expanse of the Central Namib lying to the south of MDRL 3345 is archaeologically unexplored. The east to west decrease in the density of archaeological sites in the Namib also reflects environmental limits to human existence. The availability of water would obviously have been the major constraint on human settlement in this part of the Namib. Water in the form of weak seepages and subsurface accumulations would have been almost entirely restricted to the bed of the Swakop River. Yet, Figure 9 shows that most of the archaeological sites are situated at considerable distances from the river. This apparent contradiction is a characteristic feature of archaeological site distribution in the Namib, and points to the opportunistic use of ephemeral rainwater ponds in the desert. However, the absence of archaeological sites in the Swakop River valley itself does not necessarily indicate that it was unimportant to human communities; on the contrary, its readily available water, timber and forage was an attraction even to early colonial settlers who established themselves along the river valley, which also served as a convenient route to the interior. The fact that evidence of earlier settlement seldom survives in such situations is mainly due to the effect of torrential flooding from higher rainfall along the interior escarpment.

6.7.3 Bannerman’s EPL 3345 The archaeological survey carried out for the whole of EPL 3345 and MDRL 3345 located a total of 34 sites, representing sporadic human occupation during the late Pleistocene, and at various times during the Holocene and recent historic period. Archaeological sites on these areas are strongly associated with areas of localised rock outcrop, primarily granite corestones on the gravel plains, and dolerite ridges in the area north of the Swakop River. This emphasis is a characteristic feature of the distribution pattern of archaeological sites elsewhere in the Namib. Although the association with gravel plains is slightly weaker on EPL 3345 than in the surrounding area, such open-site locations do feature, along with rubble slopes and drainage lines. The higher-than-normal emphasis on drainage lines on EPL 3345 reflects the importance of the Swakop River valley, especially in the colonial era. Three groups of archaeological sites were found on the EPL and MDRL area. Group A falls within the EPL 3345, while Group B and C are within the MDRL 3345.

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Figure 9: EPL 3345 and MDRL 3345 showing the Sites found during the Survey

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6.7.3.1 Group A Sites The majority of the Group A sites relate to short-term occupation of the area by small hunter- gatherer groups exploiting wild grass seed which they dug from the underground caches of harvester ants (Messor spp.). This particular subsistence strategy is represented by localised diggings, 1-2 m in diameter, with local densities related to rainfall patterns. The diggings centre around base-camp sites situated within approximately 2 km of water.

Potential / actual impacts • disturbance of archaeological sites

6.8 Namib Naukluft Park and Dorob National Park The EPL area falls within the Dorob National Park and a brief description and its economic importance is given below. The Dorob National Park is a protected area in Erongo Region, along the central Namibian coast, which is 1,600 kilometres in length. It was gazetted as a national park under the Nature Conservation Ordinance No.4 of 1975 on 1 December 2010, and with Namib-Naukluft Park covers an area of 107,540 square kilometres. The park extends from the Kuiseb Delta (south of Walvis Bay), north to the Ugab River, and west from the Atlantic Ocean to what was before the National West Coast Tourist Recreation Area.

6.8.1 Administration Both, the Namib Naukluft Park and Dorob National Park are administered by the Ministry of Environment. All facilities, e.g. camp site, roads, etc. are maintained by this ministry. Visitors and non-MET residents of the Gobabeb Centre (located at the Kuiseb River) require permits that outline their activities within the Namib Naukluft Park. No entry permit is yet required to access the Dorob National Park.

6.8.2 Current visitor services in the northwestern part of the Namib Naukluft Park and Dorob National Park As mentioned all visitors need a permit from MET before entering the Namib Naukluft park. The permit allows visitors to stop and overnight at lookouts and campsites. The D1991 passes through the EPL area. The main tourism target area is located North and South the D1991, which is a popular tourist route through the Namib Naukluft Park. The D1991 passes through the EPL area and is primarily used by tourists to get to the Goanikontes Oasis or moon landscape viewpoints that are situated on the southern side of the Swakop River within the MDRL area. Exploration activities within the EPL area may be visible from the D1991.

Potential / actual impacts • Visual impact which disturbs the wilderness impression

6.9 Socio-Economic The Erongo Region is active in the trade, tourism, fishing, mining and agriculture sectors and makes a significant contribution to the overall economy. It has a Human Poverty Index (HPI) of 17.1, which makes it the best-off region in the country; the national average is 24.7 and the worst region (Zambezi) scored 36 (NPC, Erongo Regional Poverty Profile, 2007). The Erongo Region development plan (2000-2006) includes the following four objectives: • diversify economic activity through value-adding to fisheries, mining and agricultural outputs;

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• support self-employment in the secondary and tertiary sectors; • maintain and improve the physical infrastructure of the region, especially in and to the outlying areas; and • develop, initiate and implement empowerment programmes for women and marginalised groups.

The region is situated at the end of the Trans-Kalahari Highway that interlinks with Botswana and Gauteng Province in South Africa. The Trans-Caprivi Highway connects the region to the country’s northern business centres and extends to Zambia, Zimbabwe and the Democratic Republic of Congo. Both these roads connect with the port at Walvis Bay, which is the main focus and economic nucleus for these two highways. The Walvis Bay Corridor Group as an organisation and a public-private partnership promotes the harbour in playing a crucial economic link to any economic centre in Southern Africa, with various advantages over other harbours. Walvis Bay and Swakopmund are also linked to Windhoek on the national railway system by the TransNamib railway. Telecommunications has improved tremendously over the last few years, particularly in the rural areas, as coverage by mobile phones has expanded to 95% of the population. Walvis Bay has an airport suitable for regional passenger airlines, while Swakopmund airport is used considerably by tourists in smaller planes. Furthermore, the region has numerous other air strips suitable for small aeroplanes. The central coastal area from Walvis Bay to Henties Bay is a major holiday destination and centre for relaxation, with many accommodation establishments and camping sites. In the centre of this stretch is Swakopmund which can be regarded as the main centre for tourism. Swakopmund is the second most visited town with 50% and Walvis Bay with 32% of all tourists visiting these towns (NTB, MET, 2006). The seasonality of the tourism sector is partly evened out as tourists from international destinations such as Europe and the rest of Africa have different holiday times to the local (inland) tourists. Accommodation capacity in the coastal towns is 20% of Namibia’s complete capacity (Hospitality Association of Namibia). The Erongo Region had over 247 000 beds available in August 2008 from a Namibian total of over 806 000 (NTB, 2009). There is constant growth and development in the coastal regions to accommodate the increase in this demand. In 2008, the beds available in the Erongo Region increased by 12% in eight months. Total establishments in the Erongo Region selling bed nights increased from 316 establishments in January 2006 to 510 establishments in August 2008, indicating a growth rate of nearly 2% per month. There are 483 businesses registered in Swakopmund, with 91% of these businesses being one-man enterprises, employing no more than 3 people. There are also large scale retailers, banking services and an increasing number of manufacturing services which provide goods and services to the growing mining sector (Nacoma, 2010). The fishing industry is susceptible to huge variations in catches due to varying annual fishing quota allocations, while the mining sector is susceptible to huge variations in commodity prices. Tourism is a growing sector and contributor to Erongo’s portion of Gross Domestic Product (GDP) but has been affected by the global recession. It depends on the seasonality of tourist arrivals and the fluctuations of the currency. Nevertheless, Erongo’s economy is booming and several new developments at the coast are planned including: • New Indoor Sports center and public swimming pool • New passenger terminal for Walvis airport. • Expanded hotel and luxury flats near the Mole seafront. • Bahnhof Square and Lifestyle Centre, including a theatre, a private sector. development in partnership with TransNamib. • Carenet retirement village of 188 houses at Mile 4. Namibia may face a shortfall of power, particularly if new mines come into operation. In Walvis Bay, the old thermal diesel power station of 24 Megawatts that was built in 1976 to

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cater for peak demands and power outages at Rössing mine will be upgraded to 50 MW capacity. NamPower has got Environmental Clearance to increase the capacity by building a coal power plant at Arandis. This has however been shelved at present. The development of the Kudu Gas Power Station development near Oranjemund is also not progressing at this stage. A fourth turbine with a capacity of 92MW was commissioned in 2012 at Ruacana’s hydro- electric power station on the Kunene River. The first wind generated electricity near Lüderitz as well as solar power in the southern parts of Namibia have been commissioned. Sufficient fresh water supply for the coastal regions remains a challenge. Current abstraction from the Omdel and Kuiseb aquifers is approximately 9.8 Mm3/a of water for domestic and non-mining purposes. Areva has constructed a desalination plant for the Trekkopje mine north of Swakopmund. Water from this desalination plant is entering the current water reticulation infrastructure and mining operations use desalinated water. Increasing the capacity of this desalination plant to supply more water is an option that Bannerman and other mines would consider. Walvis Bay town council installed a containerised desalination plant in 2009 to augment its fresh water supply to residents. Additional units to enlarge this desalination unit could result in the system supplying half the town’s water- consumption needs and would assist the town greatly in times of periodic flooding of the Kuiseb River, when current water supply installations suffer damage. Regarding public services, by 2004 the Erongo Region was not receiving sufficient government contributions and expenditure for public health and educational services. The population per nurse and population per doctor is about 60% higher than the average for Namibia. Education expenditure per primary school learner in the Erongo Region for 2003/2005 was N$2 365 per learner, compared to Namibia’s average of N$2 905 per learner. This will lead to further aggravating effects in the coming years, with a drastic increase in mining activity and an influx of job-seekers. The Erongo Region and especially the coastal towns will have to request an increase in public medical and educational services. Usually, the mining sector assists with its own funds for its own needs in the health sector, but general educational investments are depending on government.

Potential / actual impacts • Potential job creation • Economic benefits to the Region. The exploration activities will bring financial investment to Namibia and the Region.

7 EXPLORATION ACTIVITIES As usual in exploration a phased approached of the exploration activities is proposed. Depending on the results of each phase the exploration programme might continue or be terminated. At the beginning of the exploration a non-invasive phase (Phase 1), this is followed by an invasive exploration phase (Phase 2). The respective activities of each phase are described below.

7.1 Non-invasive exploration activities – Phase 1 To obtain a better understanding of the area of interest Bannerman (than Turgi Investments (Pty) Ltd.) commenced with non-invasive groundwork. A letter was submitted to the Department of Environmental Affairs (DEA) and the Directorate of Parks and Wildlife (DPW) on 11 June 2006 applying to start with the below described work prior to the obtaining of the Environmental Clearance. The following non-invasive groundwork was proposed and carried out: • Mapping All mapping was carried out on foot and no new tracks or previously rehabilitated tracks were re-opened. Hand-sized samples were taken for further analytical studies.

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• Gamma ray spectrometry Drilling completed in the 1970s and 1980s totaled approximately 250 boreholes. A number of these holes are still open and valuable information was gained without ground disturbance by re-entering these open holes with a gamma ray spectrometer. Only the old main access track to the old drill area was used and the old boreholes were accessed on foot. The holes were cleared of radon gas and then a small probe was lowered into the hole and the gamma rays read to a computer. No samples were taken and no ground outside vehicle access was disturbed.

7.2 Invasive exploration activities – Phase 2 Phase 2 consisted of various drilling methods and was only start once the results of phase 1 had been analysed. The locations for boreholes of the drilling were determined using the result of Phase 1 and existing geological reports. Drilling started using Reversed Circulation (RC) drilling and followed with a diamond drilling programme. Figure 10 shows the borehole location and the type of drilling method. Also the bi-annually Environmental Audits Reports (2007 to 2012) show the exploration activities for the audited period. Access to the drill sites was as much as possible established using previously non rehabilitated tracks and only where necessary new tracks were established. On exploration areas where the drilling was completed and no further exploration activities were planned, all newly established tracks were rehabilitated by raking the tracks (Appendix 4). Environmental awareness training was provided to all staff and drilling crews.

• Reversed Circulation (RC) Drilling Drilling rigs, compressor and generators are mounted on trucks suitable for most terrains and fitted with the appropriate tyres for the area. Drill pads are kept to a minimum size. Fuel to power the drill rigs is brought to the site in drums or in a small truck. Water is trucked in from the Rössing Mine pipeline. The RC drilling methods produces rock chips which are funneled through a primary and secondary cyclone into 1m x 1m plastic woven bags. Smaller geological samples are taken from these bags for analysis. Since September 2010 drill chips are disposed at the old Husab Fluorite Mine. The disposal method was discussed with DPW and MET and on 24 September 2010 the procedure was approved. Prior to the disposal at the old Husab Mine, drill chips were disposed of at the Swakopmund waste site. All boreholes are capped to avoid small animals falling into them. At the end of the exploration programme all borehole collars are cut and sealed off permanently. During the drilling operations, the drill crew ensured that their vehicles and rigs do not spill hydraulic oils or fuel. The area where fuel, oils etc. are decanted was (and is) lined with a tarpaulin in order to contain any possible spillage. Drilling crews for RC rigs usually consists of 5-6 people. The drill crews are accommodated at Farm Weizenberg located in the Swakop River along the D1991 and in Swakopmund. • Diamond Drilling Drilling rigs, compressor and generators are mounted on trucks suitable for most terrains and fitted with the appropriate tyres for the area. Drill pads are kept to a minimum site. Where necessary, sumps are dug into the ground to hold the water and biodegradable drilling aids may be added. Fuel to power the drill rigs are brought to the site in drums or in a small truck. Water is trucked in from the Rössing Mine pipeline. In contrast to the RC drilling, this drilling method needs a significant amount of water, and a water truck will provide water on a rotating basis. Continuous solid cores are recovered during diamond drilling. The cores were initially stored in Swakopmund, since 2009 a core store was built on Farm Goanikontes where all cores and RC samples are stored. After the expiry date of the MDRL licence and/or a decision not to proceed with the project the cores have to be submitted to the Geological Survey of Namibia by law.

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During the diamond drilling operation, the drill crew ensures that their vehicles and rigs do not spill hydraulic oils or fuel. Decanting of fuel, oils etc. are carried out in designated areas specifically designed for the management of fuels and lubricants and the work area is covered by tarpaulin as a minimum. Drilling crews for diamond rigs usually consists of 5-6 people.

Figure 10: RC and Diamond holes drilled between 2007 and 2020

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7.3 Infrastructure Equipment of vehicles Phase 1 Phase 2 Vehicles 1 to 2 4x4 vehicle 1 to 2 4x4 vehicle Drilling equipment 1 RC drill rig; 1 equipment truck; 1 water truck; 1 diamond rig; 1 equipment truck; 1 water truck.

7.4 Workforce In the table below the number of permanent Bannerman employees and contractors employed over the years in the exploration activities are depicted. Year Staff Contractors 2007 24 32 2008 27 40 2009 32 40 2010 31 23 2011 28 15 2012 24 11 2013 6 0 2014 13 8 2015 10 8 2016 8 8 2017 6 10 2018 5 2 2019 4 1 2020 4 4

7.5 Water The method of RC drilling does not need an excessive amount of water. Water for diamond drilling was and is obtained from the Rössing Mine pipeline. No water is used from the Swakop River aquifer or from any other groundwater sources in the area.

7.6 Environmental Monitoring and Rehabilitation As stipulated in the Pro-forma Environmental Contract drawn up by the Ministry of Environment and Tourism, Bannerman submitted every six months an Environmental Report to the Ministry stating the current environmental performance of the exploration team members (mapping geologists and drilling crew). Internal and external monitoring involved and involves members of the MET and the Environmental Consultants. Nearly all RC and diamond boreholes have been rehabilitated (see Figure 10). The next external bi-annual monitoring will be conducted in January 2021.

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Rehabilitation is carried out according to the procedures 001 to 003 (see Appendix 4).

7.7 Radiation safety Measures All people on site have been inducted regarding radiation safety measures. Bannerman purchased 8 personal dosimeters as well as radiation in air and radon area monitoring equipment to take radiation measures at the drill rigs, rehabilitation areas and core / sample handling sites. The readings from the dosimeters are downloaded monthly when exploration activities are in progress and area monitoring is also conducted monthly. Bannerman engaged a consultant – VO Consulting to design a Radiation Management Plan (RMP) which was approved by the National Radiation Protection Authority (NRPA) in February 2011. In 2016 the RMP was revised and once again approved by the NRPA. Annual radiation monitoring reports are sent to the regulator and the interpretation shows that the total dose to employees and contractors does not exceed the international limit of 20mSv per year for occupational workers. The downloaded data is investigated and inspected for any spikes/abnormalities.

9 AFFECTED PARTIES A number of small holdings located in the Swakop River near Goanikontes are in the vicinity of the EPL area. Bannerman conducted and still conducts ad hoc meetings with the affected parties as the need arises. .

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10 IDENTIFICATION OF POTENTIAL ENVIRONMENTAL IMPACTS ARISING FROM PHASE 1 AND 2 OF THE EXPLORATION ACTIVITIES AND PROPOSED MITIGATION MEASURES

Table 6 sets out the general aspects, which have been and are addressed prior to any exploration activities to ensure that all exploration team members are aware of the aims set out in the EMP. Potential environmental impacts arising specifically from exploration activities in Phase 1 and Phase 2 are listed separately in Table 7 and Table 8. Table 6: General Aspects Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact Exploration To establish a strong General EPL area General • Provision in the budget is made for Environmental Awareness initiation Environmental behavior of and training and for internal and external Environmental Awareness Protocol from exploration Monitoring Costs as well as for rehabilitation costs. the beginning of the team in the EPL • Appointment of a senior person to assume responsibility for exploration programme area. environmental issues. in order to ensure the • All individuals who work on, or visit, the sites are aware of the least possible damage to contents of the EMP – inductions are given. the environment. • The EMP is included in all Tender Documents. • Main access tracks are clearly demarcated and no new tracks are to be made except with the approval of the Bannerman appointed Environmental Officer. Implementation To define roles and General EPL area General • Senior exploration staff and all senior contractors are aware of, of the EMP responsibilities in terms behavior of and implementing, EMP requirements. These people are of the EMP. To make all exploration expected to know and understand the objectives of the EMP persons aware of these team in the and will, by example, encourage suitable environmentally roles and responsibilities MDRL area. aware behavior to be adopted at the site. to ensure that exploration • Immediate recognition will be given to appropriate activities are conducted environmentally acceptable behavior. Any inappropriate in compliance with the behavior will be immediately corrected. An explanation as to EMP. why the behavior is unacceptable must be given, and, if To implement necessary, the person could be disciplined, e.g. for different environmental non-environmental compliance. management that is

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Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact preventative and proactive. To establish the resources, skills, etc. required for effective environmental management. Environmental To implement General EPL area General • Every senior/supervisory member of the team is to familiarise awareness environmental behavior of themselves with the contents of the EMP and to understand briefing / training awareness briefing / exploration their roles and responsibilities in 'walking the talk' and ensuring training for all individuals team in the EPL compliance with the EMP. who visit, or work, on area. • The Environmental Consultants will hold an Environmental site. Awareness Briefing meeting which has to be attended by all exploration and drill contractors before the start of the drilling operation. The meeting will discuss the potential dangers to the environment of the following activities: littering, off-road driving, waste disposal, poaching & plant theft etc. The need to conserve water and implement water saving measures will also be presented. • The need for soil / substrate preservation should be explained. • Individuals can be questioned on the Environmental Philosophy and EMP and must recall the contents. Public relations To maintain sound • Inform the relevant person at MEFT regarding movement. relationships with the • Ongoing meetings with Swakop River residents (affected landowner (Ministry of parties). Environment and Tourism) and affected • No littering occurs. parties.

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Table 7: Potential impacts arising from non-invasive exploration activities during Phase 1 Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact Accommodation None as crew is not General Disturbance of • The geological / geophysical / teams are accommodated in accommodated within environment flora and fauna Swakopmund. the NNP Waste To maintain a clean and Fauna, general Disturbance to • The following waste management procedures shall be management tidy site / area. environment, fauna. implemented: visual impact Visual impact ▪ Minimisation of waste production; ▪ Where possible, compact waste to reduce its bulk; ▪ What is taken in has to be taken out and disposed of at an official waste site; ▪ Waste containers with suitable lids are provided on site; ▪ Illegal dumping and littering is not to be tolerated. Development of Disturbance of general General Visual impact • The old main access track which was established during the Access Roads environment environment Destruction of previous exploration activities and is still clearly visible shall be and Tracks flora used to access the target area. This shall be confirmed in writing by the relevant Ministry. • The reopened main access track shall be clearly signposted to discourage tourist to enter the track. • No additional new tracks will be made. All other areas will be entered on foot.

Table 8: Potential impacts arising from exploration activities during Phase 2 – drilling Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact Accommodation Disturbance of general Fauna, Flora Disturbance of • Geological / drill / rehabilitation teams are accommodated environment fauna and flora either in Swakopmund and/or Farm Weizenberg. Waste To maintain a clean and Fauna, general Disturbance to • The following waste management procedures are implemented environment, fauna. Visual

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Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact management tidy site / area. visual impact impact on site: ▪ Minimise the production of waste; ▪ Where possible, compact waste to reduce its bulk; ▪ What is taken in has to be taken out and disposed at an official waste site; ▪ Waste containers with suitable lids are provided on site and at the camp; ▪ Illegal dumping and littering is not to be tolerated and Bannerman Mining Resources (Namibia) (Pty) Ltd shall make it clear that repeat offenders will have to leave the site. Ensure this is clearly stated in the tender documents. ▪ RC drill sample waste to be disposed off at the approved old Husab Mine trenches Development of Disturbance of general General Visual impact • The target area shall only be entered on the official main Access Roads environment environment access track. and Tracks • To enter the drill sites as much as possible along previously established tracks. • If new tracks have to be created these should not be conducted in a straight line. New tracks shall be driven slightly deviating (approximately 1-2 m) from the centreline. • All newly created tracks shall be rehabilitated after the drill hole has been finalized, e.g. raking the middle ‘berm’, loosen the compacted ground. Management of To undertake the Disturbance of Loss of • Impervious rubber or plastic sheeting is to be used to prevent drill sites respective drilling natural indigenous pollution by diesel, oil and other related sources of pollution. programmes in such a environment vegetation • All litter is placed in a container with a lid that is secured manner that it will be Disturbance of against wind. The rubbish is taken to an official waste site. difficult to determine fauna where these activities • Soil contaminated by oil or diesel is removed and dumped at took place in 5 years the Walvis Bay hazardous waste site.

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Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact time. • The area of disturbance around the borehole site is kept as small as possible. • If possible, the driller collects drilling penetration rates and water information data in addition to the other information that is required. • Rest water levels are taken ideally at the start of drilling, at the end of drilling, at least 24 hours after drilling has stopped, and again 72 hours after stopping. • Boreholes (not drilled at an angle) that intersect water have the casing left in them, the top of the hole around the casing is grouted and the borehole capped immediately before rehabilitating the area. • Drill sites are rehabilitated on an ongoing basis following Procedure 003 ‘Rehabilitation of tracks and drill sites‘. • Open water should be fenced of and preferably covered during night to avoid attraction of bees and wildlife. • Sumps are fenced in to avoid fatalities of animals attracted by the water. Management of To minimise the risk of General Loss of • The Project Manager / Geologist and Contractor have identified hazardous pollution through the environment indigenous all activities that involve the handling of potentially hazardous substances implementation of all vegetation substances and protocols for the handling of these substances reasonable measures to Disturbance of have been put in place and their implementation supervised. prevent leakage, spillage fauna Hazardous substances are handled in accordance with the or inappropriate disposal manufacturer’s specifications and existing legal requirements. of hazardous • The Project Manager / Geologist encourages the use of the substances. least polluting, most rapidly biodegradable cleaning product, To minimise the risk of solvent, etc. hazardous substances • The Project Manager / Geologist and Contractor will ensure affecting the health of all that all individuals, who could be exposed to hazardous individuals and plant and substances, are adequately protected and educated about the

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Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact animal life. safe and proper methods for handling of these substances. To use biodegradable • Procedures for the containment and clean up of accidental products as far as is hazardous accidents are developed by the Project Manager / reasonably possible. Geologist in accordance to the manufacturer’s specifications. • The Project Manager / Geologist or Contractor should immediately implement actions to stop or reduce and contain any spills. • The Project Manager / Geologist arranges and supervises implementation of the necessary clean up procedures and proper disposal of contaminated soil, water and other materials at an approved facility. • Clean up, and dispose of contaminated soil at an official waste site. Management of To monitor radiation Human Exposure to • Dosimeters are provided to staff and contractors to measure radiation exposure of staff and radiation radiation levels. exposure contractors • Area monitoring of gamma radiation, radon gas and radiation in air is done monthly • Readings are interpreted on a monthly basis and the full dose radiation exposure calculated. • Mitigation measures are taken in the unlikely event that the international limit of 20mSv per year for occupational workers be exceeded.

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Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact Surface & To conserve water. General Visual • Borehole rest water levels and quality are recorded. groundwater To avoid the pollution of environment Groundwater / • Working areas, where hazardous substances are handled or management any water and prevent stream pollution stored, are designed to collect and contain hazardous polluted water from substances. Impervious materials are provided, e.g. drip trays, entering stream channels or sumps to collect and contain liquid pollutants. or underground aquifers. To monitor the rest water levels and quality of production boreholes, if water is encountered. Site rehabilitation To rehabilitate the drill General Visual impact • The following rehabilitation actions are recommended: sites and camp to as environment Tourism ▪ All drill mud and cores are removed from site to avoid close an approximation activities additional scars in the landscape following Procedure 002 of the pristine state as is ‘Rehabilitation of Diamond Sumps’; technically, financially ▪ All RC coarse rejects samples are disposed of at the old and reasonably possible. Husab Mine following Procedure 001 ‘Disposal of RC Coarse Reject Samples’ ▪ All litter from the site i.e. bottles, tins, piping, etc are taken to an appropriate disposal site. ▪ All debris, scrap metal, etc is removed before moving to a new drill site. ▪ All drilling mud is either disposed of in the open borehole or taken off site and disposed of at an official waste site. ▪ All water tanks are dismantled and removed. ▪ All sumps are covered and contoured. The stored top soil / substrate is distributed and raked over the disturbed site. • All the tracks to and at the site are rehabilitated by following Procedure 003 ‘Rehabilitation of tracks and drill sites‘. • The following should be undertaken at all disturbed areas that require further rehabilitation:

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Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact ▪ If applicable the stockpiled subsoil / substrate is to be replaced (spread) and/or the site is neatly contour to establish effective drainage patterns; ▪ Re-place the stored topsoil / substrate. • 2 years after rehabilitation the drill sites are not visible from 500m. Management of To avoid, or reduce, the Visual impact • Disturbed areas are kept to a minimum. the natural potential negative impact Tourism • No incidents of poaching or illegal plant or reptile collection are habitat on the bio-physical activities reported. Offenders will be handed over to the authorities. environment, including the scenic value thereof. • No permanent infrastructure will be developed at the exploration camp; • No domestic or other animals are brought to the exploration site. • Any person who causes willful or malicious damage to the environment will be held responsible for repairing the damage immediately and handed over to the authorities. Managing To avoid disturbance of Cultural heritage Damage or • Documented consultation with an archaeologist, and/or local natural heritage known archaeological / destruction expertise when in doubt. sites & artifacts palaeontological sites. • All individuals are aware of which areas are sensitive. To record accurately any • Every pile (not waste or ore material dumps) of stones is new sites found and treated as a possible archaeological site. Do not use them, as report to the responsible the rocks could be a burial cairn or hunting blind. authority. • No heritage objects are moved without a permit from the National Monuments Council and any permitted removal of heritage objects is done under the supervision of a qualified archaeologist, palaeontologist or historian. • Any archaeological sites that are found are not be disturbed, but be carefully photographed, the exact location recorded and the finding reported to the National Monuments Council.

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Affected Potential Activity Aspect Mitigation measure/recommendations/explanation environment impact Visual quality To preserve the scenic Tourism • The movement and use of vehicles be limited to prevent Management aspects of the target activities unnecessary damage to vegetation. area and surroundings. • Any rock sample that is taken from in-situ outcrops is taken To minimise visual from a place that is not visible from potential tourist viewpoints. impacts created by Geological features worth preserving or that could be potential exploration as far as sites of scientific interest are not defaced. reasonably possible. • No new tracks are created, except off the main access track and one-way tracks along the drill grid. All access tracks will be rehabilitated following Procedure 003 ‘Rehabilitation of tracks and drill sites’.

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11 CONCLUSION The EMP (see Section 10) specifies mitigation measures to avoid or minimize identified possible environmental impacts. The mitigation measures in conjunction with any additional measures stipulated in the Environmental Clearance are the legally binding document between the Directorate of Environmental Affairs and all contractors working on Bannerman’s EPL 3345 area.

A. Speiser MSc MPhil A. Speiser Environmental Consultants cc

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References

ASEC, July 2006. Environmental Overview and Management Plan for the Exploration Activities of Turgi Investments (Pty) Ltd on Exclusive Prospecting Licence 3345 ASEC / ERM, April 2012. Etango Project Environmental and Social Impact Assessment, Volume 1 BIWAC, 2010a from Ashton et. al., 1991. An environmental impact statement for the Rössing uranium mine, Namibia. Report to Rössing Uranium Limited, Swakopmund by Water Quality Information Systems, Division of Water Technology, CSIR, Pretoria, South Africa. BIWAC, 2010a from CSIR, 1997. An Assessment of the Potential Environmental Impacts of the proposed Aquifer Recharge Scheme on the Khan River, Namibia. Final Report by CSIR to Rössing Uranium Ltd., Report No. ENV/P/C – 97104, Swakopmund, Namibia. http://209.88.21.36/Atlas/Atlas_web.htm http://weather.namsearch.com http://209.88.21.36/Atlas/Atlas_web.htm http://209.88.21.36/Atlas/Atlas_web.htm http://209.88.21.36/Atlas/Atlas_web.htm http://209.88.21.36/Atlas/Atlas_web.htm http://weather.namsearch.com Irish, J., 1994. Biomes of Namibia. Navorsings van die Nasionale Museum 9South Africa) 10:550-584. Liebenberg-Enslin, H., Krause, N. and Breitenbach, N., 2010. Strategic Environmental Assessment for the Central Namib ‘Uranium Rush’, Air Quality Specialist Report. Report Number APP/09/MME-01 Rev1. Namibia Tourism Board (NTB, MET), 2006. The impact of travel and tourism on jobs and the economy. National Planning Commission, 2007. ERONGO, Regional Poverty Profile, Republic of Namibia, National Planning Commission Rutherford M. C. & Westfall R. H., 1986. Biomes of southern Africa – an objective categorization. Mem. Bot. Surv. S. Arf. 54:1-98.

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APPENDIX 1 – Environmental Clearance

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APPENDIX 2 –

PERMIT – ‘DRILL CHIP DISPOSAL AT THE OLD HUSAB MINE’

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APPENDIX 3

Details of EPL as granted by the Ministry of Mines & Energy

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APPENDIX 4 – Rehabilitation Procedures 001 – 003

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Procedure Number: 0001 Version: .002

Review Date: June 2011

Task: Disposal of RC Coarse Reject Samples

Department: Environmental

Introduction Disposal of RC coarse rejects occurs on a daily basis. The samples for disposal will be collected directly from the drillhole collar position or from company storage facilities. The samples will be loaded into dumpster bins before transport to an approved waste disposal facility. A record of the level of radiation must be taken and recorded on each full dumpster before it is transported to the waste disposal site. These completed record sheets must be returned to the Company office for scanning, data entry and storage of originals.

PPE Required • Overalls • Gloves • Dust masks • Steel Cap boots

Safety The disposal of RC coarse rejects involves the manual handling of heavy bags of drill spoil. Care should be taken to use the correct manual handling technique for heavy objects. If the bags are particularly heavy, two people should be used to complete the lift. Lifting bags into the dumpster or onto the rear of a backie will involve lifting above waist height. If possible this should be avoided and samples loaded via the open rear door of the backie. If possible place the dumpster in a depression or next to a mound of material to minimise the required lift. The RC rejects will contain fine grained uranium minerals that are potentially dangerous if inhaled (breathed in) or ingested (eaten). At all times care should be taken to avoid eating or breathing the fine dust. Dust masks are to be worn at all times and hands and faces should be washed with water before consuming any food or smoking a cigarette. Dust will accumulate on the work cloths. It is a requirement that the workers shower in the facilities provided and change into clean cloths before returning to their homes.

Equipment Required Ludlum Radiation Meter – (Budgie) RC Coarse Reject Record Sheet

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Procedure • Fill the dumpster with the reject RC drill cutting bags • Do not place too many bags in the dumpster - we do not wish to lose material in transit. If the dumpster doesn’t have a lid (as shown in the picture) secure shade netting tightly over it to ensure that no spillages (loss) occurs during transport. • Record the date the bin is collected for disposal • Record the bin number – the same bin maybe used multiple times each month • Record the hole numbers which are contained within the dumpster and sample number (if the last hole can’t be accommodated totally) • Record the budgie values at the four designated positions on the dumpster (see diagram). The locations are at the middle of each side of the bin. Position 1 is at the end of the bin and sides are numbered in a clockwise direction trough to Position 4 • Measure the dose rate on each of the four positions on the skip • Record the measured values in the waste dump information sheet • Measure the dose rate at a distance of one (1) meter from each of the four designated positions • Record the measured values in the waste dump information sheet

3 2 1 4

Bugie Operation 1. Select Normal on the vertical slide 2. Select x1 in the horizontal slide 3. Place the budgie directly on the bin and hold steady for a least 30 seconds 4. If the counts per minute CPM exceeds 500, move the horizontal slide to x10 5. Repeat stages 3 and if necessary stage 4 moving to x100. 6. Record the budgie reading and do not forget to multiply by the ‘x10’ or ’x100’ factor if necessary 7. If the CPM value exceeds 500 notify Bannerman Management before allowing the dumpster to be collected, alternative actions may be required.

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RC Coarse Reject Record Sheet

Date CPM Bin # Site_name Trench # Signature removed Side 1 Side 2 Side 3 Side 4 On 1m On 1m On 1m On 1m

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Procedure Number: 0002 Version: .002 Review Date: June 2011

Task: Rehabilitation of Diamond Sumps Department: Environmental

Introduction At the completion of each diamond drillhole there remains a sump that contains water, drilling muds and drill cuttings. Adjacent to the sumps there will be spoil that was excavated to create the sump. The drilling residue (water, drill cuttings and drilling muds) needs to be removed so that the spoil can be returned to the sump to recreate the original surface. Currently arrangements for disposal of residue drilling muds have not been made; therefore the material will need to be disposed off at a designated location e.g. Husab trenches. Drilling muds are water soluble, not hydrocarbon based and environmentally safe. However, they have been introduced to a sensitive ecological environment and should be removed where ver possible.

PPE Required • Safety glasses (during fence erection or dismantling) • Overalls • Gloves • Steel Caped rubber boots

Safety Diamond drill sumps must be left to dry out completely before material is disposed off . Special care needs to be taken to ensure staff does not loose their footing and slip while entering, working in or leaving the sump. Lifting bags / buckets from the sump may involve lifting above waist height. Care and correct manual handling procedures need to be followed while completing this task especially since footing will be slippery.

Dust from drill cuttings and drilling chemicals will accumulate on the work cloths. It is a requirement that the workers shower in the facilities provided and change into clean cloths before returning to their homes.

Equipment Required Fencing Materials (wire and posts) Bucket / scoop Shovels / Bags

Procedure

• Immediately after the completion of the drill hole – fence off the drill sumps to ensure animals have no access • Leave sumps to dry out completely – no mud • Excavate and bag dried out drill cuttings to be disposed of with the RC Coarse Reject samples. (See Procedure 001)

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• Back fill the sumps and trenches using spoil excavated and stockpiled adjacent to the sumps, taking care to return the rock to the bottom of the sump and returning the soil/weathered horizon to the surface recreating the original profile

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Procedure Number: 0003 Version: .002 Review Date: June 2011

Task: Rehabilitation of tracks and drill sites Department: Environmental

POLICY STATEMENT AND OBJECTIVES Bannerman is currently undertaking exploration works in its Exploration licence (EPL 3345). A large portion of the EPL is located within the Namib Naukluft National Park (NNP) and the balance within the Dorob National Park, which has recently been proclaimed as National Park. Bannerman recognises that the landscape has an aesthetic value, that the area is host to a variety of fauna and flora and that the ecosystem is sensitive to disturbance. Bannerman is therefore committed to minimising disturbance created from its drilling activities by: • Planning where to place drill sites and access roads; • Minimising the footprint of drill sites and keeping active working areas clean; • Undertaking ongoing rehabilitation of drill sites and roads once exploration activities have been completed.

SCOPE The aim of this procedure is to provide guidance on the rehabilitation of tracks and drill sites across a variety of different landscapes, including sandy river beds, gravel plains and rocky hills. This procedure is applicable to all areas disturbed by Bannerman’s exploration activities and is applicable to both Bannerman’s personnel and its contractors.

DEFINITIONS AND ABBREVIATIONS Definitions Ephemeral stream – a stream that flows only after rain and has no baseflow component (Oxford dictionary of ecology). Rehabilitation A general term referring to all measures taken to repair damaged environments including the removal of infrastructure, cleaning up pollution and re-vegetating (Burke, 2007). Restoration refers to the process of reinstating a habitat’s environmental conditions as well as plants and

Abbreviations MET Ministry of Environment and Tourism NNP Namib Naukluft National Park DNP Dorob National Park

PROCEDURE Reason for rehabilitating and restoring the environment Rehabilitation of disturbed areas is undertaken for two main reasons: • To minimise the visual impact ; • To reinstate disturbed areas so that they can become integrated into functioning ecosystems.

It is relatively easy to rake tracks until the footprint has disappeared and it looks neat. However, this does not mean that the area has been restored, will not be damaged by water or wind or that plants will grow in the rehabilitated area. To ensure that the rehabilitation remains in place over time and that the environmental conditions are restored one needs to: • Understand the environment in which one is working (e.g. gravel plains or drainage areas); • Understand the nature of the damage that has been done (e.g. compaction, disturbance of surface crusts); • Choose the appropriate rehabilitation methods for that specific site.

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Understanding the environment During a vegetation study, four broad landscapes types (zones) were identified within the Bannerman EPL. They are: • Flat sandy gravel plains with shallow ephemeral washes; • Gently undulating hills with shallow soil and low rock outcrops; • Deeply incised, rocky landscape with steep slopes; • Swakop River and its main tributaries.

Choosing the appropriate restoration methodology Restoration and rehabilitation is not a fixed science. The most suitable approach will not only vary from one landscape to the next but will also be affected by the severity of the impact. This procedure provides a broad guideline of the components that must be considered when undertaking restoration at Bannerman. However, it will be important to evaluate each drill line and drill site independently and apply the rehabilitation technique you believe to be most appropriate. As very little restoration work has been done in the central Namib it is essential that all undertakings be viewed as an experiment and that Bannerman review and modify their methodologies based on the outcomes of their trials.

Restoration of tracks and drill sites When restoring tracks and drill sites the following objectives should be considered: • The visual impact of exploration is kept as small as possible; • The public are discouraged from driving of the main road; • The Company’s reputation of running a tidy operation is maintained; • A habitat’s environmental conditions as well as plants and animals that were there before the disturbance can be reinstated. The steps to be followed when doing restoration are outlined in Table 1.

RESPONSIBILITES It is the Exploration Superintendent’s responsibility to ensure: • Communication of this procedure to relevant Bannerman employees and contractors; • Implementation of this procedure; • Review this document periodically.

TRAINING All personnel (Bannerman and contractors) involved in exploration shall receive training in the use of this procedure. Records of training will be kept.

SUPPORTING DOCUMENTATION Environmental procedures:

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• 0001 – Disposal of RC Coarse Reject Sample

• 0002 - Rehabilitation of Diamond Sumps.

TABLE 1: REHABILITATION APPROACH

PLANNING To be done by BANNERMAN and the ENVIRONMETNAL CONSULTANT Before disturbing a site, visit the area and choose the best location. • Aim to avoid damage to plants. (In rocky areas particularly, consult with the environmental consultant before destroying plants of conservation concern). • Try to avoid working on steep slopes but if this is required avoid creating scars that cut directly up the steep slope.

Minimise the disturbance footprint.

• Clearly designate the permitted working area. The geologist should demarcate the drill site working area prior to the drill rig arriving, or on the first day of arrival. • Keep infrastructure (vehicles, water tanks, core samples etc) within the demarcated working area. • Create a turning circle for the vehicles. • No oil is to be stored on drill sites. All oil is stored at a designated area off site. • Contractors to have plastic sheeting or absorbent mats to manage general spillages and to accommodate accidents (hydraulic failures).

Take a photograph of the site prior to disturbance

• For each line that is drilled a few reference photos should be taken (GPS coordinates and direction of photo must be noted). These photos will help assess the effectiveness of final restoration.

Relocate plants

• If plants of conservation concern are present consult with the Environmental Consultant and if necessary relocate them to another appropriate site or to store them use during rehabilitation. • If necessary obtain a plant removal permit from the authorities (Department of Forestry for protected trees or MET for other plants).

EXPLORATION ACTIVITIES To be done by BANNERMAN and the DRILLING CONTRACTORS Minimise disturbance by operating strictly in the designated work areas and tracks. • The Exploration Superintendent must inspect the drill lines to ensure that the drillers and other geologists are not creating unnecessary disturbance (e.g. excessive tracks or expanding a drill site) Domestic waste to be removed • Drilling contractors to remove litter off site on a daily basis and dispose of in town.

Clean up diesel or oil spills immediately

Drilling contractors to minimise and manage all hydrocarbon (diesel, oils and greases) spills in the following way:

• Avoid hydrocarbon pollution by using an appropriate mat to absorb/collect general spills • Dig up areas polluted by hydrocarbons. • Ensure that all of the pollution is removed. • Dispose of the contaminated sand in the skip set aside for RC grits and Diamond drill slimes. • Dispose of this waste at the designated site.

Photograph the site once exploration has finished but prior to rehabilitation starting.

• For every line drilled a few photos should be taken before rehabilitation commences to provide a before and after comparison. GPS coordinates and direction of photo must be noted.

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FINAL REHABILITATION To be done by BANNERMAN and the REHABILITATION CONTRACTORS Remove any residual evidence of litter and dispose at the landfill in Swakopmund.

Diesel and oil spills • Report diesel spills to the Geologist so that the Drilling Contractors can be called in to deal with their spillage.

Rip compacted areas

• Rip areas that have been compacted. This can be achieved by using picks and rakes or in heavily compacted areas by using a ripper. • When ripping, try to avoid creating parallel furrows that will promote erosion. • Ripping should occur to full rooting depth. On gravel plains a depth of about 50mm should be adequate as this will break down the compaction without loosening too much of the soil. Fill in holes and troughs

• After ripping compacted areas, fill in holes and road troughs with subsurface material (rocks in first, then sand). • RC drilling chips can be used to infill deep holes but the powder must not come to surface. • Do not fill in holes with sand alone as the wind will scour the sand out and re-establish the hole.

Reshape the disturbed area to fit in with the adjacent landscape

• Rake soil and gravel from adjacent areas to try and recreate the same texture and look as surrounding areas. Rakes are used to distribute the stones so that the texture is the same as the other areas. • If necessary sweep the area using brooms. Sweeping fills in the spaces between the stones with the fine sand and removes visible borders such as road edges.

Special considerations

• Reintroduction of plants. If plants were removed initially, liaise with the environmental consultant to assess the merit or relocating plants from the surrounding area back into the rehabilitated tracks or drill sites. • Formation of desert pavement and crusts On the gravel plains and hill slopes, spray a fine water mist over the rehabilitated area, thus allowing a crust to form. Ideally, people using watering cans or a light vehicle should be used to do this to avoid re-compaction of the soils. • Rehabilitating steep slopes. After raking, pack stone berms across the disturbed site so as to minimise the likelihood of erosion from water or wind. These berms may be removed after a couple of years (if area is restored and berms pose a visual impact). • Rehabilitation of tracks near to main roads. To minimise the likelihood of the public leaving the main road to investigate exploration sites, pay particular attention to sections of track within the first 25m from the main road. • Discouraging the public from using rehabilitated tracks. If necessary physical barricades may need to be considered for an interim period once the rehabilitation work has been completed, so as to prevent the public using the track, particularly adjacent to the main road, in the hills to the north of the Swakop River and the Swakop’s main tributaries.

MONITORING To be done by the ENVIRONMENTAL CONSULTANT and BANNERMAN Assess rehabilitation work

• Bring in the Environmental consultant to assess rehabilitation efforts. • If the visual impacts of the disturbed sites have been removed and the surface texture re-established, then the rehabilitation work will be considered complete for that site and the rehabilitation contractor will

EO /EMP for Bannerman Mining Resources exploration activities on EPL 3345 be paid. If not the contractor will be required to address deficiencies. • As rehabilitation is a dynamic process it must be seen as an experiment. If a particular approach does not appear to be working methodologies will be amended. Photograph the site once rehabilitation is complete • An ‘after’ photo will be taken for comparison with the ‘before’ photos.

Monitor rehabilitated sites • Inform NNP and DNP officials of those sections that have been rehabilitated, so that they can try and avoid damage by future users. • Establish representative sites that will be used as long term monitoring sites. On a biannual basis, or after specific natural events such as rainfall or wind storms, monitor rehabilitated sites. • Take photos to record rehabilitation success. • Compare these sites against the reference photos taken before drilling.

Close off rehabilitated areas • If after two years the rehabilitated areas are still in tact and the landscape functionality approximates the adjacent areas then the area can be closed out.

• A final close out form is required from MET.

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