ERPM Ext 2 EIAR Empr

FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT AND ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

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

NAME OF APPLICANT: ERPM Extension Area 1 (Pty) Ltd

TEL NO: 084 050 4613 FAX NO: 086 684 8245 POSTAL ADDRESS: PO Box 6213, Cresta, 2118 PHYSICAL ADDRESS: CAMI House, 4 Fir Drive, Northcliff, 2195 FILE REFERENCE NUMBER SAMRAD: GP 30/5/1/2/2 10078 MR

OCTOBER 2019

ERPM Ext 2 Mine, East Rand, Gauteng i Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

1. IMPORTANT NOTICE In terms of the Mineral and Petroleum Resources Development Act (Act 28 of 2002 as amended), the Minister must grant a prospecting or mining right if among others the mining “will not result in unacceptable pollution, ecological degradation or damage to the environment”.

Unless an Environmental Authorisation can be granted following the evaluation of an Environmental Impact Assessment and an Environmental Management Programme report in terms of the National Environmental Management Act (Act 107 of 1998) (NEMA), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological degradation or damage to the environment.

In terms of section 16(3)(b) of the EIA Regulations, 2014, any report submitted as part of an application must be prepared in a format that may be determined by the CA and in terms of section 17 (1) (c) the CA must check whether the application has taken into account any minimum requirements applicable or instructions or guidance provided by the CA to the submission of applications.

It is therefore an instruction that the prescribed reports required in respect of applications for an environmental authorisation for listed activities triggered by an application for a right or a permit are submitted in the exact format of, and provide all the information required in terms of, this template. Furthermore please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the Regulation and will lead to the Environmental Authorisation being refused.

It is furthermore an instruction that the Environmental Assessment Practitioner must process and interpret his/her research and analysis and use the findings thereof to compile the information required herein. (Unprocessed supporting information may be attached as appendices). The EAP must ensure that the information required is placed correctly in the relevant sections of the Report, in the order, and under the provided headings as set out below, and ensure that the report is not cluttered with un-interpreted information and that it unambiguously represents the interpretation of the applicant.

2. OBJECTIVE OF THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS The objective of the environmental impact assessment process is to, through a consultative process— (a) determine the policy and legislative context within which the activity is located and document how the proposed activity complies with and responds to the policy and legislative context; (b) describe the need and desirability of the proposed activity, including the need and desirability of the activity in the context of the preferred location; (c) identify the location of the development footprint within the preferred site based on an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all the identified development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects of the environment; (d) determine the—- (i) nature, significance, consequence, extent, duration and probability of the impacts occurring to inform identified preferred alternatives; and (ii) degree to which these impacts— (aa) can be reversed; (bb) may cause irreplaceable loss of resources, and (cc) can be avoided, managed or mitigated; (e) identify the most ideal location for the activity within the preferred site based on the lowest level of environmental sensitivity identified during the assessment; (f) identify, assess, and rank the impacts the activity will impose on the preferred location through the life of the activity; (g) identify suitable measures to manage, avoid or mitigate identified impacts; and (h) identify residual risks that need to be managed and monitored.

ERPM Ext 2 Mine, East Rand, Gauteng ii Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

ACRONYMS AND ABBREVIATIONS

AEL Atmospheric Emission Licence BID Background Information Document CA Competent Authority CBA Critical Biodiversity Area CoE City of Ekurhuleni C-Plan Gauteng Conservation Plan CR Critically Endangered CRR Comments and Response Report DAFF Department of Agriculture, Fisheries and Forestry DMR Department of Mineral Resources DRDLR Gauteng Department of Rural Development and Land Reform DWS Department of Water and Sanitation EA Environmental Authorisation EAP Environmental Assessment Practitioner EC Electrical Conductivity EIA Environmental Impact Assessment EIAR Environmental Impact Assessment Report EMM Ekurhuleni Metropolitan Municipality EMPr Environmental Management Programme EN Endangered ERPM East Rand Proprietary Mines Limited ESA Ecological Support Area Gautrans Gauteng Department of Roads and Transport GDARD Gauteng Department of Agriculture and Rural Development GDP Gross Domestic Product GPEMF Gauteng Province Environmental Management Framework IAPs Interested and Affected Parties IDP Integrated Development Plan LoM Life of Mine mamsl Metres above mean sea level mBC Metres below collar mbgl Metres below ground level MPRDA Minerals and Petroleum Resources Development Act (No. 28 of 2002) NAAQS National Ambient Air Quality Standards NEMA National Environmental Management Act (No. 107 of 1998) NEMAQA National Environmental Management Air Quality Act, No. 39 of 2004 NEMBA National Environmental Management: Biodiversity Act, No. 10 of 2004 NEMPAA National Environmental Management Protected Areas Amendment Act, No. 31 of 2004 NEMWA National Environmental Management Waste Act, No. 59 of 2008 NFEPA National Freshwater Ecosystem Priority Areas NHRA National Heritage Resources Act, No. 25 of 1999 NNR National Nuclear Regulator NNRA National Nuclear Regulator Act, No. 47 of 1999 NWA National Water Act, No. 36 of 1998 HSO Health and Safety Officer PES Present Ecological State

ERPM Ext 2 Mine, East Rand, Gauteng iii Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

PHRAG Provincial Heritage Resources Authority of Gauteng PPP Public Participation Process RE Remaining Extent ROD Record of Decision RSDF Regional Spatial Development Framework SAHRA South African Heritage Resources Association SAHRIS South African Heritage Resources Information System SANS South African National Standards SCC Species of Conservation Concern SDA Surface Development Area/s TDS Total Dissolved Solids VU Vulnerable WML Waste Management Licence WRD Waste Rock Dump WUL Water Use Licence WULA Water Use Licence Application

ERPM Ext 2 Mine, East Rand, Gauteng iv Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

TABLE OF CONTENTS

1. IMPORTANT NOTICE ...... II

2. OBJECTIVE OF THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS ...... II

ACRONYMS AND ABBREVIATIONS ...... III

PART A ...... 1

3. CONTACT PERSON AND CORRESPONDENCE ADDRESS ...... 1

a) Details ...... 1 b) Description of the property...... 1 c) Locality map (show nearest town, scale not smaller than 1:250000) ...... 2 d) Description of the scope of the proposed overall activity (Provide a plan drawn to a scale acceptable to the competent authority but not less than 1: 10 000 that shows the location, and area (hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site) ...... 3 e) Policy and Legislative Context ...... 15 f) Need and desirability of the proposed activities (Motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location) ...... 23 g) Motivation for the preferred development footprint within the approved site including a full description of the process followed to reach the proposed development footprint within the approved site (NB!! – This section is about the determination of the specific site layout and the location of infrastructure and activities on site, having taken into consideration the issues raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout)...... 23 b) Full description of the process undertaken to identify, assess and rank the impacts and risks the activity will impose on the preferred site (In respect of the final site layout plan through the life of the activity. Including (i) a description of all environmental issues and risks that were identified during the environmental impact assessment process and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures) ...... 127 c) Assessment of each identified potentially significant impact and risk (This section of the report must consider all the known typical impacts of each of the activities (including those that could or should have been identified by knowledgeable persons) and not only those that were raised by registered interested and affected parties - the supporting impact assessment conducted by the EAP must be attached as an appendix) ...... 128 d) Summary of specialist reports (This summary must be completed if any specialist reports informed the impact assessment and final site layout process and must be in the following tabular form - attach copies of Specialist Reports as appendices) ...... 134 e) Environmental impact statement ...... 148 f) Proposed impact management objectives and the impact management outcomes for inclusion in the EMPr (Based on the assessment and where applicable the recommendations from specialist reports, the recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation) ...... 148 g) Final proposed alternatives (Provide an explanation for the final layout of the infrastructure and activities on the overall site as shown on the final site map together with the reasons why they are the final proposed alternatives which respond to the impact management measures, avoidance, and mitigation measures identified through the assessment) ...... 149 h) Aspects for inclusion as conditions of Authorisation (Any aspects which have not formed part of the EMPr that must be made conditions of the Environmental Authorisation) ...... 149 i) Description of any assumptions, uncertainties and gaps in knowledge (Which relate to the assessment and mitigation measures proposed) ...... 149

ERPM Ext 2 Mine, East Rand, Gauteng v Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

j) Reasoned opinion as to whether the proposed activity should or should not be authorised ...... 152 k) Period for which the Environmental Authorisation is required ...... 153 l) Undertaking (Confirm that the undertaking required to meet the requirements of this section is provided at the end of the EMPr and is applicable to both the Environmental Impact Assessment report and the Environmental Management Programme report) ...... 153 m) Financial Provision (State the amount that is required to both manage and rehabilitate the environment in respect of rehabilitation) ...... 153 n) Deviations from the approved scoping report and plan of study ...... 155 o) Other Information required by the competent Authority...... 155 p) Other matters required in terms of sections 24(4)(a) and (b) of the Act (the EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in sub-regulation 22(2)(h), exist. - the EAP must attach such motivation as an appendix) ...... 157

PART B ...... 159

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT ...... 159

1) DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME ...... 159

a) Details of the EAP (Confirm that the requirement for the provision of the details and expertise of the EAP are already included in PART A herein as required) ...... 159 b) Description of the Aspects of the Activity (Confirm that the requirement to describe the aspects of the activity that are covered by the environmental management programme is already included in PART A herein as required) ...... 159 c) Composite Map (Provide a map at an appropriate scale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffers) ...... 159 d) Description of Impact management objectives including management statements ...... 159 e) Impact management outcomes (A description of impact management outcomes, identifying the standard of impact management required for the aspects requiring management) ...... 165 f) Impact management actions (A description of impact management actions, identifying the manner in which the impact management objectives and outcomes contemplated in the paragraphs above will be achieved) ...... 169 g. Monitoring of Impact Management Actions ...... 190 h. Monitoring and reporting frequency ...... 190 i. Responsible persons ...... 190 j. Time period for implementing impact management actions ...... 190 k. Mechanism for monitoring compliance ...... 190 l. Indicate the frequency of the submission of the performance assessment report ...... 204 m. Environmental Awareness Plan ...... 204 n. Specific information required by the Competent Authority (among others, confirm that the financial provision will be reviewed annually) ...... 209

2) UNDERTAKING ...... 211

3) UNDERTAKING UNDER OATH/ AFFIRMATION ...... 211

-END- ...... 211

ERPM Ext 2 Mine, East Rand, Gauteng vi Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

FIGURES

Figure 1: Locality map indicating the Mining Right Area (MRA) and Surface Development Areas (SDAs) ...... 2 Figure 2: ERPM Extension Area 2 site plan ...... 7 Figure 3: Map showing the location of the listed activities associated with ERPM Extension Area 2 ...... 8 Figure 4: Location and extent of activities at the Windmill Shaft SDA ...... 9 Figure 5: Infrastructure to be placed at the Windmill Shaft SDA ...... 10 Figure 6: Location and extent of activities at the Witpoortje Vent Shaft SDA ...... 11 Figure 7: Infrastructure to be placed at the Witpoortje Vent Shaft SDA ...... 12 Figure 8: ERPM Ext 1’s contiguous mining rights (ERPM and Ext 1) with the current project (Ext 2) ...... 13 Figure 9: Witpoortje Vent Shaft SDA relative to the CoE Region D RSDF ...... 20 Figure 10: Windmill Shaft SDA relative to the CoE Region E RSDF ...... 21 Figure 11: Mining Right area and SDAs relative to the GPEMF zoning ...... 22 Figure 12: Monthly total rainfall and average daily temperatures, Springs, CoE (Source: WeatherSA, 2018) ...... 90 Figure 13: Annual wind rose for the period 2012 – 2014 (Source: South African Weather Service OR Tambo Weather Station) .... 91 Figure 14: Soils associated with the Windmill Shaft SDA ...... 94 Figure 15: Soils associated with the Witpoortje Vent Shaft SDA ...... 95 Figure 16: Disturbed soil within the Witpoortje Vent Shaft SDA ...... 96 Figure 17: Land cover for the proposed mining right and SDAs (South African National Land-Cover, 2014) ...... 96 Figure 18: Heritage sites near the proposed Witpoortje Vent Shaft SDA ...... 97 Figure 19: Palaeosensitvity of ERPM Ext. 2 MRA ...... 98 Figure 20: Geology in the project area ...... 99 Figure 21: Hydrocensus borehole positions and groundwater level elevation contours ...... 101 Figure 22: The monthly seasonal flow pattern of the Rietspruit ...... 103 Figure 23: The annual flow in the Rietspruit ...... 104 Figure 24: Regional map of Ekurhuleni (EMM, 2015) ...... 108 Figure 25: Language profile ...... 109 Figure 26: Education profile ...... 109 Figure 27: Household utilities ...... 110 Figure 28: Employment and annual household income ...... 110 Figure 29: Location of ERPM Ext. 2 relative to surrounding wards and existing and proposed residential areas ...... 111 Figure 30: Ecosystem types of the project area ...... 114 Figure 31: Vegetation types of the project area ...... 115 Figure 32: CVB wetland near the Witpoortje Vent Shaft SDA ...... 117 Figure 33: HSS wetland near the Windmill Shaft SDA ...... 117 Figure 34. Location of ERPM Ext. 2 Mine relative to surrounding environmental and current land use features ...... 121

ERPM Ext 2 Mine, East Rand, Gauteng vii Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

TABLES

Table 1: Locations of the dust fallout buckets and respective co-ordinates ...... 92 Table 2: Locations of the passive samplers and the respective co-ordinates ...... 93 Table 3: Hydrocensus results ...... 100 Table 4: The existing flow records of Gauging Station C2H136 in the Rietspruit ...... 104 Table 5: Surface water quality monitoring results for the samples collected from the streams associated with the ERPM Ext 2 Mine ...... 104 Table 6: Sound level measurement sites near the Windmill Shaft SDA ...... 106 Table 7: Sound level measurement sites near the Witpoortje Vent ShaftSDA ...... 106 Table 8: Statistical profile of Ward 105, 99, 82 and 74 of Region E ...... 109 Table 9: Current and planned land use for the SDAs ...... 119 Table 10: Assessment of potentially significant risks ...... 129 Table 11: Specialist reports that informed the EIA process ...... 134 Table 12: Specialist recommendations considered in the EIA process ...... 135 Table 13: Standard guiding impact management outcomes...... 165 Table 14: Impact management and monitoring ...... 169 Table 15: Air quality management measures ...... 170 Table 16: Heritage, archaeology and palaeontology management measures ...... 171 Table 17: Biodiversity management measures ...... 172 Table 18: Blasting and subsidence management measures ...... 174 Table 19: Noise management measures ...... 175 Table 20: Socio-Economic management measures ...... 176 Table 21: Soil management measures ...... 178 Table 22: Traffic management measures ...... 180 Table 23: Visual management measures ...... 181 Table 24: Water management measures ...... 182 Table 25: Hydrocarbon management measures ...... 184 Table 26: General waste management measures ...... 185 Table 27: Hazardous substances / hazardous waste management measures...... 186 Table 28: Summary of environmental monitoring mechanisms ...... 190 Table 29: Environmental monitoring programmes ...... 194 Table 30: Air quality monitoring points ...... 203 Table 31: Blast monitoring points ...... 203 Table 32: List of possible installations within the regulatory 500 m for Shaft A and Shaft B ...... 203 Table 33: Blasting monitoring objectives ...... 203 Table 34: Noise monitoring points ...... 204 Table 35: Acceptable rating levels for noise in districts (SANS 10103: 2008) ...... 204

ERPM Ext 2 Mine, East Rand, Gauteng viii Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

PART A SCOPE OF ASSESSMENT AND ENVIRONMENTAL IMPACT ASSESSMENT REPORT

3. CONTACT PERSON AND CORRESPONDENCE ADDRESS a) Details i) Details of the EAP

Name of Environmental Assessment Practitioner (EAP) Prime Resources (Pty) Ltd Physical Address: 70 - 7th Avenue, Parktown North, Johannesburg Postal Address: PO Box 2316, Parklands, 2121 Telephone Number: 011 447 4888 Fax Number: 086 604 2219 Email: [email protected] Professional Affiliations: PrEng; PrSciNat, SAIMM ii) Expertise of the EAP

The qualifications of the EAP (With evidence refer to Appendix 1)

Prime Resources (Pty) Ltd is a specialist environmental consulting firm providing environmental, social, and related services, which was established in 2003. Prime Resources was founded by Peter Theron (PrEng, SAIMM), the Managing Director and Principal Environmental Consultant of the firm. Peter has a GDE Environmental Engineering from the University of Witwatersrand and over 30 years’ experience in the field of environmental science and engineering.

Gené Main (Pr.Sci.Nat, Environmental Science), the Project Manager and Principal Scientist for the proposed project, has a M.Sc. (Botany) from the University of the Western Cape and 12 years’ experience in the field of environmental science.

Louise Jones, the Senior Environmental Scientist for the proposed project, has a M.Sc. (Environmental Science) and six years’ experience working on projects in South Africa, and internationally, in the mining, industrial and waste management sectors. Her experience includes performance assessments, social and labour plans, financial liability assessments associated with mine closure and rehabilitation, environmental impact assessments and management programmes and environmental compliance auditing. Louise also has experience in Geographic Information Systems.

Key Prime Resources Personnel CVs are included as Appendix 1.

Summary of the EAP’s past experience (In carrying out the Environmental Impact Assessment Procedure)

A copy of the Prime Resources Company Profile is attached as Appendix 2. b) Description of the property

Farm Name: Portions 5 and 19 of the farm Witpoortje 117 IR Approximately 27 ha Application area (Ha) 19.6 ha comprises the Windmill Shaft surface development area (SDA) 7.3 ha comprises the re-opening and re-equipping of the Witpoortje Vent Shaft SDA Magisterial district: Ekurhuleni South East Magisterial District in the City of Ekurhuleni, Gauteng Province Distance and direction from 7 km South-East of Boksburg Town nearest town 11 km East of Vosloorus 21 digit Surveyor General Code Portion 5 of the Farm Witpoortje 117 IR - T0IR00000000011700005 for each farm portion Portion 19 of the Farm Witpoortje 117 IR - T0IR00000000011700019

ERPM Ext 2 Mine, East Rand, Gauteng 1 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 c) Locality map (show nearest town, scale not smaller than 1:250000)

Figure 1: Locality map indicating the Mining Right Area (MRA) and Surface Development Areas (SDAs)

ERPM Ext 2 Mine, East Rand, Gauteng 2 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 d) Description of the scope of the proposed overall activity (Provide a plan drawn to a scale acceptable to the competent authority but not less than 1: 10 000 that shows the location, and area (hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site) i) Listed and specified activities

NAME OF ACTIVITY (All activities including activities not listed) LISTED (E.g. Excavations, blasting, stockpiles, discard ACTIVITY dumps or dams, Loading, hauling and transport, AERIAL Mark with Water supply dams and boreholes, EXTENT APPLICABLE LISTING NOTICE an X where accommodation, offices, ablution, stores, Ha or m² applicable workshops, processing plant, storm water control, or affected. berms, roads, pipelines, power lines, conveyors, etc…etc…etc.) Listing Notice 2 (GNR984 of 2014) (As amended by GNR325 of 2017) Activity 17 Any activity including the operation of that activity which requires a mining right as contemplated in section 22 of the Underground mining activities 3 850 ha X Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002), including associated infrastructure, structures and earthworks, directly related to the extraction of a mineral resource, including activities for which an exemption has been issued in terms of section 106 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002). Listing Notice 1 (GNR983 of 2014) (As amended by GNR327 of 2017) Activity 2 (No longer applicable) The development and related operation of facilities or infrastructure for the generation of electricity from a non-renewable resource where- (i) the electricity output is more than 10 megawatts but less than 20 megawatts; or (ii) the output is 10 megawatts or less but the total extent of the facility covers an area in excess of 1 hectare.

Activity 9(No longer applicable) Surface infrastructure including refrigeration plant, The development of infrastructure exceeding 1000 metres in length for the bulk transportation of water or storm water- access shaft and associated head gear, vent shaft, (i) with an internal diameter of 0,36 metres or more; or change house, administrative buildings, workshops, (ii) with a peak throughput of 120 litres per second or more; excluding where- water treatment plant, powerlines (power supply (a) such infrastructure is for bulk transportation of water or storm water or storm water drainage inside a road reserve; or connection), water pipelines, salvage yard, topsoil 27 ha X (b) where such development will occur within an urban area. stockpiles, stormwater and pollution control

infrastructure, bulk fuel storage, explosives handling Activity 10(No longer applicable) area, access roads, parking area, a stores area and a The development and related operation of infrastructure exceeding 1000 metres in length for the bulk transportation of backfill / grout plant sewage, effluent, process water, waste water, return water, industrial discharge or slimes (i) with an internal diameter of 0,36 metres or more; or (ii) with a peak throughput of 120 litres per second or more; excluding where- (a) such infrastructure is for bulk transportation of sewage, effluent, process water, waste water, return water, industrial discharge or slimes inside a road reserve; or (b) where such development will occur within an urban area.

Activity 14(No longer applicable)

ERPM Ext 2 Mine, East Rand, Gauteng 3 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Activity 16 The development and related operation of facilities for the desalination of water with a design capacity to produce more than 100 cubic metres of treated water per day.

Activity 20 (New activity not included in EA application) Any activity including the operation of that activity which requires a prospecting right in terms of section 16 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002).

Activity 25 The development and related operation of facilities or infrastructure for the treatment of effluent, wastewater or sewage with a daily throughput capacity of more than 2000 cubic metres but less than 15000 cubic metres.

Activity 28 Residential, mixed, retail, commercial, industrial or institutional developments where such land was used for agriculture or afforestation on or after 01 April 1998 and where such development: (i) will occur inside an urban area, where the total land to be developed is bigger than 5 hectares; or (ii) will occur outside an urban area, where the total land to be developed is bigger than 1 hectare; excluding where such land has already been developed for residential, mixed, retail, commercial, industrial or institutional purposes.

Activity 30 Any process or activity identified in terms of section 53(1) of the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004).

Listing Notice 2 (GNR984 of 2014) (As amended by GNR325 of 2017) Activity 2(No longer applicable) The development and related operation of facilities or infrastructure for the generation of electricity from a non-renewable resource where the electricity output is 20 megawatts or more.

Activity 4(No longer applicable) The development of facilities or infrastructure, for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of more than 500 cubic metres.

ERPM Ext 2 Mine, East Rand, Gauteng 4 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Activity 7 The development and related operation of facilities or infrastructure for the bulk transportation of dangerous goods- (i) in gas form, outside an industrial complex, using pipelines, exceeding 1 000 metres in length, with a throughput capacity of more than 700 tons per day; (ii) in liquid form, outside an industrial complex, using pipelines, exceeding 1000 metres in length, with a throughput capacity of more than 50 cubic metres per day; or (iii) in solid form, outside an industrial complex, using funiculars or conveyors with a throughput capacity of more than 50 tons day.

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

Activity 17 Any activity including the operation of that activity which requires a mining right as contemplated in section 22 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002), including associated infrastructure, structures and earthworks, directly related to the extraction of a mineral resource, including activities for which an exemption has been issued in terms of section 106 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002).

Activity 21 Any activity including the operation of that activity associated with the primary processing of a mineral resource including winning, reduction, extraction, classifying, concentrating, crushing, screening and washing but excluding the smelting, beneficiation, refining, calcining or gasification of the mineral resource in which case activity 6 in this Notice applies.

Activity 25(No longer applicable) The development and related operation of facilities or infrastructure for the treatment of effluent, wastewater or sewage with a daily throughput capacity of 15000 cubic metres or more.

Listing Notice 3 (GNR985 of 2014) (As amended by GNR324 of 2017) Activity 4(No longer applicable)

ERPM Ext 2 Mine, East Rand, Gauteng 5 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Activity 10(No longer applicable) The development of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 30 but not exceeding 80 cubic metres. In Gauteng – iv. Sites identified as Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs) in the Gauteng Conservation Plan or in bioregional plans; v. Sites identified within threatened ecosystems listed in terms of the National Environmental Management Act: Biodiversity Act (Act No. 10 of 2004); vi. Sensitive areas identified in an environmental management framework adopted by relevant environmental authority; vii. Sites identified as high potential agricultural land in terms of Gauteng Agricultural Potential Atlas;

Activity 12 The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan. In Gauteng - i. Within any critically endangered or endangered ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004; ii. Within critical biodiversity areas identified in bioregional plans; Activity 15 The transformation of land bigger than 1000 square metres in size, to residential, retail, commercial, industrial or institutional use, where, such land was zoned open space, conservation or had an equivalent zoning, on or after 02 August 2010. Listing Notice 2 (GNR984 of 2014) (As amended by GNR325 of 2017) Activity 6 The development of facilities or infrastructure for any process or activity which requires a permit or licence in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent, excluding Project activities that require a WULA - including (i) activities which are identified and included in Listing Notice 1 of 2014; dewatering, abstraction, dust suppression, discharge, 27 ha X (ii) activities which are included in the list of waste management activities published in terms of section 19 of the National pollution control dam and river crossings. Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental Management: Waste Act, 2008 applies; or (iii) the development of facilities or infrastructure for the treatment of effluent, wastewater or sewage where such facilities have a daily throughput capacity of 2000 cubic metres or less.

ERPM Ext 2 Mine, East Rand, Gauteng 6 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 2: ERPM Extension Area 2 site plan

ERPM Ext 2 Mine, East Rand, Gauteng 7 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 3: Map showing the location of the listed activities associated with ERPM Extension Area 2

ERPM Ext 2 Mine, East Rand, Gauteng 8 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 4: Location and extent of activities at the Windmill Shaft SDA

ERPM Ext 2 Mine, East Rand, Gauteng 9 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 5: Infrastructure to be placed at the Windmill Shaft SDA

ERPM Ext 2 Mine, East Rand, Gauteng 10 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 6: Location and extent of activities at the Witpoortje Vent Shaft SDA

ERPM Ext 2 Mine, East Rand, Gauteng 11 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 7: Infrastructure to be placed at the Witpoortje Vent Shaft SDA

ERPM Ext 2 Mine, East Rand, Gauteng 12 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 ii) Description of the activities to be undertaken (Describe the methodology or technology to be employed, including the type of commodity to be mined and for a linear activity, a description of the route of the activity)

ERPM Extension Area 1 (Pty) Ltd (“ERPM Ext 1”) is a subsidiary of East Rand Proprietary Mines Limited (ERPM) (Pty) Ltd (“ERPM”). ERPM Ext 1 holds a prospecting right (GP243PR) which it intends to convert into a Mining Right (submitted with reference number: GP 30/5/1/2/2 10078 MR). Since submission of the EA application, ERPM’s contiguous mining rights - GP151MR and GP150MR – have been sold to ERPM Ext 1. GP243PR is located to the south and adjacent to GP150MR (refer to Figure 8).

Figure 8: ERPM Ext 1’s contiguous mining rights (ERPM and Ext 1) with the current project (Ext 2)

ERPM Ext 1 plans to consolidate the underground resources of GP243PR (referred to as ERPM Extension Area 2 or ERPM Ext 2), with those of GP150MR and GP151MR. The combined underground resources within these three areas justifies the large capital commitment to develop a long term, large scale mining operation. The Far East Vertical (FEV) shaft and FEV vent shaft on GP151MR will be refurbished and used to access underground workings of GP151MR and GP150MR, but this does not form part of the current scope or project.

In order to gain access to the underground operations of the ERPM Ext 2 area, a twin shaft complex, called Windmill Shaft, will be constructed on Portion 5 of Witpoortje 117 IR. Mined ore extracted underground will be crushed and mixed with groundwater, to form a slurry which will be transported to surface via a hydraulic hoist system. This slurry will then be directed using existing pipelines to either the Knights Plant, which is north-west of the Windmill Shaft SDA, or to the Ergo Plant, which is north-east of the SDA. Tailings material from Knights or Ergo Plant will then be piped to the existing ERGO tailings dam.

The estimated Life of Mine (LoM) is 6 years for sinking and establishment, 47 years in production and 5 years for decommissioning and rehabilitation.

The required workforce is currently estimated at 976 permanent employment opportunities (excluding procurement or contractors). The bulk of these will consist of unskilled and semi-skilled labour.

ERPM Ext 2 Mine, East Rand, Gauteng 13 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Windmill Shaft SDA

Surface infrastructure associated with the development of Windmill Shaft (refer to Figure 5), is to be developed within the proposed SDA. This twin shaft complex will consist of two independent rock hoisting shafts, with one servicing the shallower levels (1800 - 2500 metres below collar (mBC)) and another servicing the deeper levels (> 2500 mBC). The shaft system will be fitted with refrigeration and ventilation infrastructure to provide fresh cool air to the underground operations. The surface infrastructure required for development is as follows:

 Shaft A and Shaft B o Shaft A will be 3 025 metres below collar (mBC) (with a 50 m headgear, men and material winder). o Shaft B will be 2 500 mBC (with a 50 m headgear, men and material winder, and vent shaft). o The shafts will be lined for the first 30 – 40 m only and both will be 6 m in diameter. o It is estimated that construction of both shafts will take 6 years. Shaft B (the shallow shaft) will be commissioned first and Shaft A (the deeper shaft) will be commissioned at the end of year 1.  A refrigeration plant, that will allow for the cooling of underground mining operations;  A water treatment plant is potentially required for the treatment of underground water;  Security office, change house, administrative buildings, workshops, salvage yard, stores and general waste storage area;  Powerlines (power supply connection) and substations will connect to existing power sources;  Water supply pipeline for potable and service water supply from the municipal reticulation system;  Stormwater and pollution control infrastructure, including diversion berms, storm water channels and a pollution control dam;  A backup generator and a fuel supply tank within a bunded area;  Explosives handling area;  Waste rock dump (WRD) (Waste rock from sinking of the shafts);  Existing access roads will be used as far as possible, however a small road network around the refrigeration plant and a parking area will be constructed; and  A grout plant (backfill plant) to provide material to support underground mine workings.

Ore and waste rock will be stored below ground. Waste rock will be used as backfill material. It is proposed that any excess water from below ground, not used as service water by ERPM Ext 1, will be transferred to DRD Gold for use in their operations. Topsoil will be used to create a berm upstream of the infrastructure area, and will further be vegetated to screen the residential areas from noise and visual impacts. Operations at the Windmill Shaft will be 24 hours per day.

Witpoortje Shaft SDA

An existing shaft, called the Witpoortje Shaft is to be refurbished and re-equipped as a ventilation shaft with ventilation infrastructure to provide fresh cool air to the ERPM Ext 2 underground operations. Surface infrastructure associated with the development of Witpoortje Vent Shaft (refer to Figure 7), is to be developed within the proposed SDA of approximately 7 Ha. The surface infrastructure required for development is as follows:

 Ventilation shaft (4.8 m in diameter) – existing shaft, to be refurbished.  Surface ventilation fans.  Generator and compressor.  Access road.

Decommissioning and rehabilitation

A period of 5 years has been assumed for decommissioning and rehabilitation. All surface infrastructure will be removed with the exception of the WRD which is to remain on surface and be rehabilitated. The area where the proposed surface infrastructure is to be removed will be rehabilitated to return the area to the pre-mining state (i.e. aligned to the baseline environment) able to support a suitable land use based on the planning objectives for the area.

ERPM Ext 2 Mine, East Rand, Gauteng 14 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 e) Policy and Legislative Context

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED HOW DOES THIS DEVELOPMENT COMPLY WITH AND RESPOND TO THE POLICY AND LEGISLATIVE (A description of the policy and legislative context within which the development is proposed including an identification (i.e. Where in this document has it CONTEXT of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments been explained how the that are applicable to this activity and are to be considered in the assessment process); development complies with and (e.g. In terms of the National Water Act:- Water Use responds to the legislation and Licence has/has not been applied for) policy context) An integrated application in terms The development is taking place as a result of mining The Mineral and Petroleum Resources Development Act (No. 28 of 2002) (MPRDA) is the key legislation of the MPRDA and NEMA is being activities and the DMR is therefore considered the CA. governing mining activities within South Africa. The Department of Mineral Resources (DMR) is the Competent undertaken. While the NEMA An application for a Mining Right was submitted to the Authority (CA) that deals with all mining related applications. process is being followed, the DMR DMR on 21 February 2019, through the SAMRAD is considered the CA. online system (Accepted 12 March 2019). The NEMA process is being followed for the relevant The National Environmental Management Act, No. 107 of 1998 (NEMA) is enabling legislation intended to listed activities. provide a framework for integrating environmental management into all developmental activities to promote co- Application for EA was submitted on 21 February 2019. operative environmental governance with regard to decision making by state organs on matters affecting the According to the EIA Regulations the following are to be environment. submitted in support of the application: The EIA Regulations of GNR982, December 2014 as amended in 2017 serve to regulate the procedure and criteria  Scoping Report (submitted on 24 April 2019 and for submitting, processing and considering decisions for applications for Environmental Authorisation (EA). These accepted 2 July 2019) together with the results of Regulations provide details on the process to be followed for the consultation of stakeholders and IAPs, the consultation with IAPs and State Departments, to Refer to Section 3.d)i) for the identification of the CA, and the various timeframes and application requirements for EA. A further three be submitted to the CA within 44 days of applicable listed activities. Regulations, GNR983, GNR984, and GNR985 (all of 2014 as amended in 2017), provide lists of activities for which submission of the application; and EA, either in the form of a Basic Assessment or Scoping and EIAR / EMPr, is required before the activity can  The EIAR and EMPr (this document) together commence. with the results of consultation with IAPs and Since the enactment of the “One Environmental System” on 8 December 2014, the EA process in terms of the State Departments within 106 days of acceptance NEMA must be followed for any mining activities requiring a right or permit in terms of the MPRDA to fulfil the of the Scoping Report (18 October 2019). requirements of Section 5A(a) of the Act. In instances where EA is required for a mining project, the DMR is This document has been prepared to meet the identified as the CA. requirements of the EIA Regulations (GNR982 of 2014 as amended). Refer to Section 3.e)i)(1)(a) for a The National Environmental Management Air Quality Act, No. 39 of 2004 (NEMAQA) has placed the description of the ambient air responsibility for air quality management on local authorities that will be tasked with baseline characterisation, No listed activities are triggered by the proposed quality within the project area. management and operation of ambient monitoring networks, licensing of listed activities, and emissions reduction project. Therefore, no AEL is required. Refer to Sections 3.e)ii) and Table strategies. GN893 of 2013 provides the list of activities in terms of Section 21(1)(a) for which an Atmospheric Provision for rehabilitation has been made in the 10 for the potential impacts on Emission Licence (AEL) is required in terms of Chapter 5 of the Act. This notice further establishes minimum Closure Plan (Appendix 21). ambient air and potential emission standards for the listed activities. The proposed project does not trigger any listed activities in terms of Air quality monitoring and management measures have mitigation. GN893. been stipulated in the EMPr, to ensure that the Also refer to Appendix 6 for the air The National Dust Control Regulations (GNR827 of 2013) prescribe general measures for the control of dust in all Applicant complies with the legislative requirements. quality study and Appendix 20 for areas, including residential and light commercial areas. the impact assessment. Heritage considerations have formed part of the The National Heritage Resources Act, No. 25 of 1999 (NHRA) serves to protect and manage South African Refer to Section 3.e)i)(1)(a) and for environmental process. In terms of the requirements of heritage and cultural resources, which include places, buildings, structures and equipment of cultural significance, a detailed description of the the NHRA, archaeology and palaeontology specialists historical settlements and townscapes, archaeological and paleontological sites, graves and burial grounds. The Act cultural, heritage and were appointed to conduct an assessment of the area. protects any heritage resources from damage by developments by stipulating in Section 38 that any person palaeontology resources within the In terms of the requirements of the NHRA, archaeology intending on undertaking any form of development which involves the activities listed below must, at the earliest project area. and palaeontology specialists were appointed to

ERPM Ext 2 Mine, East Rand, Gauteng 15 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

stage of initiation, notify the South African Heritage Resources Association (SAHRA) specifically the Provincial conduct an assessment of the area. Three sites of Heritage Resources Authority of Gauteng (PHRAG): cultural heritage importance were identified, however A. the construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or none of these sights are within the proposed barrier exceeding 300 m in length; infrastructure footprints. Mitigation measures for B. the construction of a bridge or similar structure exceeding 50 m in length; potential chance finds are included in the EMPr. C. any development or other activity which will change the character of a site— i. exceeding 5 000 m2 in extent; or ii. involving three or more existing erven or subdivisions thereof; or iii. involving three or more erven or divisions thereof which have been consolidated within the past five years; or iv. the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority; D. the re-zoning of a site exceeding 10 000 m2 in extent; or E. Any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority. Section 38(8) of the Act states that if heritage considerations are taken into account as part of an application process undertaken in terms of NEMA and the EIA process, there is no need to undertake a separate application in terms of the NHRA. Heritage considerations will form part of this environmental process. The National Water Act, No. 36 of 1998 (NWA) regulates all matters relating to inland water resources. It thus Refer to Section 3.e)i)(1)(a) for a operates as a management instrument with the lead authority being the Department of Water and Sanitation (DWS). detailed description of the This Act provides mechanisms for the prevention of the pollution of water resources to support the management of groundwater and surface water water as a renewable resource. Section 21 of the Act lists water uses for which authorisation is required from the resources within the project area. A Pre-Application Water Use Enquiry has been DWS. Refer to Sections 3.e)ii) and Table submitted to DWS via the e-WULAAS online system. Regulation GN704 of 1999 provides regulations for the use of water for mining and related activities. These 10 for the potential impacts on regulations describe how mining activities should be managed to protect water resources. The Act thus plays a water resources and potential crucial role in the mining process as many mining-related activities use water are listed in Section 21, thereby mitigation. requiring approval from DWS. The National Environmental Management Waste Act, No. 59 of 2008 (NEMWA) serves to reform the laws regulating waste management in order to protect public and environmental health by providing measures for the Waste management relevant to prevention of pollution and ecological degradation and to provide defining requirements for the licensing and control A commitment to abide by the norms and standards is this project has been addressed in of waste management activities. GN921 of 2013 provides definitions for activities which require a Waste included in the EMPr, should waste be stored in excess the EMPr (Section f), Part B of this Management Licence (WML) and identifies the relevant EAs which are further required for said activities. of threshold values and for longer than 90 days. document). The storage of waste above the specific thresholds (in excess of 100 m3 of general waste or 80 m3 of hazardous

waste) for a period of more than 90 days triggers a Category C activity which requires compliance with the National Norms and Standards for the Storage of Waste (GN926 of 2013). The Hazardous Substances Act, No. 15 of 1973 aims to control substances that may cause injury, ill-health, or death through their toxic, corrosive, irritant, strongly sensitising or flammable nature, or by the generation of A commitment to abide by the Act The Applicant will ensure that any hazardous materials pressure. The Act provides for the division of such substances or products into groups in relation to the degree of has been included in the EMPr on site are handled in a manner in line with that danger as well as the prohibition and control of the importation, manufacture, sale, use, operation, application, (Section f), Part B of this described in the Act. modification, disposal or dumping of such substances and products. Hazardous materials such as explosives and document). hydrocarbons will be handled on site.

ERPM Ext 2 Mine, East Rand, Gauteng 16 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

The proposed Witpoortje Vent Shaft SDA is located within sections of Critical Biodiversity Area (CBA) and Ecological Support Area (ESA), as per the Gauteng Conservation Plan (C-Plan) (Refer to Figure 3). The Proposed Windmill Shaft SDA is not located within any CBA or ESA. Some sections of the Witpoortje Vent Shaft SDA fall The purpose of the National Environmental Management: Biodiversity Act, No. 10 of 2004 (NEMBA) is to within the RE of the CR Kliprivier Highveld Grassland provide for the management and conservation of South Africa’s biodiversity within the framework of the NEMA. This Refer to the terrestrial ecology Ecosystem which is considered a threatened ecosystem includes, among others, the protection of species and ecosystems. baseline in Section 3.e)i)(1)(a); and in terms of Section 52 of NEMBA. Section 52 of the Act provides for listing of threatened or protected ecosystems, in one of four categories: Critically refer to Sections 3.e)ii) and Table Conservation areas near ERPM Ext 2 Mine include: Endangered (CR), Endangered (EN), Vulnerable (VU) or Protected. The main purpose of listing threatened 10 for the potential impacts on  Dalpark Bird Sanctuary (not a proclaimed ecosystems is to reduce the rate of ecosystem and species extinction and includes the prevention of further biodiversity. protected area but considered a local green degradation and loss of structure, function and composition of threatened ecosystems. Threatened terrestrial Biodiversity management has been corridor) - approximately 5.3 km to the north east ecosystems have been delineated based on the South African Vegetation Map, national forest types and priority addressed in the EMPr (Section f))  Rondebult Bird Sanctuary - approximately 7 km to areas identified in a provincial systematic biodiversity plan. in Part B of this document). the west Chapter 4, Part 2 of the Act provides for listing of species as threatened or protected. If a species is listed as Also refer to Appendix 16 terrestrial  Korsman Bird Sanctuary - approximately 12 km to threatened, it should be further classified as CR, EN or VU (GNR151 of 2007). The Act also defines restricted ecology study the north activities in relation to a specimen of a listed threatened or protected species (GNR152 of 2007).  Suikerbosrand Provincial Nature Reserve - approximately 13 km to the south  Blesbokspruit Ramsar site and the Marievale Bird Sanctuary Provincial Nature Reserve - approximately 15 km to the east/ south-east  These are all outside of the mining area and no other protected or conservation areas are located within 10 km of the study area. The Mine Health and Safety Act, No. 29 of 1996 and Regulations provide for protection of the health and safety of staff and other persons at mines and, for that purpose to promote a culture of health and safety; to provide for the enforcement of health and safety measures; to provide for appropriate systems of employee, employer and State participation in health and safety matters; to establish representative tripartite institutions to review legislation, promote health and enhance properly targeted research; to provide for effective monitoring systems and inspections, The Applicant will ensure that operations on site are in

investigations and inquiries to improve health and safety; to promote training and human resources development; to line with the requirements of the Act and Regulations. regulate employers' and staff' duties to identify hazards and eliminate, control and minimise the risk to health and safety; to entrench the right to refuse to work in dangerous conditions; and to give effect to the public international law obligations relating to mining health and safety. The Applicant will ensure that operations on site are in line with the requirements of the Act and Regulations. There are no significant radiation The Applicant will ensure that operations on site are in impacts associated with the ERPM line with the requirements of the Act and Regulations. The National Nuclear Regulator Act, No. 47 of 1999 (NNRA) applies to the siting, design, construction, operation, Ext 2 Mine as there will be no mine According to the NNR, records shows that ERPM (Pty) decontamination, decommissioning and closure of any nuclear installation; vessels propelled by nuclear power or residue stockpiles and only waste Ltd is the holder of nuclear authorisation, COR-53. having radioactive material on board which is capable of causing nuclear damage; and any action which is capable rock from sinking of the shafts will ERPM Extension Area 1 (Pty) Ltd does not have a of causing nuclear damage. The NNRA is regulated by the National Nuclear Regulator (NNR) and Certificates of be placed on site. Ore and all other nuclear authorisation with the NNR and in term of the Registration are required for radiation sources above a certain threshold. The NNRA also makes provision for safety waste rock will be stored below NNR Act they are not permitted to conduct or let wok to standards and regulatory practices by means of the regulations (GNR388 of 2006). ground. Mined ore extracted be executed in all areas that are sources of radiation underground will be crushed and without nuclear authorisation. NNR Act Section 25 also mixed with groundwater, to form a

ERPM Ext 2 Mine, East Rand, Gauteng 17 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

slurry which will be transported to prohibit the transfer of nuclear authorisation to another the surface via a hydraulic hoist third party. system. This slurry will then be directed using existing pipelines to ERPM Ext 1 to apply for the necessary nuclear either the Knights Plant or to the authorisation prior to conducting work in affected areas. Ergo Plant. Waste rock will be used as backfill material. The City of Ekurhuleni (CoE) Integrated Development Plan (IDP) (2013/14 - 2015/16) provides the regional socio-economic context of the project area. The IDP states that the CoE has a total surface area of 1 975 km² that accommodates a population of approximately 3 million. Migration into the area is a key challenge, which is evident in the number of informal settlements and by the informal trading activity. The CoE is considered an industrial hub. Economically active people constitute 41.5 % of the population. The area contributes approximately 6.1 % to national production. Over the period 1996 to 2011, the economy grew by an estimated average of 3.2 % per annum. Refer to the social baseline in The main contributing sectors have been identified as retail, entertainment, aviation, property development, mining Section 3.e)i)(1)(a). This has also and manufacturing (food and beverage, packaging, chemicals, metal, services, and other manufacturing services). been taken into consideration in

The CoE has a 100 year history of mining which has resulted in environmental deficits including acid mine drainage, the determining of the need and undermined degraded areas, and mine dumps containing radio-active materials. Approximately 41 % of the CoE has desirability of the project, refer to been identified as being of importance for protection for agriculture; 22 % of this is of high importance, while 19 % is Section 3.f). of moderate to high importance. The natural environment of the CoE can be broken down as follows: 19 % CBAs, 18 % Ecological Areas, 1 % Protected Areas, 16 Threatened Plant Species, 14 Threatened Animal Species, and 10 % Threatened Ecosystems. The industrial and urban development that has shaped the CoE has resulted in high levels of pollution impacting soil, water and air resources. It has also resulted in degradation of ecosystems and the subsequent loss of biodiversity. According to the CoE RSDF, The Witpoortje Vent Shaft SDA falls over an area classified as open space and the The CoE Regional Spatial Development Framework (RSDF) (2015) provides the framework for making resource- Windmill Shaft SDA falls over an area classified as effective decisions regarding planning. The project area falls largely within Region E as per the CoE RSDF. urban development. Witpoortje vent shaft falls within Region D. Refer to Figure 6 and Figure 7. Areas classified as open space have functioning Region E is made up of Nigel, Kwatsaduza and Springs South. The most prominent land uses in Region E include: processes that should be maintained. The objective is residential uses (low, medium and high income housing); mining land, including active and closed mines and related to ensure continued functioning of the area (ecological / mining legacy issues (such as slime dams, mine heaps, etc.); conservation areas (Marievale Conservation Area); agricultural / open space) and that the area is not the Dunnotar Airport and military base; industrial development concentrated around Nigel and to the south of compromised. Developments within these areas should Springs; and vacant/undeveloped and agricultural land. Region E contains approximately 18100 ha of open space, Refer to the social baseline in be limited to existing footprints, if present, and should which is the greatest quantity of available open space within the EMM and translates to 46% of the surface area Section 3.e)i)(1)(a). This has also avoid encroaching on natural or agricultural landscapes. within the region. Development in Region E is highly limited, with an estimated 71% of the region containing been taken into consideration in Development should be undertaken in such a way that environmental constraints. The predominant environmental constraints within this region include high agricultural the determining of the need and ecological and open space networks remain intact, so potential land, protected areas and areas of ecological importance. Brakpan, in particular, is highly constrained by desirability of the project, refer that fragmentation of the system, resulting in the ecological important areas. Section 3.f). isolation of ecologically important areas and open The objective of the RSDF is to ensure continued functioning of the area (ecological/ agricultural/open space) and to space, does not occur. The relevant environmental ensure that the area is not compromised. Developments within these areas should be limited to existing assessments should be undertaken for any proposed development / disturbed footprints, and should avoid encroaching on natural or agricultural landscapes. development within these areas. Development should be undertaken in such a way that ecological and open space networks remain intact, and that Areas classified as urban development support the fragmentation of the system, resulting in the isolation of ecologically important areas and open space, does not primary economic and employment areas and will occur. primarily consist of residential development, all social The relevant national, provincial and local legislative requirements will be adhered to for the proposed development. facilities and services and land uses as may be required to achieve sustainable urban life.

ERPM Ext 2 Mine, East Rand, Gauteng 18 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

According to the GPEMF, Zone 3 is defined as a “High control (outside Zone 1)” zone and Zone 4 is defined as a “Normal control” zone. Zone 3 is also considered sensitive to development activities and in several cases may have specific values that need to be protected. Refer to the social baseline in Conservation and related tourism and recreation Section 3.e)i)(1)(a). This has also activities should dominate development in this zone. The Gauteng Province Environmental Management Framework (GPEMF) (2015) provides a framework to guide been taken into consideration in Zone 4 is dominated by agricultural uses outside of decision-making regarding land-use at all levels of planning. According to the GPEMF, the SDA falls within Zones 3 the determining of the need and urban development, thus the intention is to promote and 4. Refer to Figure 11. desirability of the project, refer agriculture and rural development that supports Section 3.f). agriculture in these areas. Mining is only compatible with Zone 5, conditionally compatible with the developments or land uses in Zones 4 and 5 and undesirable for the developments and land uses in Zones 1, 2 and 3 and no new mining development should be allowed in this zone.

ERPM Ext 2 Mine, East Rand, Gauteng 19 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 9: Witpoortje Vent Shaft SDA relative to the CoE Region D RSDF

ERPM Ext 2 Mine, East Rand, Gauteng 20 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 10: Windmill Shaft SDA relative to the CoE Region E RSDF

ERPM Ext 2 Mine, East Rand, Gauteng 21 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 11: Mining Right area and SDAs relative to the GPEMF zoning

ERPM Ext 2 Mine, East Rand, Gauteng 22 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 f) Need and desirability of the proposed activities (Motivate the need and desirability of the proposed development including the need and desirability of the activity in the context of the preferred location)

ERPM Ext 2 Mine is contiguous with the ERPM lease area and geologically is a natural extension to the south east. ERPM Ext 2 Mine is thus considered an integral component or section of the area of interest and in this mining. Due to the high capital costs of accessing deep ore bodies, ERPM Ext 2 Mine is not explorable as a standalone project. ERPM Ext 1’s intention is therefore to convert the ERPM Ext 2 prospecting right into a mining right as the area covered by this right has proven to hold a very large gold ore resource that is shallower than the ERPM Ext 1 resources. Converting this prospecting right into a mining right will result in the other two issued mining rights becoming feasible for economic and profitable extraction by creating one large mine.

The proposed Windmill Shaft SDA is relatively free from urban development and consists mainly of open land that was previously used for agriculture and is currently used for livestock grazing. Existing surface infrastructure within the surrounding area includes power lines and substations, railway lines, main roads and freeways, Rooikraal landfill site, chicken rearing and laying houses and mine residue deposits (tailings and calcine dams). The road and electrical transmission infrastructure surrounding the proposed Windmill Shaft SDA is well established, allowing the transport of people, and supply of electrical power to the site without considerable capital outlay and further disturbance to the environment. The existing slurry pipeline is located close to the proposed site. Utilising this pipeline to deliver mined ore to the processing plant removes the need for hauling and additional mine residue deposits and therefore reduces the associated environmental and social impacts and damages to the existing road infrastructure. The Windmill Shaft SDA does not support unique biodiversity or natural features and avoids watercourses and wetlands. The existing infrastructure in the surrounding area as well as the lack of unique biodiversity within the SDA therefore makes this area suitable for the establishment of a new underground mine, with the limited surface infrastructure. The proposed Windmill Shaft SDA is located on land the RSDF earmarks for urban development and the GPEMF for agriculture and rural development that supports agriculture.

An existing shaft, which will be equipped and developed as a ventilation shaft to form part of the greater ERPM Ext 2 underground mining operations, is located in the Witpoortje Vent Shaft SDA. This shaft was sealed with a concrete slab which has since been damaged by informal miners. The shaft is therefore currently a safety hazard and the reequipping of the shaft will increase access control and safety to surrounding people and animals.

Mining around the proposed sites has been undertaken for a considerable number of years, evident from the tailings waste facilities and the decommissioned shafts. It is expected that the communities in the vicinity of the proposed project would be able to supply skills and labour for the development and operation of the proposed mine. The proposed mine would be able to contribute to the upliftment of the community through the provision of employment. ERPM Ext 1 is committed to contributing towards the socio-economic activities of the immediate community and the region. The required workforce is currently estimated at 976 permanent employment opportunities (excluding procurement or contractors). The bulk of these will consist of unskilled and semi-skilled labour. Once the mine becomes operational, the employment of a local workforce will translate into more individuals being impacted through direct and indirect income. The project will also contribute to the economy through the foreign investment, paying of taxes and the export of gold. g) Motivation for the preferred development footprint within the approved site including a full description of the process followed to reach the proposed development footprint within the approved site (NB!! – This section is about the determination of the specific site layout and the location of infrastructure and activities on site, having taken into consideration the issues raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout) i) Details of the development footprint alternatives considered (With reference to the site plan and the location of the individual activities on site, provide details of the alternatives considered with respect to:

ERPM Ext 2 Mine, East Rand, Gauteng 23 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

a) the property on which or location where it is proposed to undertake the activity No alternative sites were assessed. The location of the Windmill Shaft SDA was selected based on a number of factors, including the fact that the mineral resources beneath this site are considered to be of a low grade and locating the vertical shaft complex here would ensure that the shaft pillar does not sterilise any mineral resource. Similarly, no sites were identified to considerably mitigate impacts to the social or biophysical environment. The Witpoortje Vent Shaft is an existing shaft to be refurbished.

b) the type of activity to be undertaken The mining activity comprises of underground mining operations (at depths of >1800 mBC) and associated underground activities, including blasting to extract the ore. Ore and waste rock will be stored below ground. Waste rock will be used as backfill material. Mined ore extracted underground will be crushed and mixed with groundwater, to form a slurry which will be transported to the surface via a hydraulic hoist system. This slurry will then be directed using existing pipelines to either the Knights Plant, which is north-west of the SDA, or to the Ergo Plant, which is north-east of the SDA.

Surface activities include a new shaft complex to be constructed (Windmill Shaft SDA) to gain access to the ERPM Ext 2 Mine underground resources and an existing shaft (Witpoortje Vent Shaft SDA) to be re-equipped as a ventilation shaft with ventilation infrastructure to provide fresh cool air to the underground operations. Supporting surface infrastructure associated with the SDAs will also be developed on surface.

c) the design or layout of the activity The design and layout is based largely on the surrounding existing infrastructure and the location of the underground mineral resources. The layout of the surface infrastructure has already been amended to avoid graves near the site, the nearby wetland habitats and the proposed road reserves as far as feasible. The chosen layout is the most suitable in terms of fitting onto the selected property. Minor changes could be made to the layout if required, based on comments received during the PPP.

d) the technology to be used in the activity / operational aspects of the activity No operational alternatives were considered. The operational method chosen of combining the two mining rights and with the prospecting right and using and developing the necessary infrastructure is the only option to create a financially feasible project. The proposed operation involves the use of existing infrastructure as far as possible in order to limit capital expenditure. This also limits the environmental and social impacts of the project and very little new development will occur as a result of this project. Hydraulic hoisting of slurry prevents surface development and existing slurry pipelines will be used for the transport of the slurry materials.

e) the option of not implementing the activity) If the activities associated with ERPM Ext 2 are not approved, then the potential mining activities associated with that project as well as the two adjacent mining right areas will no longer be financially viable. The associated economic benefits of employment will not be realised. The potential negative impacts of mining will however also not materialise, and the land could potentially be used for alternative purposes, such as agriculture. ii) Details of the Public Participation Process Followed (Describe the process undertaken to consult interested and affected parties including public meetings and one on one consultation. NB the affected parties must be specifically consulted regardless of whether or not they attended public meetings. Information to be provided to affected parties must include sufficient detail of the intended operation to enable them to assess what impact the activities will have on them or on the use of their land)

Scoping phase

The Scoping phase public commenting period ran from 8 March to 8 April 2019.

ERPM Ext 2 Mine, East Rand, Gauteng 24 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Landowner notification

The landowners of the properties where the surface infrastructure is to be located (i.e. the portions and farms as listed in the table in Section 2) have been identified and notified of the proposed project activities via registered mail or email. A meeting was held with the representative from Eggbert Eggs. Refer to Appendix 4.1.

Contact details for one of the landowners (Ms Suzanne Weitze) could not be obtained. Ongoing efforts will be made to contact her.

IAP registration and database

An IAP register was opened and representatives from all of the relevant State Departments, as well as any IAPs requesting to register, were added to the database. The IAP database was updated throughout the PPP.

Media notice

A media notice was published in two local newspapers (Brakpan Herald and the African Reporter) on 8 March 2019 in English. The media notice provides a brief project description, legislative requirements, and the registration process to be followed for Interested and Affected Parties (IAPs), details on the availability of the Scoping Report, and contact details for more information. Refer to Appendix 4.3.

Site notices

Site notices were posted on site and at conspicuous locations within the surrounding communities on 8 March 2019, providing a brief project description, legislative requirements, the process to be followed to register as an IAP, details on the availability of the Scoping Report, and contact details for more information. Refer to Appendix 4.4.

Scoping Phase Background Information Document (BID)

The BID provides a brief description of the project and potential impacts, the legislated environmental process, availability of the Scoping Report, the process to follow to register as an IAP, and contact details for queries. The BID was made available to State Departments and IAPs via email on 8 March 2019, and to surrounding residents by hand on 8 March 2019. The BID was made available to IAPs requesting further information. Refer to Appendix 4.5.

Scoping Report

The Scoping Report was made available for comment to State Departments (including the CA) via email or hard copy as requested and placed within the public domain on the Prime Resources website (www.resources.co.za), and at the Vosloorus, Tsakane, Kwa-Thema, Geluksdal and Brakpan Public Libraries for a commenting period of 30 calendar days (8 March to 8 April 2019). Refer to Appendix 4.6 for proof of the distribution of the Scoping Report and Appendix 4.7 for copies of the comments received and responses. The Final Scoping Report was submitted to the DMR on 24 April 2019 and accepted on 2 July 2019. Refer to Appendix 4.9 for proof of submission and acceptance of the Scoping Report.

Meetings

A meeting was held with members of the Withok Community on 03 April 2019 at 18h15 at Hardy Plants in Brakpan. The meeting notes are attached as Appendix 4.8.

EIA Phase – Feedback Public Participation Process (PPP)

The EIA phase public commenting period ran from 9 September to 10 October 2019.

EIA Phase Background Information Document (BID)

The BID was updated to summarise the questions and comments raised during the Scoping Phase, and to provide feedback on potential impacts and recommended mitigation measures, as per the EIAR / EMPr. The BID was made available to State Departments and IAPs via email on 9 September 2019, and was provided to any IAPs requesting further information. Refer to Appendix 4.10.

ERPM Ext 2 Mine, East Rand, Gauteng 25 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Availability of draft EIAR and EMPr

An EIAR and Environmental Management Programme (EMPr) (this document) was compiled and made available for review and comment at the Vosloorus, Tsakane, Kwa-Thema, Geluksdal and Brakpan Public Libraries, and on the Prime Resources website. It was also made available to State Departments (including the CA) for a period of 30 calendar days (9 September to 10 October 2019). An email and/or SMS were sent out to all registered IAPs on 9 September 2019 notifying them of the localities where the EIAR and EMPr could be viewed, and the commenting period. Refer to Appendix 4.11 for proof of the distribution of the EIAR and EMPr and Appendix 4.12 for copies of the comments received and responses.

Meetings

A feedback meeting was held with members of the Withok Community on 04 September 2019 at 18h15 at Hardy Plants in Brakpan. The meeting notes are attached as Appendix 4.13.

A meeting was held with members of the CoE on 20 September 2019 at 09h00 in Benoni. The meeting notes are attached as Appendix 4.13.

A meeting was held with members of the Geluksdal Community on 30 September 2019 at 09h00 in Geluksdal. The meeting notes are attached as Appendix 4.13.

Comments and Response Report (CRR)

A CRR was compiled (refer to the table below) incorporating all comments received and responses thereto (refer to Appendix 4.7 and 4.12) during the 30 day Scoping Phase public consultation period and the 30 day EIAR and EMPr public consultation period. Refer to Summary of issues raised by IAPs in the table below.

ERPM Ext 2 Mine, East Rand, Gauteng 26 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 iii) Summary of issues raised by IAPs (Complete the table summarising comments and issues raised, and reaction to those responses)

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED Landowner/s and lawful occupier/s of the land where the activity will take place Eggbert Eggs (Pty) Scoping Meeting held -  R.Briel Group Credit Manager of the Kuipers Group said that Land use agreements Ltd Directors: Phase 15 May 2019 the conditions in the rearing houses are therefore vital in must be in place before Charles Le Maitre Notification ensuring good egg production rates and that rearing the commencing with any of and Jurjen via email- 07 chickens was a fundamental part of their business model. the proposed activities Coenraad Kuipers March 2019 Should anything negatively affect this early process, the entire on site. production line would be at risk. EIA Phase  R.Briel said that their operations rely heavily on groundwater.  LJ (Louse Jones) from Prime Resources (PR)) This has been included Notification G.Rossouw the General Manager of Eggbert Eggs said that said that the proposed surface infrastructure as a condition that must via email- 09 the groundwater pumped at the site near the Rooikraal included a Twin shaft; refrigeration plant; be included in the September Tailings is yellow in colour and has an odour and that all of change house, administrative buildings, authorisation and is 2019 their sites have water purification systems in place as the workshops, salvage yard, and stores; water addressed in Table 20. groundwater is given to the chickens. treatment plant; powerlines connected to  R.Briel asked what infrastructure is proposed on Eggbert Eggs existing power sources and water supply Groundwater, dust, portion of land (Portion 5 of the Farm Witpoortje 117 IR). pipeline; stormwater and pollution control blasting and noise is infrastructure, backup generator and a fuel addressed in the EIA. supply tank; explosives handling area; small Refer to the baseline road network and a grout plant (backfill plant). section and to Table 10  R.Briel stated that he had major concerns over the various  LJ said that all of these concerns are noted and and Appendix 20 for the negative impacts that the mining operations would pose on that specialists will be assessing these impacts. detailed impact their business at large. GR reiterated that their business was LJ added that the groundwater specialist would assessment with built around the supply of a biological product. assess the potential impacts on both mitigation measures. Of particular concern was groundwater quality, dust, blasting groundwater quality and availability. and noise. GR explained that chickens are easily frightened/ scared and blasting or loud noises can cause sudden death of the birds. RB said that should the groundwater quality worsen, their productivity would be greatly affected. Dust was an additional concern raised, since the chicken coops must be maintained at very specific conditions and the chicken houses do not have dust filters.  R.Briel asked what mitigation measures the mine would  LJ said that the EIA would contain all of the implement to address these impacts. specialist findings, recommendations and mitigation measures.  G.Rossouw asked if PR were aware of a proposed highway in  LJ said that she was aware of this and had the area? seen the provincial road reserve on the Ekurhuleni GIS website. Mrs Susanne Contact details unavailable Weitze Mineral rights holders DMR acceptance letter received on 16 April required consultation with AngloGold Ashanti and Bunengi Holdings AngloGold Ashanti Letter hand Email received - A.Minnaar (Senior Legal Administrator from AngloGold Ashanti) - No response necessary. (mineral rights delivered on 06 May 2019 Our telecon on 3 May 2019 refers. As confirmed, please be advised 23 April 2019 that AngloGold Ashanti Ltd sold its operations in the

ERPM Ext 2 Mine, East Rand, Gauteng 27 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

The appropriate contact person at DRD/Ergo Mining, whom would be able to perhaps advise you whether a third party has applied for additional Mining Right/s is: Reneiloe Masemene Group Legal Counsel and Company Secretary

With all due respect, the DMR’s records is NOT always up to date and I do not understand why they have mentioned that ERPM should consult with AngloGold Ashanti Ltd if we do not hold or have not applied for any Rights.

I trust that the information will assist you. Bunengi Holdings Letter hand No response received (mineral rights delivered on within the same 23 April 2019 area) Landowners or lawful occupiers on adjacent properties Ekurhuleni Scoping No comments received Metropolitan Phase Municipality (EMM) Notification Afrisam (SA) Pty via email- 07 Email received - N. Govender (Environmental Specialist from Afrisam (South Africa) (PR responded via email on 9 April 2019) Water quality and Ltd March 2019 05 April 2019 (Pty) Ltd) - blasting is addressed in Thank you for your email. the EIA. Refer to the EIA Phase Good day baseline section and to Notification I can confirm that the people mentioned in your Table 10 for the risk via email- 09 Kindly register the following people as IAPs for this project - email below have been added to the Interested and assessment and September Glenn Johnson - contact details removed for confidentiality Affected Party (IAP) database for the Proposed mitigation measures. 2019 Zielas du Preez - contact details removed for confidentiality ERPM Ext 2 Mine. Louis Sterley - contact details removed for confidentiality Your concerns are noted and will be incorporated Neighbouring mines Afrisam Company Secretary - contact details removed for into the final Scoping Report to be submitted to the need to be made aware confidentiality DMR. of the underground mine Melissa Reddy - contact details removed for confidentiality plan once it has been Nivashni Govender - contact details removed for confidentiality In response to your comments: determined, this has Comments on the ERPM project are as follows -  To clarify ERPM Extension Area 2 (ERPM Ext been included in Table 1. It appears that the ERPM Ext 2 Mining Right Area is adjacent 2) is the name of the proposed mine and 20. to the Afrisam Rooikraal Quarry to the South. It is unclear as ERPM Extension Area 1 (Pty) Ltd is the name to whether this MRA is what is being converted from a of the applicant. prospecting to a mining right, or whether it is already an  The ERPM Ext 2 Mining Right Area is what is authorized mining right area. The confusion comes about due being converted from a prospecting to a mining

ERPM Ext 2 Mine, East Rand, Gauteng 28 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED to the various names being used e.g. ERPM Ext 1, ERPM Ext right and the applicant (ERPM Extension Area 2, as well as various prospecting and mining right areas. It 1 (Pty) Ltd) also holds the mining rights for the would be very helpful for IAPs to have a map indicating where adjacent areas, namely GP151MR (called the these prospecting and mining right areas are on a map, as well ERPM Original Mining Right) and GP150MR as what is existing and what is currently being converted or (called ERPM Extension Area 1). See map applied for. This cannot be deduced from the map on Page 8 below. of the BID, or from the maps in the scoping report (Figures 2, 3 4 etc.). 2. A water treatment plant has been identified as possibly being constructed for this project. It is not clear as to where this infrastructure will be built, and where potential discharge points will be. The document mentions that excess water from below ground will be transferred to DRD gold for their use, however no mention is made for water being released into the natural environment from the treatment plant itself. Afrisam Rooikraal quarry is situated directly next to the Rietspruit, and is authorized to draw water from the Rietspruit from time to time. Changes to the water quality of the Rietspruit will have an effect on our water usage patterns should water not be found suitable from a quality perspective. If water will be discharged into the Rietspruit, clear water quality discharge targets should be adopted and met. 3. Afrisam Rooikraal is an opencast dolerite and dolomite quarry. From the maps in the BID, it can be seen that the MRA is situated directly next to the Afrisam quarry on the Southern end. Afrisam is concerned about the effect of underground  The potential impacts that you list will be blasting on our operation, and the possibility of fall of ground in assessed in the EIA phase, and as a registered our pit. It is unclear as to how close underground mining is IAP you will be notified of the availability of this progressing towards the Afrisam quarry, and it would be good information. if the underground mine plan can be shared with us, in order  The underground mine plan is not yet available for Afrisam to determine the level of risk involved with having however when the plan has been confirmed it an underground mine situated right next to our mine. If a will be made available to you. concern does exist, which can only be determined once Afrisam is aware of ERPMs mine plan, then Afrisam should be Please do not hesitate to contact us should you notified of any blasting taking place at ERPM at all times. have any additional questions or queries. 4. Afrisam does blast for aggregate at the Rooikraal facility, and likewise with the point above, we are unaware of whether our blasting activities may have an impact on ERPMs underground activities. Afrisam and ERPM need to come to an understanding of when blasting notifications need to go out to each other etc. San Michele Home No comments received DRD Gold (Ergo Mining Pty Ltd)

ERPM Ext 2 Mine, East Rand, Gauteng 29 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

We need to register the following as IAP’s: The scoping phase public participation period will DP Westley - One G Services (Pty) Ltd - Development and Project run from 8 March 2019 to 8 April 2019. Managers on Helderwyk development. DG Cheesman – One G Services (Pty) Ltd - Development and Kindly furnish all comments or queries to Prime Project Managers on Helderwyk development. Resources ([email protected]) by 8 April P van der Meer – Purple Moss 19 (Pty) Ltd 2019. C Marshall – Purple Moss 19 (Pty) Ltd – Helderwyk land owner/developer There will another round of public participation during the EIA phase of the project (in June / July Some of the above will be alternates – but best all are registered 2019) and any comments received after 8 April 2019 under Helderwyk for now. will be incorporated into the EIAR.

Please acknowledge receipt and confirm registration as IAP’s.

Email received - Sorry forgot the email details earlier. (PR responded via email on 5 April 2019) 05 April 2019 Herewith: DP Westley - One G Services (Pty) Ltd - Development and Project Thank you I will update the database accordingly. Managers on Helderwyk development. Email: contact details removed for confidentiality Please do not hesitate to contact us should you DG Cheesman – One G Services (Pty) Ltd - Development and have any questions or queries. Project Managers on Helderwyk development. Email: contact details removed for confidentiality P van der Meer – Purple Moss 19 (Pty) Ltd. Email: contact details removed for confidentiality C Marshall – Purple Moss 19 (Pty) Ltd – Helderwyk land owner/developer. Email: contact details removed for confidentiality Dr Gwen Theron Email received - Dr Gwen Theron - (PR responded via email on 11 October 2019) (representative for 10 October We would like to reply on behalf of the land owners, Purple Moss Purple Moss 19 Pty 2019 19 (Pty) Ltd., (Purple Moss) of Portion 62 of the Farm Witpoortje We hereby acknowledge receipt of your email. Ltd) 117 IR located within the areas of your application. Your objection and the concerns raised are noted and will be addressed in the final EIA to be submitted to the DMR.

(PR responded via email on 17 October 2019)

ERPM Ext 2 Mine, East Rand, Gauteng 30 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

We are aware of the proposed Helderwyk development on portion 62 as per your map, and have referred to this within Appendix 14 (Socio- Economic Impact Assessment) of the EIA which was made available for public comment.

Specific reference is made to your comments below:

The NEMA regulations require that the information Proof of submission and for the current process is made available and does acceptance of the not require that all previous reports are continuously Scoping Report by the made available. However, the proof of submission DMR is included as and acceptance of the Scoping Report by the DMR Appendix 4.9 in the EIA. was included as Appendix 4.9 in the EIA which was made available for public comment. The Scoping

Location of Portion 62 of the Farm Witpoortje 117 IR Report (including the public participation conducted) can be made available to you for review. Please A. Objection advise as to whether you would like to receive a 1. Purple Moss 19 (Pty) Ltd. is objecting to the application with copy of this report. reasons and observations being amongst others: a) Lack of information provided on the website for review and Should you wish to obtain a copy of the prospecting comment. licence, we will request such via our client. b) Lack of the required studies that will specifically safeguard Application forms are generally not made available Purple Moss during the establishment of the mine activities for public review as the information contained and during the operations. therein is incorporated into the Scoping Report and c) General comments on the specialist studies that area subsequent documents. Should there be specific applicable to the Purple Moss land is also provided. information within the application that you believe is missing from the Scoping and EIA Reports, please B. Lack of information provided on the website for review and advise and we will endeavour to make this comment information available to you. 1. The website contains the following information a) Draft Environmental Impact Assessment Report Unfortunately we are unable to make the documents b) Environmental Management Programme available for a further 30 days as the regulated c) Air quality Report timeframes have come to an end. The final EIA d) Blasting Report Report must be submitted to the DMR by 18 October e) Soil and Land use Report 2019. Your comments will however be included in f) Heritage Report that report, including your objections and reasoning. g) Palaeontological Report h) Groundwater Report In general the baseline air quality would apply to the i) Hydrology Report greater area, including portion 62 which is within 1.6 j) Noise Report km of the proposed Windmill Shaft development site. k) Socio Economic Report This baseline data could therefore be considered to l) Visual Report apply to portion 62 as well, unless there are specific m) Terrestrial Ecology Report existing sources of additional emissions closer to n) Aquatic Ecology and Wetland Report portion 62 that would be having a negative impact

ERPM Ext 2 Mine, East Rand, Gauteng 31 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED o) Hydropedological Report on the local air quality. The air quality specialist has p) Traffic Report recommended that quarterly dust fallout monitoring q) Impact Assessment must commence at least 6 months prior to r) Draft Final Rehabilitation, Decommissioning and Closure Plan construction and for the first year of construction, s) Draft Environmental Risk Assessment Report which will provide an updated baseline study t) Basic Information Document immediately prior to mining activities. Further monitoring requirements are stipulated to continue 2. The following information is not available: into the operational phases. a) Application forms b) Scoping report The blasting specialist noted specifically that the c) Approval of scoping report by the mandated authorities effects of blasting at depth during the operational d) Public participation report of the scoping report phase (mining at depths of >1800 mBC) will be too e) Prospecting license low to be assessed. It is expected that the extent of the potential damaging impacts of blasting will be 3. Reason for request: local and occur during the construction phase only a) This set of information is required to assess the applicable and that the blasting impacts during the operational response in the current submission. Although it may have phase are considered highly unlikely to occur and been available in the original submission it is important to that the consequence of these impacts occurring is keep the information on the website, to allow the participants slight. Commentary will be required prior to mining to reference these documents as the current application as to the potential for subsidence to occur with material is reviewed. specialist input from a rock engineer. The blasting/ The blasting/ vibration b) Without the information it is not possible to complete a vibration and subsidence management measures and subsidence thorough review and correlate the current submission against has therefore been updated to include a subsidence management measures the scoping report submission. The approval and feedback assessment which must be conducted prior to have been included in form the mandated authority must also be available to construction and a suitable subsidence management Table 18. comment against their request. It may not be adequate plan and monitoring programme must be drawn up according to the public participants. based on the findings of this subsidence assessment. The pre-mining conditions of the 4. Request: surrounding structures must also be determined by a) Please provide these documents and provide an additional 30 land survey and photographic records via a days for review and comment structural integrity assessment as advised by a structural engineer prior to construction. Monitoring C. Lack of the required studies that will specifically safeguard of mining-induced seismicity on surface and surface Purple Moss during the establishment of the mine activities structures, using appropriate seismographs installed and during the operations in permanent positions, is also included in the 1. Observation. monitoring plan. As the proposed mine shaft is located approximately 2 kms South of Portion 62 of the Farm Witpoortje 117 IR southern boundary, and In general the baseline noise level data would apply further is situated down stream from Portion 62 of the Farm to the greater area, including portion 62 which is Witpoortje 117 IR, all reports were briefly read through and within 1.6 km of the proposed Windmill Shaft pertinent notes made, however, the following aspects that could development site. This baseline noise level data have significant impacts on Portion 62 of the Farm Witpoortje 117 could therefore be considered to apply to portion 62 IR are highlighted: as well, unless there are specific existing sources of a) Air Quality noise closer to portion 62 that would be having a b) Blasting negative impact. The noise specialist has c) Noise recommended that quarterly noise monitoring must

ERPM Ext 2 Mine, East Rand, Gauteng 32 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED d) Socio Economic commence during first year of construction and then annually thereafter until construction completed, 2. Air Quality which will provide an updated baseline study prior to The Draft Air Quality Report was done by IMA TRADER 20 CC in mining activities. Further monitoring requirements May / June 2019. are stipulated to continue into the operational Some of the report findings are: phases. a) As the mine is at concept stage reference is made to records from other similar mines. The prevalent air pollutants are dust The specialists have advised as to the from initial blasting, waste stockpiles and vehicles driving on recommended frequency of this monitoring but dust roads, SO2 and NO2 being emissions from mining should the authorities require more intensive ventilation, generators and vehicle exhausts. monitoring, the monitoring programme will be b) Dust will be more prevalent during dry winter months. amended to align with these. The monitoring results c) Prevailing winds in the area come from North, North West and can be made available specifically to Purple Moss, North North West. and will be made available upon request to all IAPs. d) Sampling was done which indicated existing air quality from surrounding residential and industrial sources, to create a The anticipated socio-economic impacts have been The potential cumulative baseline for comparison when the mine is constructed and identified and assessed. Indirect socio-economic impacts which could operational. impacts will occur, but the extent to which these will result from the existing e) Dust fall out was found to be within the acceptable standards. materialise is unknown. Socio-economic monitoring processing plants and f) Once operational, the dust and gases removed from and mitigation measures to stem potential negative tailings facilities which underground blasting will be removed into the atmosphere via socio-economic impacts have been included in the are proposed to be used the vent shaft which is situated approximately 4, 5 kms to the EIA/EMPr, but these will need to be implemented in for this project, should be East of Portion 62 of the Farm Witpoortje 117 IR’s Eastern conjunction with the municipality. considered prior to boundary. The project description, as provided in the EIA construction and this has g) Generally regarding air quality, Portion 62 of the Farm Report, is not anticipated to have significant health been added as a gap Witpoortje 117 IR is situated North of the mine shafts with impacts, however the potential cumulative impacts under Section 3.i. prevailing winds blowing the dust etc. away to the South. which could result from the existing processing plants and tailings facilities which are proposed to be 3. Potential impacts and required intervention. used for this project, should be considered prior to a) Although the report indicate that there may be low impact on construction and this has been added as a gap in the Portion 62 of the Farm Witpoortje 117 IR , Purple Moss the EIA. require a baseline study to be conducted on Portion 62 of the Farm Witpoortje 117 IR prior to any activity taking place. b) The base line dust study must be provided to Purple Moss and will be used to track changes and impacts after commencement of the construction. c) The study must record climatic conditions during the period. d) Furthermore, during construction dust monitoring must be conducted monthly during construction and then quarterly thereafter. e) Results must be provided to Purple Moss as the results become available.

4. Blasting The Blast Impact Assessment was carried out by Blast Management and Consulting in July 2019.

ERPM Ext 2 Mine, East Rand, Gauteng 33 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

5. Potential impacts and required intervention. a) Base line seismic studies must be conducted on Portion 62 of the Farm Witpoortje 117 IR, prior to any activity taking place. b) Nowhere in the reports was it mentioned about effects of blasting at depth, so it is not known what the effects could be. Even ground vibration may not be felt – but this is not known. c) Furthermore, a photographic record must be done on Portion 62 of the Farm Witpoortje 117 IR. Over the next 6 years

ERPM Ext 2 Mine, East Rand, Gauteng 34 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

6. Noise The Draft Noise Impact Assessment was undertaken by IMA TRADER 20 CC in August 2019. Some of the report findings are: a) The report indicates that there are several activities and operational aspects of the mine that will contribute to noise – including: vehicle traffic, blasting, drilling, earth moving equipment, sirens, ventilation fans, winders/head gear, generators and pumps. b) The report considered impact of environmental sound which deals mainly with the activities on surface and near surface and not underground noise which is categorised as occupational noise. c) The report recorded existing ambient noises in the study area – which at this time includes vehicles driving on roads, birds, animals, airplanes passing etc. The information will be used as a baseline to measure the mining activity noise against. One of the noise receptors was placed along the southern boundary of Portion 62 of the Farm Witpoortje 117 IR, which helps understand the existing noise impacts. d) As no information exists on potential noise from the mining activities, examples of similar activities were calculated using a simplified linear “noise decay calculation”. e) Due to the distance from Portion 62 of the Farm Witpoortje 117 IR, it appears that noise from activities on the mine should not pose a problem or be a nuisance. f) The calculated noise at the southern boundary of Portion 62 of the Farm Witpoortje 117 IR during the construction phase as well as during the operational phase is expected to be 51dBA which is 10 Dba above the day time ambient level Recorded at 40.7Dba. This difference exceeds the 7 Dba increase suggested by legislation to cause a noise nuisance. g) An impact assessment was done considering the probability and duration of an occurrence, the severity or magnitude of impact, resulting in a table of possible results. The results are broadly defined into high, medium and low significance.

ERPM Ext 2 Mine, East Rand, Gauteng 35 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

7. Potential impacts and required intervention. a) Base line nuisance studies must be conducted on Portion 62 of the Farm Witpoortje 117 IR prior to any activity taking place. b) Specific nuisances must be identified. c) Potential types of nuisance must be modelled. For instance, blasting noise is very different from drilling. d) The types of nuisance must thus be categories and base lines provided. e) Measurements during the construction period must be conducted continuously. f) Results must be provided to Purple Moss as the results become available. 8. Socio Economic The Socio-Economic Impact Assessment was done by Prime Resources in August 2019. Some of the report findings are: a) Estimated workforce of the mine is 976 permanent employees. The bulk of these will be unskilled and semi- skilled.

ERPM Ext 2 Mine, East Rand, Gauteng 36 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

ERPM Ext 2 Mine, East Rand, Gauteng 37 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

D. CONCLUSION

ERPM Ext 2 Mine, East Rand, Gauteng 38 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Please note the objector Purple Moss 19 (Pty) Ltd reserve their rights to further comment on the application. Deon Duvenage EIA Phase Email received 9 Thank you for your e-mail. (PR responded 10 September 2019) Mhiduve (Pty) Ltd Notification September 2019

ERPM Ext 2 Mine, East Rand, Gauteng 39 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

I have also attached a Google Earth file containing the areas associated with the proposed ERPM Ext 2 Mine.

Livhuwani Ndou EIA Phase Email received Dear Applicant (PR responded 16 September 2019) Transnet Freight Notification 12 September Please kindly indicate if there is any Transnet Property in the Rail JHB via email- 09 2019 vicinity of the Project Site. There are Transnet properties within the greater September ERPM Ext 2 Mining Right Area (MRA), however 2019 none of these are within the proposed surface development areas (SDAs). The Transnet properties within the MRA include the following:  Portion 35, Portion 37, Portion 38 and Portion 251 of the Farm Witpoortje 117 IR;  Portion 19, Portion 20, Portion 21 and Portion 22 of the Farm Rooikraal 156 IR; and  Portion 2 of the Farm Glen Roy 132 IR. I have also attached a map showing the location of the Transnet properties in relation to the ERPM Ext 2 Mine MRA and SDAs.

ERPM Ext 2 Mine, East Rand, Gauteng 40 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Municipal ward councillor Henry Christopher EIA Phase Email received H. Buitendacht – I have requested that the community be consulted (PR responded via email on 11 September 2019) A meeting was held with Buitendacht (Ward Notification 10 September on this matter by means of a meeting the community on 30 no 82) via email- 09 2019 This request has been under mined and over looked. As per our telephonic conversation, you said that the September 2019. September Geluksdal community meet weekly, every Monday at 2019 9 am. Would it be possible for us to attend the next meeting, this coming Monday (16th September), to give the community more information about the proposed ERPM Ext 2 Mine? If you could please confirm that this would be suitable and send the address of the venue where you meet (you said it was a church?)

(PR responded via email on 16 September 2019) As discussed, we would like to confirm that we will be meeting with you and the Geluksdal community on Monday 30 September at 9am.

Can you please send the address for the meeting venue? Precious Mduduzi Scoping No comments received Luvalo (Ward no Phase 99) Notification David Thulani via email- 07 Simelane ((Ward no March 2019 74) Stefanie EIA Phase Ueckermann (Ward Notification no 105) via email- 09 September 2019 Municipality (CoE)

ERPM Ext 2 Mine, East Rand, Gauteng 41 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED Sifiso Ndwandwe; Scoping Letter received A. Hietbrink (EAP, Environmental Resource and Waste (PR responded via email on 17 April 2019) Irreplaceable vegetation, Cecilia Rakgoale; Phase via email – 17 Management Department from CoE) - sensitive areas, and Anél Hietbrink; Notification April 2019 Thank you for your comments, which will be wetlands are addressed Lilian Kwakwa; via email- 08 Attached, please find the comments on the DSR for the proposed incorporated into the final Scoping Report to be in the EIA. Refer to the Nomvula Flara March 2019 bulk sampling activities including trenching in cases of Alluvial submitted to the DMR. baseline section. Environmental Hardcopy of Diamond Prospecting (Ref no. 30/5/1/2/2 10078 MR). Resource and DSR 1. The Environmental Resource Management Department in The comments will be addressed within the EIA, to The layout plans clearly Waste Management delivered by rendering its comments assessed the environmental parameters / be made available at a later stage for your further indicate all proposed Department hand - 08 constraints of the property against the following environmental review. infrastructure (refer to March 2019 management tools: Figure 5 and Figure 7). 1.1 Provincial Environmental Management Framework, 2015 Hardcopy of 1.2 Ekurhuleni Biodiversity and Open Space Strategy (EBOSS), The Water Use Licence EIA delivered 2008 Application (WULA) will by hand - 06 1.3 The Ekurhuleni Bioregional Plan, 2012 include a separate layout September20 1.4 Applicable Environmental Legislation plan indicating 19 stormwater management 2. Based on the above tools and the information contained in the infrastructure and EIA Phase application, the Division comments as follows on the proposed pollution control. Notification activities: via email- 09 2.1 The report indicates the following activities – EIA includes contingency September 2.1.1 Additional twin shaft, inclusive of an access and vent shaft plans to prevent 2019 (Windmill Shaft) will be constructed on Portion 5 of the Farm contaminants from Witpoortje 117-IR to allow for access to the underground mining entering the stormwater operation for ERPM Ext. 2. system or the 2.1.2 The development of head gear on Portion 5 of the Farm surrounding environment Witpoortje 117-IR and nearby wetland 2.1.3 Crushed ore will be transported via existing pipeline, either (refer to Table 24). Knight Plant Pipeline or Ergo Plant Pipeline 2.1.4 Re-opening and re-equipping of the vent shaft (Witpoortje The specialist studies Vent Shaft) on Portion 19 of the Farm Witpoortje 117-IR. proposed in the DSR 2.2 Surface infrastructure at Windmill Shaft (surface area – were undertaken (Table approximately 20 ha) – 11) and clear mitigation 2.2.1 Twin shaft with headgear and winder and vent shaft measures are provided 2.2.2 Refrigeration plant, to cool underground mining operations (Table 10). 2.2.3 Change house, administrative buildings, workshops, salvage yard, stores 2.2.4 Water treatment plant – treatment of underground water 2.2.5 Powerlines, water supply pipeline for potable and service water supply (municipal reticulation system) 2.2.6 Stormwater and pollution control infrastructure inclusive of diversion berms 2.2.7 Back-up generator and above ground fuel supply tank 2.2.8 Explosives handling area 2.2.9 Access roads 2.2.10 Grout plant

ERPM Ext 2 Mine, East Rand, Gauteng 42 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

ERPM Ext 2 Mine, East Rand, Gauteng 43 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED any contaminants from entering the CoE stormwater system or the surrounding environment and nearby wetland. 2.12 The specialist studies proposed in the DSR must be undertaken and clear mitigation measures must be provided. All activities to be undertaken on the said property must be in accordance with all applicable by-laws, policies and requirements of the EMM. It should be noted that, in terms of Section 24F of the NEMA, Act No 107 of 1998, as amended, no listed activity may commence prior to an EA being granted by the CA. Meeting held –  Deeren Naicher (DN) said that he was concerned that the life Meeting minutes 20 September of mine was very long and asked how we can know or be sure attached as Appendix 2019 of what will happen in 47 years’ time. 4.13  DN asked if the proposed mine will limit future developments  LJ indicated that the known housing (specifically with regards to proposed human settlements in developments in the area have been mapped the area) and if the mine would sterilise large portions of land. in relation to the proposed mine and that the mine plan must take these proposed human settlements into account. LJ requested the CoE to provide the location of any other planned developments in the area. LJ explained that the surface infrastructure will be limited to avoid sterilising land and the underground operations will be very deep and will not sterilise the surface.  DN asked if there will be large volumes of material placed on  LJ said that there will be a small waste rock the surface. dump on surface at Windmill Shaft, for the waste rock removed when the shafts are constructed. During the operational phase, waste rock will be used as backfill material underground (grout). Ore will be crushed and mixed with water underground to form a slurry, which will be pumped to surface and sent for processing at either the Knights or ERGO Plants via the existing pipeline network. The tailings material will be sent from the plant to one of ERGO’s existing TSFs.  LJ noted DNs concerns regarding the TSF. The  DN said that although the mine is proposing to have limited TSF and potential expansion thereof was not surface infrastructure the existing tailings storage facility (TSF) considered as part of this project or the EIA as is located on surface and is very large and will have to be the TSF is owned and operated by ERGO. This expanded as additional tailings material is deposited on it. will however be identified as a gap in the EIA.  LJ said that this is currently unknown, however  DN asked what the final size of the TSF would be at the end the mine will have to collaborate with ERGO of the life of the mine. and work within their approved TSF design / dimensions. LJ said that ERGO’s plants receive material from a number of operations in

ERPM Ext 2 Mine, East Rand, Gauteng 44 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED DN asked for a map indicating the extent of the area that will the area and that the client will have to be sterilised due to this project; including other proposed investigate the quantity of tailings that will be projects in the area and the final size of the TSF. produced by ERPM Ext 2 and consider how this will affect the size of the TSF and whether there is sufficient capacity on the TSF to contain this additional material. According to DRDGOLDs website, the Brakpan tailings deposition facility (BTF) is an integral component of the retreatment process and ensures the ability of the ERGO operations to continue treating waste material long into the future. The BTF has been modified to increase the capacity of the site by incorporating the Withok TSF footprint, with the capacity extended to over 750Mt and a footprint of approximately 1440 Ha (as measured from Google Earth).  LJ further explained that the mine has applied for certain listed activities and if they want to change the project description or add any  DN said that the CoE does not have a clear picture of how this additional activities they would have to apply project will affect the future developments over the next 47 for the required authorisations before they can years. He said that the mine must determine ERGO’s implement those activities. The mine must processing capacity and confirm that ERGO has sufficient ensure that all the environmental authorisations capacity on their existing TSFs for the tailings material to be are obtained prior to commencing with any produced throughout the life of mine. activities. Similarly, if ERGO wanted to construct a new TSF or expand an existing TSF, they would have to follow the legislated environmental authorisation process.  LJ said that because mining will be > 2.5 km below ground, there is not expected to be any risk of subsidence and the impacts are largely  DN asked what risks there were for undermining residential limited to the surface development areas. areas.  LJ said that the infrastructure to be located on surface would be limited to within the surface development areas, as indicated on the maps  DN said that the surface areas described for this project look and that only these areas would be sterilised by very small considering the scale of the mining right area and the mine. The rest of the development will be he reiterated that the CoE does not want this mine to below ground. negatively impact the proposed housing developments (as has been the case with Leeuwpoort, where the mine has not  LJ explained that ERPM Ext 1 owns the provided permission for the development that fall over their adjacent mining rights (GP151MR and mining right area). GP150MR) which were previously owned by  DN asked if this project will form part of the adjacent ERPM ERPM. ERPM Ext 1 plans to consolidate the mining right area. underground resources of this project (Ext 2 – GP78MR), with those of GP150MR and

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 LJ indicated that air blast will be perceptible  MM said that it would be useful if the CoE land division met only for the first 3 - 4 blasts as the shafts are with the mine to discuss Leeuwpoort and determine a way constructed. People and animals within forward in terms of this project as well. approximately 500 m of the blasting may be  MM asked about the blasting and how it will affect surrounding startled. Thereafter blasting impacts will be low, homes? because of the depth of mining below ground and should not cause any damage to infrastructure or boreholes on surface.  LJ noted CR’s comment.

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 LJ said that we can only go on the information  Pinkie Netshidzati (PN) said the CoE cannot be expected to we have at present, and in terms of tailings make decisions on assumptions when future generations will disposal the mine would use one of ERGO’s be affected; they have to be certain. existing TSFs . The mine will have to  Martin Bekker (MB) said it is difficult for the CoE to make a collaborate with ERGO and work within their decision on the project as it has such a long life of mine and approved TSF design / dimensions. If the there are a number of unknowns including tailings disposal mine’s project description were to change in and whether ERGO’s TSF will have sufficient capacity in 47 the future then the mine would have to apply years’ time. for the necessary environmental authorisations.  LJ explained that the Mining Right Area is different to the Surface Right Area and that the mine does not own the surface rights. The DMR and development authorities should be  Alrich Bestbier (AB) said that the mine must have a say in determining the location of proposed what developments can take place on the surface. developments.  LJ agreed and said that both surface development areas are currently zoned for agriculture, and that a rezoning application will be submitted in future before they commence  AB said that the mine would have to apply for the necessary with mining activities. rezoning applications for the surface development areas.  LJ said that this meeting was intended to provide feedback and to address concerns that the CoE raised during the scoping phase, however the mine will engage with  AB said that the CoE needs the support of the mine for future stakeholders and IAPs as identified during the development in the area, and that they cannot be in a situation EIA process. like they are with Leeuwpoort. AB said that the CoE needs  LJ said that the comments raised here will be assurance that the mine is willing to engage with them and passed on to the client who can make support other developments. The CoE needs to determine a arrangements to meet with the CoE. The mine strategy for granting permissions for developments etc. will also need to put a community liaison officer  AB said that the CoE needs to know who will be responsible among others in place, to ensure that continual for negotiations as they cannot support such a vast project if engagement occurs with IAPs. they do not have a clear way forward in terms of mining and  LJ said that the project description does not other future developments. indicate that there will be any major hazards on surface and an MHI is currently not required for this project.  Sandra Durand (SD) said that a Major Hazardous Installation  As per the layout plan, the surface areas will be (MHI) study must be undertaken, as the CoE has a situation easily accessible.

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SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED where a school has to be relocated because of the risks of  LJ noted the comment. being near to a MHI.  LJ said that the existing servitudes in the area  SD said that emergency services must be able to gain access would be investigated to ensure that the SDAs to the mine. do not infringe on the servitudes and that the  SD raised a concern about people burning tyres in the area. wayleaves would be applied for where  SD said that Sasol and Afrox both have servitudes and necessary. associated buffers in the vicinity of the project.  LJ said that the mine would engage with the CoE in this regard however, the mine cannot be solely responsible for managing development/ expansion of settlements around  SD said that the CoE has issues with the informal the mining area. communities in the area already. The uncontrolled growth of  LJ said that the SDAs will be secured with these communities will make it difficult to provide services. fencing and security personnel. On closure the shafts will be properly sealed to ensure that the area is safe. The mine may have a positive  SD said that the CoE has concerns around safety at the mine impact in reducing illegal mining activities in the shafts, as there have been instances where children have area. fallen down the shafts.  LJ noted SD’s comment. This is an issue that will need to be addressed by both the mine and the DMR. Illegal mining areas will need to be investigated and mapped and provided to the  SD also said that the CoE has issues with illegal mining. mine to incorporate into their plans. Some areas have been undermined and when emergency vehicles attempt to access the area, the ground collapses. SD asked how the mine will ensure that these issues are not exacerbated. Letter received A. Hietbrink sent the comments on the DEIR for the proposed (PR responded via email on 11 October 2019) via email – 09 ERPM Extension Area 2 Mine (GP30/5/1/2/2/10078MR): October 2019 Support on the proposed development is subject to the following: We hereby acknowledge receipt of your email.  Various processes such as Risk Assessment, MHI, EIA and feasible studies are outstanding or not in place; Your comments are noted and will be addressed in  Life safety and proposed compliance measures related to the the final EIA. 2.5km deep shaft must be addressed; (PR responded via email on 17 October 2019)  Successful approval of an application by DAFF: An agreement between Ekurhuleni Department of Human Settlements, Real As discussed at the meeting held with the CoE, an Estate and ERPM is advised to avoid future sterilisation of MHI study is not considered necessary as no surface development due to underground activities and failure hazardous installations are to occur as a result of to release consent as Mineral Rights Holders for Municipal the project. The EIA and associated risk assessment township development; and have been completed and are to be submitted to the  The applicant must take into consideration of the number of DMR on 18 October 2019. approved and proposed residential Townships in the area in the report that must be approved by DMR, (houses not built The relevant health and safety aspects will be yet). addressed once a detailed mine plan is available. Comments from Environmental Resource and Waste Management Department, Legislative Compliance Division: Copies of the documentation have been made available to DAFF and no comments have been

ERPM Ext 2 Mine, East Rand, Gauteng 48 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED  The proposed Windmill Shaft above ground development are received to date. It is unclear which approvals need zoned Agricultural. to be obtained from DAFF. Rezoning of the land to  The proposed location of the Witpoortje Vent Shaft are located mining has been included as a proposed condition of on the Remainder of Portion 19 of the Farm Witpoortje 117-IR authorisation in the EIA Report. and Portion 283 of the Farm Witpoortje 117- IR. Both these properties are zoned Agriculture with mining rights. Further discussions will need to take place between The requirement for  The GPEMF indicate that the Windmill Shaft and Witpoortje the Applicant, the Municipality and surrounding further discussions has Vent Shaft are located within areas sensitive to development property developers in order to discuss future been included as a activities and also dominated by agricultural activities. development plans in the area. This has been proposed condition of 2.3.1. Zone 3: High control zone (outside the urban included as a proposed condition of authorisation in authorisation in Section development zone); and the EIA Report. 3.j.ii. 2.3.2. Zone 4: Normal control zone.  According to the Bioregional Plan, the proposed development The project requires that a Water Use Licence fall within Critical Biodiversity Areas, Ecological Support Areas Application be submitted and that a Water Use and No Natural Remaining. Licence be obtained prior to activities occurring.  The proposed development is located within the regulatory zone of wetlands in terms of the National Water Act, 1998 (Act The project proposes that slurry be disposed of at No. 36 of 1998). one of two existing tailings disposal facilities, and  The properties under discussion are currently zoned that it be transferred to these facilities by means of “Agricultural”. Therefore, should the properties be rezoned, an existing slurry pipeline. Confirmation is required the applicant must submit an application to the Department of from the owners of these facilities that they are able Agriculture, Forestry and Fisheries (DAFF) in terms of the to dispose of the proposed quantities of slurry; this Subdivision of Agricultural Land Act, 1970 (Act No. 70 of has been included as a proposed condition of 1970). authorisation in the EIA Report.  The report does not indicate where slurry will be disposed of. The report must clearly indicate the proposed location as well The generation of AMD post-closure has been The recommendations in as identified alternatives and quantity of slurry that will be addressed as far as possible with the information Table 10 of the report disposed of during the life of mine. that is currently available. It is noted that additional are included as work is required on the groundwater aspects of the commitments in the  The generation of Acid Mine Drainage (AMD) post closure and project but that these investigations can only be EMPr. the proposed mitigation measures must be clearly addressed undertaken once more information becomes in the reports, as this will have a detrimental impact on available. The recommendations in Table 10 of the agriculture and human settlements in the area if not managed report are included as commitments in the EMPr. appropriately.

 The recommendations within Table 10 of the report pertaining The requirements of Section 25 of the NWA are to AMD must therefore be implemented. It is therefore noted and will be addressed as part of the WULA, recommended that an Acid Mine Drainage Monitoring and for the transfer of excess water. Management Plan be compiled.

 The report indicated that excess water abstracted from below A stormwater management plan will be compiled ground, not used as service water, will be transferred to DRD and submitted with the WULA. Civil design drawings Gold for mining operations. The applicant's attention is drawn will accompany the application. to the requirements of Section 25 of the National Water Act, 1998 (Act No 36 of 1998), should this activity take place. Not Comments regarding the records of African grass- Refer to Section 3.g.i water may be transferred prior to compliance to Section 25. owls in the area are noted and additional measures and Table 17. have been put in place in the EIA and EMPr to appoint a faunal specialist to find and relocate

ERPM Ext 2 Mine, East Rand, Gauteng 49 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED  A Stormwater Management Plan is required, and must be individuals prior to construction. Individuals are to be approved by the City. It is required that a suitably qualified civil carefully relocated to an area of similar habitat engineer, registered with ECSA, be appointed. outside of the development footprint and the  The layout must clearly indicate the proposed stormwater appropriate permits are to be obtained. Downward management system and the separation of clean and dirty facing night-lighting is planned for the development. water / pollution control system.  Should it be required that any sensitive fauna or flora species Relevant reports will be submitted to SAHRA for be removed / relocated during the construction phase of the review and comment. project, the applicant must ensure that the necessary permits are in place prior to removal / relocation. Project details, including connections to sewer or  The ecological report did not indicate that the African Grass- alternative ablution facilities, will be finalised at a Owl (Tyto capensis) was observed on site. The City is aware later stage and the necessary approvals obtained. of sighting within the vicinity of both shaft locations. The African Grass-Owl is a species that is currently under threat due to a loss of habitat caused by increasing urbanisation. These secretive owls depend on a specific type of wetland habitat to live and breed as well as sufficient open grassland in which to hunt. The CoE will not be responsible if the species status will keep on declining.  The report must address the type of lighting that will be used during night time. The proposed locations are known to have grass owl, and are sensitive to artificial light. No artificial light, i.e. floodlights, which may have an impact on the surrounding area will be permitted. Lights must installed facing down and towards infrastructure and not the surrounding environment.  The Heritage Impact Report and Palaeontological Impact Report must be submitted to SAHRA for comment. Recommendations / comments from SAHRA must be addressed in the FEIR and a copy of the response must be attached to the FEIR.  The report did not specify the type of ablution facilities, i.e. chemical toilets that will be used by underground workers or chemicals to be used for cleaning the toilets; and how and where the waste will be collected and disposed of.  A copy of the maintenance and monitoring plan for the existing pipelines must be included in the FEIR and recommendations / mitigation measures must be included in the report.  All concerns raised during the Focus Group meeting with the City of Ekurhuleni, dated 20 September 2019, minutes attached hereto, must be addressed in the FEIR.  Recommendations, findings, mitigation measures, and conclusions from the specialist reports must be implemented on site.

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Hardcopy of Draft EIA delivered by hand - 09 September20 19

EIA Phase Notification via email- 09 September 2019 Jan Mitchell and Scoping No comments received. Tobile Bokwe Phase Eskom Notification via email- 07 March 2019

EIA Phase Notification via email- 09 September 2019 Department Land Affairs Cindy Benyane, Scoping Email received - A. Shiburi (DRDLR) - PR confirmed with A. Shiburi that the Land Claim Land Claim letter Edith Mokgoto, Phase 11 March 2019 Please note that your receipt of inquiry it is hereby acknowledged, letters had been received for all of the affected farms attached as Appendix 5. Solomon Maruma, Notification our turnaround time it is 14 working days due to our internal in February. procedures that must be followed.

ERPM Ext 2 Mine, East Rand, Gauteng 53 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

EIA Phase Notification via email- 09 September 2019

Hardcopy of Draft EIA delivered by hand - 09 September20 19 Steven Mukhola Hardcopy of Email received - Mulalo Mukwevho (GDARD) - (PR responded via email on 30 April 2019) Addressed in the EIA: Gauteng DSR 26 April 2019  Assessment and Department of delivered by Kindly find the attached letter for your attention. Thank you for your comments. implementation of Agriculture Rural hand - 08 GDARD had the following comments: alternatives March 2019

ERPM Ext 2 Mine, East Rand, Gauteng 54 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

considered in design the final mining right layout plan. newspapers (Brakpan Herald and the African Plan (refer to Table  Feasible and reasonable alternatives must be provided and Reporter) on 8 March 2019 in English). 25, Table 26 and comparative assessment of those alternatives must include:  Site notice locations report. Table 27) o Location in relation to surrounding land uses and  Road construction adjacent road infrastructure and services designs (where o Assessment of activity alternatives including current applicable) (refer to and future developments trends in the area Table 22) o The proposed mining rights must address efficiencies in relation to alternative energy sources WULA will address: and use of renewable energy  Water conservation  Significant rating of impacts must lead to reliable conclusion and demand that mitigation measures identifies will reduce impacts to an management acceptable level  Locality maps and layout plans must meet certain requirements  The plan of study outlining specialist studies, EMPr and all other information must be contained in the EIA.  Public participation must be undertaken in accordance with Regualtion41 and no newspaper advert, site notices were in the BID attached to the draft Scoping Report.  The proposed development must address efficiencies in relation to water conservation and demand management.  Waste Management Plan must be compiled an attached on the final report.

ERPM Ext 2 Mine, East Rand, Gauteng 55 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Scoping Phase Notification via email- 08 March 2019

EIA Phase Notification via email- 09 September 2019

Hardcopy of Draft EIA delivered by hand - 09 September20 19 Patle Mohajane, Hardcopy of Email received - P. Mohajane (Programme Manager: Naturally Occurring (PR responded via email on 8 April 2019) ERPM Ext 1 to apply for Malebo Makgale DSR 30 March 2019 Radioactive Material from NNR) – the necessary nuclear National Nuclear delivered by Thank you for your email. authorisation prior to Regulator (NNR) hand - 08 We refer to your extract below from the documents submitted: conducting work in March 2019 Your comments are noted. ERPM Ext 1 will apply affected areas. ERPM Extension Area 1 (Pty) Ltd (“ERPM Ext 1”) is a subsidiary of for the necessary nuclear authorisation as per your This has been included Scoping ERPM (Pty) Ltd (“ERPM”). ERPM Ext 1 holds a prospecting right email, at the appropriate time, prior to conducting as a condition that must Phase (GP243PR) which it intends to convert into a Mining Right work in affected areas. be included in the Notification (submitted with reference number: authorisation. via email- 08 GP 30/5/1/2/2 10078 MR). Since submission of the EA application, March 2019 ERPM’s contiguous mining rights - GP151MR and GP150MR – have been sold to ERPM Ext 1. EIA Phase Notification NNR Comments via email- 09  The NNR records shows that ERPM (Pty) Ltd is the holder of September nuclear authorisation, COR-53. 2019  ERPM Extension Area 1 (Pty) Ltd does not have a nuclear authorisation with the NNR and in term of the NNR Act they are not permitted to conduct or let wok to be executed in all

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EIA Phase Notification via email- 09 September 2019 Zodwa Koalepe, Scoping Emails received Funisile Bebeza (Gautrans) - (PR responded via email on 31 May 2019 and 10 Way leaves to be applied Ernest Sibeko, Phase - 28 May 2019 June 2019) for, this has addressed in Gloria Legwabe Notification and 7 June Letters received for Witpoortje 117-IR, Withok 131-IR and Table 22. Gauteng via email- 07 2019. Rooikraal 156-IR. The Department of Roads and Transport stated Your comments are noted and the applicable way Department of March 2019 that they will not be able to participate in the EIA process but that leaves will be applied for, this will also be addressed Roads and the Gauteng Strategic Transportation Network provincial roads in the EIA/EMPr, which will be made available at a Transport EIA Phase (PWV17, PWV 19, K132, K109, K155, K165, K136, PWV15, PW16 later stage for your further review. (Gautrans) Notification and K163) are affected and as such, in terms of the Gauteng via email- 09 Transport Infrastructure Act 2001, when an application for a The proposed surface area has been amended to September township establishment, change of land use is lodged with the avoid the future provincial road reserve (See 2019 relevant authority, the said application must be lodged with the attached map for you reference). Department for evaluation.

Future roads are affected by the application and as the said route falls under the provisions of Section 7 of Act 8 of 2001 (Gauteng Transport Infrastructure Act 2001) the Department must be provided with a written report for evaluation. An application must be submitted to the Department for a way leave if any part of a proposed service falls within 95 m measured from the centreline of

ERPM Ext 2 Mine, East Rand, Gauteng 57 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Where mining operations are to be undertaken, Section 49 of the Gauteng Transport Infrastructure Act, 2001 shall apply.

These conditions are laid down in terms of delegated authority in terms of the provision of the Gauteng Transport Infrastructure Act, Act No. 8 of 2001 and do not exempt the applicant/ owner/ successor-in-title from the provisions of any other law. Tebogo Scoping No comments received. Molokomme Phase Provincial Heritage Notification Resources Authority via email- 07 Gauteng March 2019

EIA Phase Notification via email- 09 September 2019 Organisations Mariette Liefferink Scoping Email received 9 Kindly advise whether the Applicant is affiliated to DRD Gold. As (PR responded via email on 10 September 2019) Federation for a Phase September 2019 you may reflect, there are currently a significant number of new The applicant, ERPM Extension Area 1 (Pty) Ltd, is Sustainable Notification mining and prospection applications and we as NGOs are a subsidiary of East Rand Proprietary Mines Limited Development via email- 07 overwhelmed by the sheer volume of these applications. I am sure (ERPM), and has no affiliation with DRD Gold other March 2019 the DMR is too! It necessitates consideration of the applications than that the mining rights (GP151MR and we shall comment on and the ones we shall not. GP150MR) and the prospecting right (GP243PR), EIA Phase which the applicant intends to convert into a mining Notification right (as per the application for Environmental via email- 09 Authorisation and associated Draft EIA Report and September EMPr currently available for comment) were 2019 acquired by ERPM Extension Area 1 (Pty) Ltd from DRD.

According to the proposed project description, ore that is mined below ground at ERPM Ext 2 will be crushed and mixed with groundwater to form a slurry and will be brought to surface via a hydraulic hoist system and transported via existing pipelines to either the Knights Plant (via the Knight Plant Pipeline) or the Ergo Plant (via the Ergo Plant Pipeline). These existing pipelines and processing plants are owned and operated by Ergo, a subsidiary of DRD Gold.

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SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED Lawrence Mkhonza Site notices SMS received - Sent his name via SMS and said he was a heritage activist. He PR added L. Mkhonza’s details to the IAP database EIA addresses Heritage and Sicelo Mavuso posted on 13 March 2019 followed up with a phone call to request a copy of the scoping and a copy of the scoping report was sent to him. and Archaeology. Brakpan Museum site and report. Refer to the baseline NPC media notice section and to Table 10 - 08 March Email received - L. Mkhonza (Heritage Projects Director from the Brakpan Museum) (PR responded via email on 1 April 2019) and Appendix 20 for the 2019 29 March 2019 – detailed impact As per our conversation with regards to registration of Interested & Thank you for your email. The contents of which are assessment with EIA Phase Affected parties (IAPs) Ref.Scoping Report GP 30/5/1/2/2 10078 noted and will be incorporated into the final Scoping mitigation measures. Notification MR SEE ATTACHED Documents. Report to be submitted to the DMR. via email- 09 September Stated that according to historical records, the areas of Withok, The information that you provided will also be sent to 2019 Witpoortje, Glen Roy, Rand Collieries and Rooikraal were early the Heritage Specialist who will be conducting the settlements prior to the Anglo-Boer War 1899 – 1902. There is Heritage Impact Assessment for the project. evidence that an Anglo-Boer War Black Concentration Camp existed in Brakpan and Cultural Heritage and Archaeological Impact Assessment Reports in the area confirm a large number of unmarked graved and burial grounds. These graves and burial grounds should be handled by the relevant Heritage Authority and that the next-of-kin be informed and consulted prior to any activity taking place in the area. Identified unmarked graves and burial grounds are located at:  Cnr Heidelberg Rd and Geluksdal Rd, Withok, Brakpan  Heidelberg Rd West, opposite Mine Dump Tailings, towards Brakpan  Nigel/Eikenhoff Rd and Heidelberg Rd, opposite Tsakane Ext 22  Denne Road, off Koot Street, opposite SPCA  Rooikraal 156IR, next to Transnet Railways Electric Transformer Surrounding communities Site notices were An IAP database was maintained during public participation and comments from the community are included in this table under the “Interested Parties” section below. posted on site. Media notice published. Distribution of notice includes nearby towns. Interested Parties As per IAP Scoping Good day database (Appendix Phase The Department of Mineral Resources has accepted an application for a Mining Right submitted by ERPM Extension Area 1 (“ERPM Ext 1”) for the proposed ERPM Ext 2 4.2) Notification Mine, to be located within the City of Ekurhuleni Metropolitan Municipality, Gauteng Province. via email- 07 Prime Resources has been appointed as the Environmental Assessment Practitioner (EAP) to undertake the Environmental Authorisation component of the application. March 2019 OPPORTUNITY TO COMMENT

ERPM Ext 2 Mine, East Rand, Gauteng 59 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED You have been identified as a pertinent Stakeholder in the Public Participation Process. Please see attached a Background Information Document providing a summary of the available information. A copy of the Scoping Report can be downloaded from the Prime Resources website (http://www.primeresources.co.za/downloads/). Should you request an electronic version, we will be able to provide a compressed version via email. The public participation period will run from 8 March 2019 to 8 April 2019. Kindly furnish all comments or queries to Prime Resources ([email protected]) by 8 April 2019. Dear Interested and Affected Party EIA Phase Please follow the link to download the Draft EIA Report and EMPr (and appendices), for the ERPM Ext 2 Mine (10078MR), for your review and comment Notification (www.resources.co.za). Hard copies are also available for viewing at the Vosloorus, Tsakane, Kwa-Thema, Geluksdal and Brakpan Public Libraries. Alternatively, we are via email- 09 able to provide a compressed version electronically upon request. September The public participation period for the EIA phase will run from 9 September 2019 to 10 October 2019. Kindly furnish all comments or queries to Prime Resources 2019 ([email protected]) by 10 October 2019. Should you wish to discuss this project further telephonically, please contact Gené Main or Louise Jones at (011) 447 4888. All comments raised will be captured in the Final EIA Report to be submitted to the DMR. EIA Phase Notification Notification of EIA Phase public participation, for the proposed ERPM Ext 2 Mine, from 9 September 2019 to 10 October 2019. The EIA Report and EMPr is available for via SMS- 09 review and comment at www.resources.co.za, Vosloorus, Tsakane, Kwa-Thema, Geluksdal and Brakpan Public Libraries. Please furnish all comments or queries to Prime September Resources ([email protected] or 011 447 4888) by 10 October 2019. 2019 Comments received from IAPs are recorded below. Thamsanqa Site notices SMS received - Sent his name via SMS. PR added T. Magoso’s details to the IAP database. Magoso posted on 08 March 2019 Johan Bartmann site and Email received - Thank u for the email. I don’t have any queries and issues. (PR responded via email on 11 March 2019) media notice 9 March 2019 published in I would like to get involved with the rubber lining corrosion and pipe Thank you for your email. English - 08 lining and supply. Who do I need to contact for this. March 2019. Prime Resources are independent environmental Please find attached my company profile. consultants and are undertaking the legislated EA EIA Phase process for the proposed project and we are Notification therefore are not involved in the employment or via email- 09 procurement process for the project. However, the September information provided in your email will be forwarded 2019 to ERPM Extension Area 1 for their consideration. Steven Boelane Site notices SMS received - Sent his name via SMS and said he was an interested in PR added S. Boelane’s details to the IAP database posted on 14 March 2019. employment. and a copy of the scoping report was sent to him. site and media notice Email received – Contacts: 081 5487 130 (PR responded via email on 30 April 2019) published in 22 April 2019 Name : STEVEN KATEHO BOELANE English - 08 Interest: employment as a Pump fitter hence I have 3 years’ Thank you for your email. We hereby confirm that March 2019 experience as a fitter, or any work as a general worker. you have been added to the Interested and Affected Party (IAP) database for the Proposed ERPM Ext 2 EIA Phase Mine. Notification Prime Resources are independent environmental via email- 09 consultants and are undertaking the legislated EA September process for the proposed project and we are 2019 therefore are not involved in the employment or procurement process for the project.

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Further to your information session last night at Hardy Plant 165 Email received - Ian Coetzer Road Withok Estates Brakpan we want to raise the (PR responded via email on 4 April 2019) 04 April 2019 following concerns;  Our properties are on agricultural zoned land and we are Thank you very much for the productive meeting. 100% reliant on the underground water tables for our business and day to day use. Municipal water is extremely expensive Your concerns are noted and will be incorporated and have no pressure so therefore it is not cost effective for to into the final Scoping Report to be submitted to the use. DMR.  The new proposed shaft of plus minus 3 kilometres in depth The potential impacts that you list will be assessed might disturb our current underground water quality and in the EIA phase, and as a registered IAP you will be quantities and surface water close to our properties. notified of the availability of this information.  The influx of people will most certainly put additional strain on our existing security issues.  Underground mining activities might cause damage to our existing structures.

ERPM Ext 2 Mine, East Rand, Gauteng 61 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

These are our primary concerns. Another email will follow this one including pictures, showing the current ground and ground water pollution already happening as a result of ERGO pumping operations and how no maintenance or inspections are been carried out on their infrastructure.

Hope you are well. Email received - 18 March 2019 Have attached folder with pictures of ERGO pipeline leaking.

ERPM Ext 2 Mine, East Rand, Gauteng 62 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

There are natural underground water tributaries (from 10m to 20m below ground) that flow from that area and are used by the local residents for drinking, irrigation, livestock etc. that will be affected.

Livestock a primary income source for most of the residents graze in the area and if not kept away from the water will drink it as it is not contained.

This has been the case for over 30 years, and is the reason we feel mining this area will only destroy any future for the community as well as negatively affect all surrounding communities.

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ERPM Ext 2 Mine, East Rand, Gauteng 64 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

ERPM Ext 2 Mine, East Rand, Gauteng 65 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Lukey Nkgapele Site notices Phone call Called to say that he was interested in the project. PR added L. Nkgapele‘s details to the IAP database posted on received - 19 and sent him a copy of the BID via email. site and March 2019 Sidney Mahlangu media notice Phone call Called to say that he was interested in the project. PR added S. Mahlangu’s details to the IAP database published in received - 19 and sent him a copy of the BID via email. English - 08 March 2019 Percy Makanye March 2019 Phone call Called to say that he was interested in the project. He said that PR added P. Makanye’s details to the IAP database received - 20 lives in Ward 105 and is a Ward committee member working on and sent him a copy of the BID via email. March 2019 economic development.

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Kindly furnish all comments or queries to Prime Resources ([email protected]) by 8 April 2019. Email received - I would like to check the impact on water resource degradation as a (PR responded via email on 16 September 2019) 12 September consequence of the extension of ERPM mine. 2019 Could you also provide me how much water will be pumped from Thank you for your email, your concerns are noted Subject: the natural resource and used in the mine. Do the mine perhaps and will be included in the final EIA. Enquiries on have a waste water treatment plant and I need to know the size. Water Quality Can you provide me also with the type of plant they use to treat In response to your questions: water whether it is conventional or unconventional.  According to the surface water and hydrology specialist study that was conducted for the

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ERPM Ext 2 Mine, East Rand, Gauteng 68 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Kindly furnish all comments or queries to Prime Resources ([email protected]) by 8 April 2019. Withok Community Site notices Meeting held -  Eddy Muller (EM) stated that it was a requirement of the act to  LJ said that the legislation did not require the Meeting minutes Focus Group posted on 03 April 2019 provide letters to all houses within the community. EM further submission of letters to all IAP’s houses and attached as Appendix Meeting site and enquired the period in which a response can be submitted that the requirements specified in NEMA in 4.8. media notice was and which phase of the project this is? He further added terms of public participation had been followed. published in that he objected to the time frames provided for comment, as LJ said that the environmental process follows EIA addresses blasting, English - 08 they were not sufficient for him to obtain legal advice and to the timeframes as stated in the NEMA EIA making the area safe for March 2019 submit responses. Regulations, and a 30-day public commenting the community (and period is required for the Scoping phase, which livestock), sinkholes EIA Phase ends on 8 April 2019, however comments (dolomite), groundwater, Notification submitted after that would be included in the surface water, dust, via email- 09 final Scoping Report if time allows or in the next noise, procurement, September phase, the EIA phase. socio-economic benefits. 2019  Louis Coetzee (LC) explained that from previous experience  LJ responded that it is the task of PR to Refer to the baseline with ERGO, the funds set aside for rehabilitation had not been compile a closure plan and to calculate the cost section and to Table 10

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SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED available when the time came for the money to be used and of closing the proposed mine. The mine is and Appendix 20 for the asked how the community can be certain that this will not required, by law, to obtain a guarantee for the detailed impact happen again. determined amount and provide proof of this to assessment with the DMR. mitigation measures.  LC enquired on the time frames of the project.  LJ informed LC that the EA process (including Refer to Appendix 21 for the WUL) could take up to a year. the Closure Plan for the  LC asked if a tailings dam would be developed and if a  LJ explained that processing will take place at closure commitments. pipeline will be constructed. an existing plant, either the Knights or ERGO Plant and that the existing tailings dam and pipelines used by these plants would be utilised for this project.  LC further explained that previous mining operations had not  LJ said that the proposed groundwater been able to utilise the groundwater due to the poor water volumes, use and storage still needs to be quality and queried where the groundwater would be pumped. determined and this will form part of the WULA. LC provided an example that in previous mining operations LJ thanked LC for raising his concerns and the sealing of underground fissures with concrete had caused stated that these would be incorporated into the blockages/ sediment in the surrounding community’s final Scoping Report. boreholes.  Chris Neveling (CN) asked if mine employees would be  LJ said that as far as possible the mine would provided with housing and if the existing hostels in the area hire local people residing in the area and that would be used as the ERGO Mine hostels are in a state of they would not be establishing housing for disrepair. employees.  CN raised the issue of an increase in security risks due to in-  LJ noted the security concern and migration of job seekers. acknowledged that there may be an influx of people into the area looking for work.  LJ said that the issue of leaking pipes has been  CN informed PR that the Knights Plant is depositing their raised by IAPs and that this concern has been tailings on the ERGO Tailing dam and raised the issue of noted. pollution due to pipes leaking and highlighted that wetlands had previously been impacted upon, and thus he objects to the mine.  CN stated that boreholes have already been drilled.  LJ explained that ERPM had a prospecting right and this allowed them to conduct prospecting activities.  CN informed PR that the wind transports dust / tailings from  LJ noted this concern and stated that the the ERGO Tailings dam over Geluksdal and at times is so bad impacts on air quality would form part of the that visibility is reduced. specialist study to be conducted.  William Ntladi (WN) raised the concern of safety in terms of  LJ noted this concern and said that a social illegal miners, and that once a mine closes, people try to specialist would further examine concerns access the mines illegally, and that the employment related to security and influx of people. opportunities will attract people looking for work and intruders.  WN stated that he was also concerned about blasting, he  LJ said that a blasting specialist would be provided an example of a scenario in Potgietersrus where appointed to determine the potential risks/ houses within a certain perimeter were affected and the mine impacts to surrounding structures and that had to relocate people due to safety reasons. WN wanted to

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SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED know how the community would know that their property where required mitigation measures would be would not be affected and how this issue would be mitigated. formulated to reduce the impacts.  WN said that some people in the community use only borehole / groundwater and the impacts to groundwater are of  LJ said that a groundwater specialist would concern. conduct a hydrocensus to determine the extent of groundwater use in the area. Some of the boreholes in the area would be analysed to determine water quality prior to mining operations and this would be used as a baseline to analyse impacts on water quality, and management / mitigation measures would also be incorporated to reduce potential  WN stated that it would be beneficial to have a PowerPoint impacts. presentation at the next meeting so that everyone could see  LJ thanked WN for his suggestion and that PR the maps. would prepare a presentation for the next  WN stated the dust from the ERGO Tailings dam causes air meeting. pollution when there is wind and that this affects the health of  LJ thanked WN for the information and stated the communities. He further stated that appropriate that potential air quality impacts of the project environmental management of the Tailings dam is not would be assessed as part of the EIA. happening.  WN explained that the community is in the process of compiling and submitting an application to the municipality, for  LJ stated that it is unlikely that the mine would the portion of the community with only borehole water, to be be able to assist in this regard. supplied with municipal water and enquired if the mine would be able to assist with this application.  Yolanda Bierman (YB) stated that she stays in close proximity to the existing ERGO pipeline and at some instances when  LJ asked YB to indicate the location of her rocks move through the pipeline it causes her house to shake. house on the map provided. LJ responded that YB further enquired about the impacts of blasting on the with regards to blasting distances she was not houses and what the legislative requirement is in terms of aware of the legislation for underground distance from blasting locations to existing structures. She mining, but for open cast mining the also stated that with the previous mining operations her house recommended safe distance is a 500 m radius has experienced movement. around the blast site. LJ also explained that the mine would be at a depth of approximately 3 km and that blasting impacts would be analysed by the specialist who would conduct the investigation during the EIA phase and provide a report in which legislative requirements would be provided. The blasting impacts due to the sinking of the shaft would  YB enquired if all those in the community would have their also be investigated. boreholes sampled or if the owner of a borehole would have to  LJ informed the meeting attendees that only a organise testing of their own borehole in order to have quality portion of the boreholes would be analysed to result prior to mining operations commencing. establish a baseline for the area, and that could be used by the community. The geohydrologist would determine the boreholes to be analysed

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SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED to ensure a representative sample, however if borehole owners had the means they could test their own boreholes if they felt it to be  Piet van Tonder (PvT) stated that he was on the neighbouring necessary. property to YB and that the pipes passed very close to his  LJ said that these potential impacts would be house. He had also experienced shaking from the pipeline. investigated during the EIA.  Matie Coetzee (MC) asked what the depth to the first level of the mine would be. He also stated that he has cattle and  LJ explained that the mine would be at a depth wanted to know what impacts the mine would have on his of approximately 3 km and that the social farm and livestock. impacts would be assessed and mitigation measures recommended to reduce the  A Coetzee (AC) stated that many people in the community impacts. have livestock and that people rely on the water from their  LJ responded that the relevant specialists boreholes. She raised her concerns about causing sickness appointed would look into potential impacts on amongst the livestock and people, particularly children, due to water quality and the impacts from blasting. LJ poor water quality. AC questioned the impacts of blasting on further stated that the design and construction houses and the potential for cracking, and whether sinkholes of the mine and associated facilities would be could be developed due to mining operations. undertaken in a manner that mitigates these potential impacts. LJ said that the potential for sinkholes to develop would have to be analysed by a specialist. Should the specialists identify sinkholes as a potential risk then appropriate mitigation measures would need to  Mandla Zulu (MZ) enquired if the mine was likely to cause an be put in place to address this impact? informal settlement to develop and what the impacts of this  LJ noted that the social impacts would be would be. assessed and that mitigation measures to reduce the impacts would be included in the EIA. It was not clear, and would largely be unpredictable, whether an informal settlement  MZ asked what would cause the mine not to commence with would develop. operations.  LJ said that the mine may not be granted their EA, WUL and other issues such as funding could cause the mine not to commence with  MZ stated that he conducted poultry farming in the area and operations. wanted to know how the water quality impacts would be  LJ said that a surface and groundwater assessed. MZ queried how the community would be specialist would be appointed to determine the compensated if something were to go wrong and the impacts extent water use in the area. Some of the were realised. boreholes would be analysed to determine water quality prior to mining operations and this would be used, as a baseline to analyse impacts on water quality, and management / mitigation measures would also be  MZ asked how local SMMEs would benefit with regards to incorporated to reduce potential impacts. potential CSIs and how local services would be prioritised.  LJ responded PR is not responsible for procurement but that the mine would use local services if they met the mine’s needs, including

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SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED potential local procurement for goods and services. LJ explained that if the SMMEs could not provide direct service to the mine they might still benefit from the knock on effect of the economic growth in the area. LJ added that any interest in employment/ supply of services sent to PR would be sent to the mine for their  Lesego Senokwane (LS) enquired what stage the process is consideration. in and what the time frames are.  LJ stated that the current stage is the Scoping phase and that the final Scoping Report has to be submitted to DMR by 18 April 2019, and that the closing date for public comment is 8 April 2019. The next phase is the EIA phase where  Dumisane Mazibuko (DM) enquired where treatment of the comments would still be accepted. ore will take place and where waste deposition will occur. DM  LJ responded that crushing would take place also enquired where crushing would take place. below ground and the ore would be transported to either Knights Plant or ERGO Plant as a slurry. The tailings would be deposited on the existing Tailings dam utilised by these plants  Pieter Hansien (PH) stated that he relies on a constant water and waste rock would be stored below ground. supply to water the gardens on his property (a wedding  LJ stated that his concerns are noted and the venue) and that he pumps/ uses borehole water for 6-8 hours geohydrologist would assess the likelihood of per day. PH asked if his water supply were interrupted, what such an impact occurring and provide measures would be put in place to address this issue. mitigation measures.  A query was raised on whether new roads would be constructed or if existing roads would be used.  LJ responded that as far as possible, existing roads would be utilised. Meeting held 4  Peter Gumede (PG) asked that the dewatering process be  LJ explained dewatering and why it will be Meeting minutes September 2019 further explained to allow attendees a better the chance of undertaken. She explained the findings of the attached as Appendix understanding. geohydrology specialist study and the impact of 4.13. dewatering on groundwater quantity. Furthermore, she stated that the impacts as a result of dewatering extend up to 250 m from the shafts and that no boreholes were identified within this zone of influence.  Matie Coetzee (MC) also raised concerns about the impacts  Izak Marais (IM) the representative from ERPM of the mine especially the sealing of the shaft to stop water Ext 1 provided further clarity on the dewatering ingress on groundwater, and ultimately their borehole water. process and explained how the mine seals of He mentioned that the ERGO tailings storage facility (TSF) the shafts to limit the amount of groundwater currently has structural problems, and therefore wonders how entering the underground workings. IM stated much more can be deposited on it. that due to the depth of mining and as per the  PG recommended that risks such as the issues with the TSF geohydrology specialist study, it is highly be identified and mitigation measures implemented. unlikely that there is a link between the surface  The community depends solely on borehole water, and aquifers and the deep aquifers where mining therefore cannot rely on long turnaround times for the mine to would take place (nearly 3 km below surface). If there is an impact it is expected that it will

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 PG asked what is regarded as proper communication between  LJ said that proper communication would be the mine and the community, and at what stage and interval according to a Community Engagement Plan this communication should occur. including the notification of blasts prior to their Refer to Table 20.

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ERPM Ext 2 Mine, East Rand, Gauteng 75 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED  PG queried what will happen on surface during operations. investigated, sinking a shaft is a long expensive process and funds have to be raised.  LJ said that the main activities will take place at the Windmill Shaft (including the handling of men and materials), however there will be  JD asked if the roads in Withok will be tarred as this would limited activity on surface as most of the benefit the community. activities will take place underground.  IM stated that needs of the surrounding communities will be prioritised. Communities that are most affected will get more social  PG asked where SMMEs / business can send their investment than those less affected. At this information for consideration. stage it is unwise to make promises.  PG queried when the mine will start.  IM indicated that it should be sent to PR at the contact information supplied on the BID.  IM gave an indication that it may start in 15 years however, due to the developments at FEV they may have to roll it forward with a start date in possibly about five years. However, it must be understood that a lot would need to happen, for instance this authorisation and Water Use Licences need to be granted furthermore, funding (especially the rehabilitation guarantee) needs to be raised in a very difficult economic climate. LJ stated that this is the initial step and projects can take a long time to get off the ground,  Danie Coetzee asked if people are going to walk to work (i.e. people must not change anything in their lives through Withok Estates to the Windmill Shaft area). at this point.  IM stated that in 2019 he does not foresee that any staff would be walking to work. In previous projects, they have engaged with the local taxi associations to provide transport. This has  PG raised the point that if there is going to be surfacing of been very successful and no complaints have roads that the mine should consider installing paving and not been received. tar. Paving can be done by SMMEs which will leave skills  The point was duly noted. when completed. Tar on the other hand can only be done by large contractors using specialised equipment. Bongani Kunene Site notices Email received - Please acknowledge receipt. (PR responded via email on 8 April 2019) EIA addresses socio- posted on 08 April 2019 economic impacts. Refer site and Sent a formal objection letter against the application for a mining Just to confirm your mail was received earlier today to Table 10 and media notice right on, amongst others, the property known as plots 190 and 191 and the contents will be incorporated into the final Appendix 20 for the published in Withok Estates. The basis for the objection is as follows: Scoping Report. detailed impact English - 08  In October 2018, white stones, probably marking a future road, (PR responded via email on 18 April 2019), In assessment with March 2019 were placed on their property (Plots 190 and 191 Withok response to your comments included in the letter mitigation measures. Estates) that would result in the demolition of his house. sent on 7 April 2019, please see the following:

ERPM Ext 2 Mine, East Rand, Gauteng 76 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED EIA Phase  There was no notification and no consultation about the  To confirm, no demolition of surface infrastructure Notification proposed road and mining right in terms of Section 10 (a), (b) of is planned for the ERPM Ext 2 Mine. The via email- 09 the MPRDA. planned surface infrastructure is limited to September  He gathered from his neighbour that there was a public portions 5 and 19 of Witpoortje 117 IR. It was 2019 consultation meeting on 3 April and that the closing date for confirmed with the mining company that stones comments was 8 April 2019. The notification did not comply with have not been placed for the demarcation of Section 10 and 97 of the MPRDA. Many interested and affected surface infrastructure. community members were not present at the public consultation  ERPM Ext 2 Mine does not include the meeting on 3 April 2019. establishment of a new road.  The application for the prospecting right was granted without  The public were notified of the proposed Mining proper notification and consultations. Right Application in terms of the requirements of  They have just deforested and destumped 500-pecan nut trees NEMA and the EIA Regulations (2014), which valued at R3.2 million and forgone a future income of R2million included the publication of notices in the Brakpan per year from the trees because they have commenced Herald and the African Reporter, on 8 March preparations for a solar power plant on Plot 190n and 191. They 2019. Site notices were also placed in need the land for the solar power plant project. On 11 April, they conspicuous areas, and Background Information are having a site visit with Italian investors who will be funding Documents were hand delivered to some of the the solar power project. For this reason, they object to any future properties surrounding the proposed road passing through their properties 190 and 191 Withok development. Estate.  No public meetings were arranged for the  The potential loss of income from the solar plant would be R400 proposed project. The legislation does not million over the 20-year term. require that public meetings are held. Representatives from Prime Resources were invited to and did attend a meeting with residents of Withok Estates, which was held on 3 April.  The prospecting right has been held by ERPM for many years. The application for the prospecting right would have included the necessary notification and consultation at that time. The current project is related to the application for a Mining Right. The EIA phase for the project will follow this Scoping Phase. The EIA Phase allows for another 30 days of public consultation. As a registered Interested and Affected Party you will be notified of the availability of the documentation for review in due course. Trust this has addressed your concerns in the meantime. Eugene Hansen Site notices Email received - E. Hansen said he is the owner of 198 Ian Coetser Street Withok (PR responded via email on 8 April 2019) EIA addresses posted on 08 April 2019 Estates and that ERPM Ext Area 2 Mine can have huge negative groundwater, blasting, site and consequences for the surrounding areas such as: Thank you for your email. property value, air media notice  The potential impact on the quality and quantity of ground Your concerns are noted and will be incorporated quality, noise, dust and published in water into the final Scoping Report to be submitted to the crime. Refer to the English - 08  Blasting can potentially cause subsidence of the land which DMR. baseline section and to March 2019 could affect his borehole level that he relies on the maintain Table 10 and Appendix garden and filling of ponds. He has recently upgraded his 20 for the detailed

ERPM Ext 2 Mine, East Rand, Gauteng 77 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

However, the information provided in your email will be forwarded to ERPM Extension Area 1 for their consideration. EIA Phase Email received Am I reading it correct that there will be no new pipe lines as ERPM (PR responded 9 September 2019) Notification September 2019 will use existing pipe lines! via email- 9 Yes that is correct, the mine plans to largely use the September existing pipeline network however, some new pipes 2019 would still be required. Xolani Zakhele Site notices Email received - Pipe fitter/mine work (PR responded via email on 30 April 2019) ERPM Ext 1 is to use Mabizela posted on 13 April 2019 local service and goods site and 0765814991 Thank you for your email. We hereby confirm that providers. The media notice you have been added to the Interested and Affected requirement for local published in Party (IAP) database for the Proposed ERPM Ext 2 procurement has been English - 08 Mine. included in Table 20. March 2019 Prime Resources are independent environmental consultants and are undertaking the legislated EA process for the proposed project and we are

ERPM Ext 2 Mine, East Rand, Gauteng 78 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

ERPM Ext 2 Mine, East Rand, Gauteng 79 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Email received - DOES THIS MEAN ILL BE PART OF THE PROJECT TO MINE ON (PR responded via email on 04 June 2019). PR 28 May 2019 MY PORTION LAND ANOTHER IUVE GOT A Thank you for forwarding to us the letter that you TRANSPORTATION CONTRACT COMPANY TO DELIVER received from the DMR. WEHERRT ROASD FRIEGHT AND MARINE (*MARIE TIME) FOR THE MINERALS We have tried contacting you telephonically several times, without success. I CAN ASSISAT IN CLIENT TO BE GRANTED THE MINE RIGHT BY DMR AND MINING TITLIES AM STILL BUSY WITH THE As per the Mineral and Petroleum Resources AUTHORITRIONS TO BE COMMUNITY EXECUTOR Development Act No. 28 of 2002 (MPRDA) the mineral and petroleum resources belong to the nation and the State is the custodian thereof. Any person/company wishing to conduct mining needs to apply for a mining right in terms of the MPRDA. Our client, ERPM Ext 1, has therefore submitted an application for a mining right to the Department of Mineral Resources (DMR).

As part of this application process, the person/company is also required to apply for EA in terms of the National Environmental Management Act (1998) (NEMA). This approval is largely limited to the surface impacts of mining (although mining is one of the activities that requires authorisation). In terms of the NEMA process, the applicant is also required to consult with IAPs and the affected landowners or lawful occupiers.

The proposed ERPM Ext 2 Mine is anticipated to occur between 2500 and 3500 m below ground. As such, the affected properties on surface are only those where the limited surface infrastructure would be located – in this case portions 5 and 17 of the Farm Witpoortje 117IR.

Therefore, although your property does fall within the greater mining right area, it would not be considered one of the affected properties because of the depth of mining and the lack of infrastructure near your property. Your comments and concerns with regards to the project are however welcome, and we have registered you as and interested party, and all future material relevant to the regulated

ERPM Ext 2 Mine, East Rand, Gauteng 80 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Email received – while can you avice where i get the certificate of minerals as shown 4 July 2019 on the deed and can i do a transfer in my name with the conditions (PR responded via email on 04 July 2019) to subjects as imposed by mining state president and do i have Prime Resources have been appointed as the mining debts liability ..and what do u understand by subsidised independent EAP to conduct the regulated mines cause i found out government subisedied mines in 2005 and environmental processes for the ERPM Ext 2 Mine the owner passed 2009 ..respond wikl phone you to more before project and we have therefore taken the evening twilight correspondence with yourself as far as we can and have now forwarded your comments (relating to mineral rights) on to our client. Email received – Thank you, will do. KINDLY INFORME ME ON THE PROCEES OF 6 August 2019 THE MINE DELEVLOPMENT. JULY HAS PASSESD TRIED As explained previously the State owns all minerals CALLING BUT LOUISES PHONE ON VOICE NOTE IN REPLY and may issue the right to mine these upon application and submission of proof that this can be undertaken efficiently. Although your title deeds shows the endorsement for a mining right this does not mean that you have claim to/ or own such mining rights. We have registered you as an interested party, and all future material relevant to the environmental process will be made available to you.

PR requested ERPM Ext 1 to contact Mr Silver directly. Email received – i need assistance on beeuing an applicant to be mineral holder of 26 September asa mine or and alluvial diggings precious stones i need a geologist (PR responded via email on 26 September 2019). 2019 scientist to help with the environmental and all other processes to We will be meeting with the Geluksdal community obtain the mining rights to the mines ... about the ERPM Ext 2 Mine project on Monday 30 September 2019 at 9 am at 760 Rockyrapid Curve, Geluksdal, Brakpan, 1546 (Rehoboth Christian Fellowship Church).

If you are available to attend the meeting, it may be i apologise for not attending the party .hope we can reschedule helpful for you to gain a better understanding of the Email received – appointment at your offices in Johannesburg proposed mining project. 30 September 2019

ERPM Ext 2 Mine, East Rand, Gauteng 81 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Prime Resources are independent environmental consultants and are undertaking the legislated Environmental Authorisation process for the proposed project and we are therefore are not involved in the employment or procurement process for the project.

However, your information will be forwarded to the mine (ERPM Extension Area 1) for their consideration. Email received - Please find attached covering letter and company profile. Thank (PR responded via email on 27 May 2019) 24 May 2019 you. Thank you for your email. Your information will be forwarded to the mine (ERPM Extension Area 1) for their consideration. Eddie Nkosi and EIA Phase Email received - I hereby send this application to be registered on your database as (PR responded via email on 24 May 2019) ERPM Ext 1 is to use Nethi Nkosi Notification 24 May 2019 an Interested and affected Party (IAP),The Thank you for your email. We hereby confirm that local service and goods via email and following company that manufactures and supplies bricks: you have been added to the Interested and Affected providers. The SMS- 09 Spearbrick (Pty)Ltd Party (IAP) database for the Proposed ERPM Ext 2 requirement for local September Based in : 161 Coetzer Street, Withok Estates, Brakpan Mine. procurement has been 2019 Prime Resources are independent environmental included in Table 20. consultants and are undertaking the legislated Environmental Authorisation process for the proposed project and we are therefore are not involved in the employment or procurement process for the project. However, your information will be forwarded to the mine (ERPM Extension Area 1) for their consideration. Email received - Thank you for the response. (PR responded via email on 7 June 2019) 7 June 2019 Herewith attached are the company documents, as well as the Thank you Nethi, I have received your documents covering letter of our expression of interest. and your information will be included in the EIA (under comments received) as well as in the data sent to the client. Khalid Peer Pr. EIA Phase Email received - Please see the attached file which contains my objections to the Thank you for your email. We hereby confirm that Eng, PMP, IWE Notification 15 September proposed underground mining. you, and those cc’ed in this email, have been added Chairperson of the via email and 2019 to the Interested and Affected Party database for the Dalpark Residents SMS- 09 In summary, it does not recognise the Bird Sanctuary in Dalpark proposed ERPM Ext 2 Mine. Association September Ext 1, so this EIA is rejected. Furthermore, it also does not take into 2019 account all the planned developments for Brakpan South by the city

ERPM Ext 2 Mine, East Rand, Gauteng 82 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Thank you for the wonderful application letter, it was very good reading and I have learnt a lot about the future of the intended mining activities for the area. In reading your application there are a few, ubt critical and fundamental errors in your report. I will assume this is due to ignorance or miscommunication of the plans for the area as well as only searching for the existing information you could have obtained from internet and library searches or via government agencies. Please come and pay me a visit and I will show you personally the errors in your report to correct as to what is happening on the ground. The most important issues are the following: 1. Dalpark Extension 1 (use google maps) has an existing bird 1. The Dalpark One Bird Sanctuary, although not Refer to Section 3 e) sanctuary, which you did not include in your report. This classified as a protected area in terms of the where the Dalpark Bird protected land is adjacent to the property you wish to start Protected Areas Act (NBA 2011 and NPAES Sanctuary (not a mining on. This is directly north of your area, which is south of 2008) or the Gauteng C-Plan, will be added to proclaimed protected Carnival City Casino. Your report is reject in its entirety, as the the EIA where applicable. area but considered a impact of mining on this sanctuary is completely left out. Please local green corridor) was redo and resubmit for comments. added to the list of 2. Secondly, how would this mining activity affect the Rietspruit 2. Mining activities and the Rietspruit river – conservation areas near river which flows into the Bird Sanctuary. Do note, we are trying according to the surface water and hydrology ERPM Ext 2 Mine. for a fishing club in the area, and your mining activities together specialist study that was conducted for the with acid mine drainage would affect properties and the project: interests of the fishermen directly. Please respond to this.  The Rietspruit rises in Tambotieville in Brakpan Please redo and resubmit for comments. and then flows in a southerly direction between the Brakpan Airfield to its west and the Leeupan to its east. It continues southwards under the N17 motorway, through the parking area of the Carnival City Casino complex, through the Van Wyk Dam and onto the area covered by the farm, Witpoortje 117 IR. From there it continues in a southerly direction to its confluence with the Withokspruit.  The Rietspruit and its tributaries immediately downstream from the two shafts have poor water quality -

ERPM Ext 2 Mine, East Rand, Gauteng 83 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

ERPM Ext 2 Mine, East Rand, Gauteng 84 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED 4. The land you wish to develop underground mining upon has 4. Urban development Refer to Figure 29. been earmarked by the City of Ekurhuleni for the development  We have mapped the proposed Dalpark of urban areas such as Dalpark Extensions 18, 25, 32 and Extension 32, Helderwyk and Minnerbron Helderwyk Extension 8 to 12 I think, plus there would be residential developments. developments for Minnerbron, Van Dyk Park, Carnival Village  If you could please send a map or the Google and a few more. Please redo your EIA and take into Earth files showing the locations of the Dalpark consideration all the above developments as they sit upon your Extensions 18, 25, Van Dyk Park and Carnival planned mining areas or they are right next door. This includes Village so that we can include these in the EIA. all related studies for road, noise, dust, water, traffic, crime, development, environmental etc. Until the above are not considered in your report, then your report is rejected. If you wish for all the information on the above developments, either consult myself or Galago Environmental Company. They did the assessments for them all. 5. Finally, the infrastructure in the area already cannot cope with 5. Additional pressure on the infrastructure in the the current demands. Please include the Corporate Social area. Investment into the local community for the building of schools,  The influx of people leading to pressure on police stations, magistrate’s courts, parks etc. as they have existing infrastructure and services, nuisance already been earmarked for the region. and social ills was assessed as an impact in Regards and on Behalf of the Dalpark 1 Residence association the EIA. This is beyond the control of the applicant, and will need to be addressed with the assistance of the municipality. The significance of this impact is considered to be high before and after mitigation.  It is expected that the majority of employees will be recruited from local areas and will commute from home to work on a daily basis.  As per the SLP, the mine intends to undertake a housing inventory within six months of the employment of the full workforce to determine the type of housing facilities being used by its employees. This will allow for an understanding of where employees are residing and whether they have established new dwellings in informal settlements, or are residing in existing houses. This does not however take into account the potential influx of jobseekers that do not find employment at the mine but choose to stay in the area.  A Socio-Economic Management Plan, that Refer to Table 20: covers, among others, stakeholder engagement, local engagement structures, Socio-Economic local procurement, recruitment and in-migration management management, has been compiled and will be implemented. measures.

ERPM Ext 2 Mine, East Rand, Gauteng 85 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Email received - thank you very much for getting back to me so soon. That is a lot to 16 September take in and I appreciate your straight forwardness with regards to 2019 the bird park, crime, logistics, traffic, other developments etc.

I will work on a google map to show you the developments as they have been presented to us and try and superimpose with your mining operations, but I will send this to you by next week. Peter Gumede EIA Phase Email received In view of the fact that there is currently a moderate risk of (PR responded via email 11 September 2019) Notification contamination of surface water The study does not explain the life via email and span of this moderate effect. Thank you for your comment. During the public SMS- 09 meeting (4 September 2019) the proposal for the September I therefore propose that ERPM should mitigate the risk of project proponent to approach the City of Ekurhuleni 2019 contamination of surface water by engaging The City of Ekurhuleni to assist in extending the municipal water supply to to extend the existing roll out of municipal water to the plots without the rest of the Withok Community was raised (by municipal water. yourself). We would like to assure you that the proposal has been captured for inclusion as a mitigation measure in the Final EIA / EMPr Report. At this stage the proponent can only commit to approaching and engaging with the City in this regard, they cannot guarantee that this will result in the supply of municipal water to the remaining plots. Geluksdal Site notices Meeting held -  Joel Mnisi (JM) thanked LJ for the presentation however he  HB said that PR had been in contact with him Meeting minutes Community Focus posted on 30 September was concerned that the 10th October is too close and there from the beginning of the public participation attached as Appendix Group Meeting site and 2019 has been insufficient time to prepare. process and that this meeting was initially 4.13. media notice scheduled for the beginning of September. HB published in encouraged the community to ask their English - 08 questions and send their responses before 10 March 2019 October.  LJ agreed that this is an issue and said that the EIA Phase  JM said that the broken sewage pipes and the resulting surface water samples showed that the rivers Notification pollution are a major concern and asked why the authorities are polluted. via email- 09 are not repairing these pipes if they are aware that they are September damaged.  JM’s concerns around the TSF were noted. 2019  JM said that the TSF is already causing sickness and The TSF and potential expansion thereof was decreased water quality and if this project proposes to use the not considered as part of this project or the EIA Refer to Section 3.i existing TSF, these issues will become worse. as the TSF is owned and operated by ERGO. This will however be identified as a gap in the EIA.  LJ said that the mine will provide jobs and skills development and that there will also be positive

ERPM Ext 2 Mine, East Rand, Gauteng 86 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

SECTION AND PARAGRAPH DATE INTERESTED AND DATE & (DATE & METHOD OF RESPONSE) EAP’S REFERENCE IN THIS COMMENTS AFFECTED METHOD ISSUES RAISED RESPONSE TO ISSUES AS MANDATED BY THE REPORT WHERE THE RECEIVED PARTIES NOTIFIED APPLICANT ISSUES AND OR (METHOD) RESPONSE WERE ADDRESSED  JM asked how the community will benefit from this project and knock-on effect for other businesses in the said that the community want to see what the mine will be area. The mines Social and Labour Plan, which able to provide to them. was submitted as part of the Mining Right Application, indicates amongst others the skills development plan, mentorship plan, internships and bursaries and the local economic development projects which are proposed.  The mine will establish a Community Engagement and Security Forum to ensure that  Zwelitsha Thwala noted the mine is a business and that they stakeholders are notified and consulted will want to make a profit. He requested more consultation so throughout the life of mine. that the mine and the community can meet half way and that both can benefit. The mine must take responsibility and accountability for all of the environmental impacts.  LJ indicated that there is insufficient time to arrange another meeting, however LJ urged  Lucky Smith requested that another meeting be held at night the people present to tell those who could not so that those who are working and the business people can attend about the project, so that they can also attend. submit their concerns to PR.  LJ said that the mine would seek to use local businesses to supply them with good and  Thamsanqa Conjwa asked what kind of business services. The mine also wants to assist in ERPM Ext 1 is to use opportunities will be available for local businesses. developing local suppliers and only look further local service and goods away for specialised items or items that cannot providers. The be sourced locally. requirement for local  LJ said that local business owners can send procurement has been their business profiles to PR and that these will included in Table 20.  Shpho Mnguni (SM) asked if there were mitigation measures be sent through to the client. to limit the impacts/ risks raised by the specialists..  The impact assessment and mitigation measures are described in detail in the EIA.  SM asked how many people will be trained and developed Refer to the baseline over the 47 years of operation and how many bursaries will be  The mines Social and Labour Plan, which was section and to Table 10 made available. submitted as part of the Mining Right and Appendix 20 for the  Patrick Mabilane (PM) wanted to know how the mine will avoid Application, indicates amongst others the skills detailed impact what has happened at other mines where there were empty development plan, mentorship plan, internships assessment with promises made to communities and where mining brings no and bursaries and the local economic mitigation measures. benefits to the affected communities. development projects which are proposed.  The Social and Labour Plan and EIA/EMPr are legally binding documents that the mine has to

 PM asked what legal documents would be in place to keep comply with and implement.

track of the mines commitments and asked if there would be a The mine will establish a Community

formal agreement between the mine and the community? Engagement and Security Forum to ensure that

stakeholders are notified and consulted

throughout the life of mine.

 LJ noted AB’s concern and provided an

example of a nearby gold mine, where

unskilled people were employed and further

ERPM Ext 2 Mine, East Rand, Gauteng 87 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

 HB asked for a copy of the presentation so that if required the  LJ said that the mine wants to limit the amount community could meet again to discuss and summarise their of infrastructure on surface and that only the concerns. waste rock removed from the sinking of the  JM indicated that in his experience with underground mining, shafts will be placed on surface. The large amounts of rock is removed and taken to the surface underground workings will use new technology and is often placed on grazing land where it remains whereby waste rock is used as backfill material permanently. JM asked what will happen to all the mined out underground to avoid bringing it to surface. The rock material. only material that will be taken to the surface is the ore which will be treated at the Knights or ERGO plant and the tailings will be sent to an existing TSF.  The majority of the blasting will be very deep and has been covered in the EIA. Once the Refer to the baseline shaft has been constructed it will probably not section and to Table 10  JM asked about the impacts of blasting, specifically the be noticed. and Appendix 20 for the integrity of underground pillars and the potential for it to cause A blasting specialist study was conducted and detailed impact houses to crack. the potential impacts as a result of blasting are assessment with addressed in the EIA. The risk of subsidence mitigation measures. and the impact of blasting on surface are considered to be low due to the depth of mining.  LJ stated that presently the mine plans to employ around 1000 people and it expected that there will be a balance between the use of  Liefde Maphuye (LM) indicated that she had experience machinery and people. working for a deep mine in Nigel and said that many mines  LJ also noted the surface infrastructure are closing or becoming mechanised which is resulting in job includes a refrigeration plant which is required losses. to cool the underground areas to ensure that  LM noted that it is difficult to keep such a deep mine cool for the conditions are suitable for people to work. people to be able to work underground and if the mine would  LJ indicated that the geology of the area is well use people or machines? known and that the mine will take the dolomites into account in their mine plan.

ERPM Ext 2 Mine, East Rand, Gauteng 88 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

ERPM Ext 2 Mine, East Rand, Gauteng 89 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 i) The Environmental attributes associated with the development footprint alternatives (The environmental attributed described must include socio-economic, social, heritage, cultural, geographical, physical and biological aspects)

(1) Baseline Environment

(a) Type of environment affected by the proposed activity its current geographical, physical, biological, socio- economic, and cultural character

Air Quality

The following information was obtained from the Air Quality Baseline and Impact Assessment undertaken by IMA Trader 20 cc in August 2019 (refer to Appendix 6).

Meteorological conditions

The project is situated within the Highveld Climatic Zone, which is characterised by warm, wet summers and cold, dry winters. Mean annual precipitation for the region is 461 mm, and average daily temperatures range from a minimum of 4 ˚C in July to a maximum of 28 ˚C in February. Monthly total rainfall and average daily temperatures measured in Springs since January 2017 are shown in Figure 12, which shows the historical rainfall between 2017 and 2018.

Figure 12: Monthly total rainfall and average daily temperatures, Springs, CoE (Source: WeatherSA, 2018)

Wind

The South African Weather Service OR Tambo Weather Station is the nearest station to the proposed ERPM Ext 2 MRA providing comprehensive wind records. The annual wind rose for the period 2012 – 2014 illustrate that during this period, winds predominantly originated from the north (16% of the time), northwest (13% of the time) and north-northwest (10% of the time), with lower occurrences of winds originating from the north-northeast, west-northwest and east (Figure 13).

ERPM Ext 2 Mine, East Rand, Gauteng 90 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Figure 13: Annual wind rose for the period 2012 – 2014 (Source: South African Weather Service OR Tambo Weather Station)

Existing emissions sources

Sources of air pollutants in the CoE were compiled during the development of an Air Quality Management Plan for EMM in 2004. Source types within CoE include:

 Industrial and commercial – including fuel burning by businesses, hospitals and schools;  Waste treatment and disposal – waste incineration, landfills and waste water treatment works;  Residential – household combustion of coal, paraffin, liquid petroleum gas and wood;  Transport – petrol and diesel driven vehicle tailpipe emissions, vehicle entrained road dust, brake and tyre wear fugitives, rail-related and aviation emissions;  Mining – especially wind-blown emissions from mine tailings impoundments; and  Other – tyre burning, wild fires, fugitive dust emissions from open areas and agricultural activities.

Identified sources within close proximity to the mine include:

 Small industrial sources and fuel burning appliances such as boilers at schools and hospitals, stand-by generators, and air heaters;  Waste - emissions emanating from landfill areas;  Household fuel combustion  Windblown emissions from nearby tailings storage facilities  Vehicle tailpipe emissions  Fugitive dust sources from roads, open areas, agricultural activities and mining  Biomass burning

The CoE falls within the Highveld Priority Area, as identified by the Department of Environmental Affairs.

ERPM Ext 2 Mine, East Rand, Gauteng 91 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Dust fallout monitoring

15 dust fallout samplers were deployed across the MRA and the adjacent areas guided by the dominant wind fields, the locations of perceived sensitive receptors, and the locations of current sources of dust fallout to determine the pre-mining dust fallout rates. The locations of the dust fallout samplers relative to the locations of the SDAs are shown in Table 1. The sample exposure times are within the ideal criteria specified in SANS 1929:2005 (30 days ± 2 days).

Table 1: Locations of the dust fallout buckets and respective co-ordinates Sampler Site Co-ordinates Location Exposure period Windmill SDA 26°18’28.34” S WM-DFO1 Located on the northern boundary of the Windmill SDA 21.06.2019 – 18.07.2019 28°17’01.19” E 26°19’06.32” S Commercial chicken farm property (Eggbert Eggs – Maye Serobe WM-DFO2 21.06.2019 – 18.07.2019 28°17’24.44” E Laying Site) directly south-east of the Windmill SDA Commercial chicken farm property (Eggbert Eggs – Rebafenyi Rearing 26°20’14.77” S WM-DFO3 Site) located immediately north-east of the ERGO slimes dam and 21.06.2019 – 18.07.2019 28°17’33.59” E south-east of the Windmill SDA 26°18’31.28” S Residential small-holding farm property immediately east of and WM-DFO4 21.06.2019 – 18.07.2019 28°17’17.27” E adjacent to the Windmill SDA Witpoortje SDA 26°17’56.96” S WP-DFO1 Residential/commercial property directly south of the Witpoortje SDA 23.05.2019 – 20.06.2019 28°20’50.56” E 26°17’38.57” S Residential property immediately west of and adjacent to the Witpoortje WP-DF02 23.05.2019 – 20.06.2019 28°20’43.59” E SDA 26°16’58.66” S WP-DFO3 Residential property directly north-east of the Witpoortje SDA 23.05.2019 – 20.06.2019 28°21’05.80” E 26°17’36.59” S WP-DFO4 Old mine pit area immediately east of the Witpoortje SDA - 23.05.2019 – 20.06.2019 28°21’15.88” E Central MRA 26°17’55.09” S Residential small-holding farm property located between the two B-DFO1 24.05.2019 – 21.06.2019 28°18’58.77” E proposed SDAs 26°17’36.62” S Informal residential community located between the Windmill SDA and B-DFO2 24.05.2019 – 21.06.2019 28°18’40.79” E Witpoortje SDA 26°17’42.85” S B-DFO3 Open grassland located between the Windmill SDA and Witpoortje SDA 24.05.2019 – 21.06.2019 28°19’08.77” E 26°17’37.38” S B-DF04 Open grassland located between the Windmill SDA and Witpoortje SDA 24.05.2019 – 21.06.2019 28°19’04.89” E * Sample WM-DF01 was eliminated from the assessment as the dust bucket was burnt in a veld fire. Sample B-DF03 was eliminated from the assessment as the sample was compromised in the field.

The following is applicable to the ambient air quality in the area during the drier winter months (i.e. May-June 2019) and prior to the development and operation of the mine:

 The dust fallout rates for all the measurement sites were low and significantly lower than both the Residential and Industrial Dust Fallout Guidelines. This suggests that there are minimal sources of coarse dust in the area of the proposed ERPM Ext 2 MRA, even during the drier winter months.  These dust fallout results suggest that coarse dust entrainment in the region will be low in the drier winter months and therefore insignificant during the wet summer months.  The highest dust fallout rate was detected in the suburban residential/commercial area to the south of the Witpoortje SDA (WP-DFO1). This area is characterised by exposed soil and gravel roads which are a source of dust.  The dust fallout rate at WM-DFO3 is an indication of the coarse dust fraction originating from the existing Withok/Brakpan Tailings Facility (TSF) directly east of WM-DFO3 and immediately south of the MRA. The dust fallout at this site, currently influenced by the existing TSF, is very low even in this drier winter period.  The dust fallout rates at WM-DFO4 and WP-DFO2 indicate the ambient dust fallout rates in the residential areas that will be located closest (within 50m) to the proposed Windmill SDA and Witpoortje SDA, respectively. The dust fallout rates measured at these two residential sites are relatively low, indicating that the existing dust nuisance in these areas is low. There is evidence that the rural gravel roads in the area of WM-DFO4 (immediately adjacent to the Windmill SDA) typically contribute to entrained dust in the region.

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 The dust fallout rates at WP-DFO3, WP-DFO4, WM-DFO2, B-DFO1, B-DFO2 and B-DFO4 are an indication of the current dust fallout rates in the surrounding areas (residential, rural and industrial) that will be located near to the proposed Windmill and Witpoortje SDAs. The dust fallout rates measured at these sites were very low indicating the existing dust nuisance in these surrounding areas is low.  These dust fallout rates will serve as baseline levels of entrained dust in the region prior to the development and operation of the ERPM Ext 2 Mine against which to compare the impacts of the mine once it is operational.

Passive Air Quality Monitoring

The ambient air quality was measured using passive samplers to provide a baseline for the data to compare typical underground emissions released from the vent shafts during the operation of the mine. The passive samplers were located across the MRA and the adjacent areas guided by dominant wind fields and the locations of perceived sensitive receptors. The samplers were deployed for the standard required time period of ± 2 weeks. The locations of the passive samplers are shown in Table 2.

Table 2: Locations of the passive samplers and the respective co-ordinates Sampling site Co-ordinates Location Exposure period Windmill SDA 26°18’28.34” S WM-PS1 Located on the northern boundary of the Windmill SDA 05.07.2019 – 18.07.2019 28°17’01.19” E 26°19’06.32” S Commercial chicken farm property (Eggbert Eggs – Maye Serobe WM-PS2 05.07.2019 – 18.07.2019 28°17’24.44” E Laying Site) directly south-east of the Windmill SDA Commercial chicken farm property (Eggbert Eggs – Rebafenyi 26°20’14.77” S WM-PS3 Rearing Site) located immediately north-east of the ERGO slimes dam 05.07.2019 – 18.07.2019 28°17’33.59” E and south-east of the Windmill SDA Witpoortje SDA 26°17’56.96” S Suburban residential/commercial property directly south of the WP-PS1 23.05.2019 – 06.06.2019 28°20’50.56” E proposed ERPM Ext 2 Witpoortje SDA 26°17’38.57” S Suburban residential property immediately west of and adjacent to the WP-PS2 23.05.2019 – 06.06.2019 28°20’43.59” E proposed ERPM Ext 2 Witpoortje SDA 26°16’58.66” S Residential property directly north-east of the proposed ERPM Ext 2 WP-PS3 23.05.2019 – 06.06.2019 28°21’05.80” E Witpoortje SDA Central MRA 26°17’55.09” S Residential small-holding farm property located between the two B-PS1 24.05.2019 – 06.06.2019 28°18’58.77” E proposed SDA’s 26°17’42.85” S Open grassland located between the Windmill SDA and Witpoortje B-PS2 24.05.2019 – 06.06.2019 28°19’08.77” E SDA 26°17’36.62” S Informal residential community located between the Windmill SDA B-PS3 24.05.2019 – 06.06.2019 28°18’40.79” E and Witpoortje SDA * Sample WM-PS1 could not be used due to damage from a veld fire

The following is applicable regarding passive air quality at the MRA:

 There was evidence that veld fires had occurred across the entire study area during the exposure period. Veld fires

will be a source of BTEX and NO2 and will typically occur in the winter months.  Benzene was detected at all the sample sites. The results were below the NAAQS of 5 μg/m3 at the sites related to the Witpoortje SDA and the central mine area but exceeded the benzene NAAQS at the Windmill SDA. The slight exceedance of benzene may have been emitted by the veld fires that were in the area during sampling.  Toluene, Ethyl Benzene, m-Xylene and o-Xylene were also detected at all the sample sites at concentrations between 1 and 10 μg/m3.

3  The ambient concentrations of NO2 are relatively low and compliant with applicable NAAQS of 40 μg/m . The concentrations recorded most likely originated from the veld fires.

 The ambient concentrations of SO2 at all the sample sites are relatively low and compliant with applicable NAAQS of 3 50 μg/m . The highest SO2 concentrations were measured at the WMPS3 site (Eggbert Eggs – Rebafenyi Rearing Site), which given the location of this site, could be due to the rearing site or due its proximity to the Withok/Brakpan TSF or its proximity to the frequently used railway line.

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 These concentrations will serve as background winter concentrations of these pollutants in the region prior to the development and operation proposed ERPM Ext 2 Mine, against which to compare the impacts of the mine once it is operational.

Blasting

The following information was obtained from a Blast Impact Assessment undertaken by Blast Managemnet & Consulting in July 2019 (refer to Appendix 7).

As site visit was undertaken on 2 July 2019 to get an understanding of the proposed mine area and its surroundings. The site was reviewed using Google Earth Imagery to identify surface infrastructure present in a 3500 m radius from the proposed mine boundary. The identified POIs include chicken broilers, farm buildings/structures, buildings/structures, old tailings dam, pan, marsh, river, dam, railway substation and railway line, tar and gravel roads, power lines/pylons, pipelines, cultivated fields, ruins and Eggbert farm hydrocencus borehole.

Soil, Land Use and Land Cover

The following information was obtained from the Soil and Land Use Survey undertaken by Prime Resources in August 2019 (refer to Appendix 8). A full description of the current landuses is provided in Section 3.g.iv.b.

Windmill Shaft SDA

The proposed location of the Windmill Shaft SDA lies on a soil decribed in the Pretoria-Witwatersrand-Vereeniging Peri-Urban Soil Survey (Yager et al., 1990) as soil series dHu27. This indicates that the soil form is Hutton. Hu27 has a sandy-clay to clay texture, and is underlain with rock with moderate leaching. The soil is expected to be deep, i.e. greater than 1.2 m, and is suitable for agruculture. The Hydropedological study indicated that the Dresden / Mispah soil form also exist within the footprint (Figure 14). The soils of the proposed site appear to be relatively undisturbed, with typical highveld-grassland vegetation cover.

Figure 14: Soils associated with the Windmill Shaft SDA

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Witpoortje Vent Shaft SDA

The Witpoortje Vent Shaft SDA lies on a soil described in the Pretoria-Witwatersrand-Vereeniging Peri-Urban Soil Survey as soil unit GsA which typically has a sandy clay loam texture. This soil unit is a composite of soil series Glenrosa and Avalon soil forms which are Lithosols (shallow and rocky) and structureless soils respectively. The hydropedological study identified the soil form at the Witpoortje SDA as Mispah / Glenrosa which are both shallow, characterised by an Orthic A horizon which grades directly into hard rock or lithocutanic material (SAS, 2019b) (Figure 15). During the site visit the soil appeared highly disturbed with mostly bedrock exposed and the remaining soil appeared shallow and rocky (Figure 16).

Figure 15: Soils associated with the Witpoortje Vent Shaft SDA

Land Use

Site visits were conducted in February 2019 and May 2019 and the following land uses were identified within the proposed site and surrounds: natural open space, historical prospecting and mining activities (mine dumps, pipelines, cleared areas etc.), substations and powerlines, railway lines, tarred roads, gravel roads/footpaths, grazing and chicken farms (Refer to Section 3.g.iv(b) for more information).

Land cover

Land cover data for the proposed mining area was obtained from the 2014 South African National Land-Cover map (Figure 17). The land cover associated with the proposed mining area is classified as cultivated commercial fields (Windmill Shaft SDA) and mines, grassland and open bush (Witpoortje Vent Shaft SDA).

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Figure 16: Disturbed soil within the Witpoortje Vent Shaft SDA

Figure 17: Land cover for the proposed mining right and SDAs (South African National Land-Cover, 2014)

Archaeology and Cultural Heritage

From correspondence received from the Brakpan Museum NPC, according to historical records, the areas of Withok, Witpoortje, Glen Roy, Rand Collieries and Rooikraal were early settlements prior to the Anglo-Boer War 1899 – 1902. There is evidence that an Anglo-Boer War Black Concentration Camp existed in Brakpan, and Cultural Heritage and Archaeological Impact Assessment Reports in the area confirm a large number of unmarked graved and burial grounds. These graves and

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burial grounds should be handled by the relevant Heritage Authority and the next-of-kin be informed and consulted prior to any activity taking place in the area. Identified unmarked graves and burial grounds within the area are located at:

 Cnr Heidelberg Rd and Geluksdal Rd, Withok, Brakpan;  Heidelberg Rd West, opposite Mine Dump Tailings, towards Brakpan;  Nigel/Eikenhoff Rd and Heidelberg Rd, opposite Tsakane Ext. 22;  Denne Road, off Koot Street, opposite SPCA; and  Rooikraal 156IR, next to Transnet Railways Electric Transformer.

The following information was obtained from a Cultural Heritage Impact Assessment undertaken by Archaetnos Culture & Cultural Resource Consultants in June 2019 (refer to Appendix 9).

Three sites of cultural heritage importance were identified. Sites 1 and 2 are demolished structures, and no historical artefacts were noted. Both structures are of negligible heritage importance and low cultural significance and may be demolished upon approval by the relevant heritage authority. Site 3 contains at least 48 graves, 9 marked and the rest unmarked. This means that two of the categories of graves, i.e unknown graves and heritage graves (older than 60 years), are present. As a result, Site 3 has a high heritage and cultural significance. Refer to Figure 18.

No archaeological (Stone Age and Iron Age) tools, artefacts, assemblages, features, structures or settlements were recorded during the survey of the project footprint.

Figure 18: Heritage sites near the proposed Witpoortje Vent Shaft SDA

Palaeontology

The palaeontological sensitivity map on the South African Heritage Resources Information System (SAHRIS) database shows red (very high palaeosensitivity), green (moderate palaeosensitivity) and blue (low palaeosensitvity) over the MRA. The SDA is green (moderate palaeosensitivity), grey (insignificant or zero) and blue (low palaeosensitvity) (refer to Figure 19).

Due to the moderate palaeosensitivity over parts of the SDA a desktop study is required.

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The following information was obtained from the Palaeontological Impact Assessment undertaken by Prof. Marion Bamford in June 2019 (refer to Appendix 10). The two sites for the shafts are on different lithologies. The Witpoortje Vent Shaft SDA, is on volcanic rocks (basaltic lava, agglomerate and tuff) and is igneous in origin, so does not preserve any fossils.

The Windmill Shaft SDA is predominantly on Jurassic dolerite and this is also volcanic in origin as the dolerite dykes intruded through country rock and sediments. Dolerite does not preserve fossils and may even have destroyed any fossils in the near vicinity, if they were present. The north eastern section of the Windmill Shaft SDA is on dolomite and sandstone of the Malmani Subgroup that could potentially have preserved stromatolites. No fossils or stromatolites have been reported from this area but because there is a small chance of finding fossils. In the Malmani Subgroup stromatolites are common. Stromatolites are the trace fossils of algal colonies that grew in the warm shallow seas of the continent more than 2500 million years ago. As the algae photosynthesised in the low oxygen atmosphere they deposited layer upon layer of calcium carbonate, calcium sulphate, magnesium sulphate and other compounds. The stromatolite structures have been classified by researchers but very seldom have the algal cells been preserved in the structures. Furthermore they are microscopic in size and one requires thin sections and microscopes to be able to see the unicellular organisms. This lithology is indicated as moderately sensitive (green) in Figure 19.

Figure 19: Palaeosensitvity of ERPM Ext. 2 MRA

Geology

This information was obtained from ERPM’s 2014 EIA/EMP compiled by Digby Wells and Associates and also from an EIAR conducted in the same area authored by Kongiwe Environmental (2018). Within the study area, the oldest rock outcrops are sediments that derive from the Witwatersrand Supergroup. These have formed pronounced ridges in the Germiston region. The reefs formed in the Witwatersrand sediments are gold-bearing and have been extensively mined throughout the East Rand region. As a result of such extensive mining there is a vast proliferation of mine dumps, which are at present being reclaimed by various mine operators in the area.

Surface outcrops across the area of interest consist predominantly of the Dwyka Group and Vryheid Formation, which are from the Karoo Supergroup, and are unconformably deposited onto older strata. The Vryheid Formation is made up of

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feldspathic sandstone, shale, mudstone and coal. This formation contains bitinous coal seams at 5 locations, which have been historically mined within the Springs area. Unconsolidated alluvial deposits deriving from the quaternary/tertiary age are located along streams, wetlands and pans. Refer to Figure 20.

With respect to soil found in the region, much of it consists of hill wash materials, alluvium along watercourses, and residual souls, all derived from the areas underlying geology. Found within the hill wash and the residual soils are sand, fine gravel and minor silt. While in the case of the water courses, alluvial deposits a mostly comprised of sand and clay with minor gravels. In addition, there are locally developed pedogenic horizons of ferricrete and ferruginous soils, particularly along the margins of water courses and the capillary fringes of perched water. These soils are typically poor and acidic, stony or sandy (Digby Wells and Associates, 2014).

Refer to Figure 34 for the land use in and around the project sites.

Figure 20: Geology in the project area

Groundwater / Geohydrology

The following information was obtained from the groundwater study undertaken by Futue Flow Groundwater & Project Management Solutions in July 2019 (refer to Appendix 11).

In terms of local geology, the proposed mine is situated on the eastern border of the Central Rand Group of mines. The structural geology of the area appears to be very complex due to the underground faulting. The northern and southern boundaries of the Central Rand Basin are controlled by major east-west striking faults with dips similar to that of the sediments.

Aquifers

Shallow perched aquifers (alluvial aquifers) exist within the weathered quartzite and shale formation, overlying the mine workings. Fractured rock aquifers, where water is stored in the intergranular part and transmitted through the fractured part of the aquifer systems, also exist on site. The lithology and geological structures (faults and dykes) define the occurrence and flow paths of groundwater. Due to the competent nature of these rocks, deformation results in brittle failure and the

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development of secondary porosity within these formations. Groundwater flow through these aquifers occurs through secondary features such as faults fractures and dykes. The Malmani dolomite in the study area is associated with carbonate rock aquifers in which water is stored and transmitted through cavities and fractures (karstic aquifers).

The study area has a moderate aquifer vulnerability according to the aquifer vulnerability map of South Africa. With the exception of the Malmani dolomite, all the aquifers in the study area are classified as minor aquifer systems. As a result, the groundwater is of limited quantity, but potenially important for local water supply and base flow for rivers. The dolomite is classified as a major aquifer system, which are viewed as a high yielding aquifer with generally good quality water.

Thermal water

Thermal water was encountered in a fault zone in Witwatersrand quartzite at a depth of between 1 600 and 1 850 m below surface of the site.

Hydrocensus

During the June 2019 hydrocensus, a total of 13 boreholes were identified (Table 3). Some of the boreholes were inaccessible due to the equipment installed, or access to the properties was denied. From the 13 boreholes the depth to groundwater level and current groundwater quality could be measured in 8 boreholes.

Table 3: Hydrocensus results Borehole Elevation Depth Water Level Volume used Owner Water Use Type ID mamsl m mbgl mamsl L/day HBH1 T J Garden centre 1 589.90 20 8.39 1 581.51 12 000 Nursery, chickens HBH2 Schutte Rooikraal 9 1 581.25 30 9.85 1 571.40 5 000 Cattle, household HBH3 Afrisam Aggregate 1 577.49 60 Unknown Unknown Unknown Crusher plant HBH4 Eggbert Laying Farm 1 579.16 Unknown Unknown Unknown Unknown Chicken farm HBH5 Eggbert Rebafenyi Farm 1 585.06 Unknown Unknown Unknown Unknown HBH6 Karel Steyn Plot 65 1 601.00 80 44.65 1 556.35 5 000 Garden HBH7 Karel Steyn Plot 16 1 560.54 30 16.2 1 544.34 1 000 Domestic HBH8 Geldenhuis Boerdery 1 556.87 30 Unknown Unknown Unknown Domestic HBH9 Withok Estates Nursery 1 562.10 60 6.59 1 555.51 10 000 Nursery HBH10 Hardy's Nursery 1 553.86 Unknown 5.17 1 548.69 20 000 Piggery, HBH11 Baloyi Plot 284 1 556.87 108 Unknown Unknown 2 000 vegetables HBH12 Musekwa 1 579.81 Unknown 6.32 1 573.49 20 000 Cattle, household Cattle, sheep, HBH13 Jake Botha Plot 578 1 575.78 60 7.59 1 568.19 10 000 household

Groundwater levels

The depth to groundwater level as measured during the hydrocensus is less than 10m. Groundwater level elevation versus topographical elevation yielded a 93% correlation thus indicating that the groundwater levels generally mimic topography in the areas where the boreholes are located and there is no indication of the aquifers being dewatered. Groundwater flow contours are directed from the higher lying quartenary catchment boundaries towards the lower lying Witbokspruit and Rietspruit that drains the study area (Figure 21).

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Figure 21: Hydrocensus borehole positions and groundwater level elevation contours

Groundwater qualities

In general, the groundwater quality is good with only some individual elements showing concentrations that exceed applicable SANS241:2015 drinking water guidelines. These include:

 Chloride (HBH6 measured 314 mg/L, exceeding the guideline of 300 mg/L). This results in the water having a distinct salty taste, but with no health effects. However, there is a likelihood of increased corrosion rates in domestic appliances.  Sulphate concentrations (HBH2 and HBH5 measured 1130 mg/L and 788 mg/L, respectively, exceeding the guideline of 500 mg/L for health impacts). At concentrations between 600 mg/L and 1000 mg/L water has a pronounced salty and bitter taste, diarrhoea occurs in most individuals; user adaption does not occur. At concentrations above 1000 mg/L water has a very strong salty and bitter taste, diarrhoea occurs in all individuals; user adaption does not occur.  Nitrate (HBH1 and HBH8 measured 12.9 mg/L and 32.5 mg/L, respectively, exceeding the guideline of 11 mg/L). At concentrations between 10 mg/L and 20 mg/L methaemoglobinaemia may occur in infants while no effects are expected in adults. Once the concentrations exceed 20 mg/L mucous membrane irritation in adults may occur.  Aluminium (HBH5 measured 0.359 mg/L, slightly exceeding the SANS241:2015 guideline of 0.3 mg/L). At concentrations between 0.15 mg/L and 0.5 mg/L intake from water may exceed 5 % of the total dietary intake, but with no effects on health. Noticeable adverse aesthetic effects (colour) occur when aluminium is present in association with iron or manganese.  Manganese (HBH7 measured 0.51 mg/L, exceeding the SANS241:2015 guideline of 0.4 mg/L). At concentrations up to 1 mg/L, severe staining and taste problems arise although no health effects are expected.  Total Coliform (HBH5 measured 1500 CFU/100 mL, exceeding the guideline value of 10 CFU/100 mL). Concentrations above 100 CFU/100 mL are indicative of poor water treatment, post-treatment contamination or

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definite growth in the water distribution system. There is a significant and increasing risk of infectious disease transmission.

The boreholes are located in a static aquifer, and the water is recently recharged. Some ion exhange has taken place since

recharge resulting in the groundwater being split almost evenly between Ca/Mg and SO4 dominant (3 out of the 8 samples) and Ca/Bi-carbonate dominant (4 out of the 8 samples). The calcium bi-carbonate dominant groundwater is considered to originate from the karst (dolomitic) aquifer.

Hydrology

The following information was obtained from the Hydrological Report compiled by African Environmental Development in August 2019 (refer to Appendix 12).

Description of the catchment

The study area falls within a single quaternary catchment, Catchment C22C. This catchment has a mean annual precipitation (rainfall - MAP) of 683.75 mm/a of which 30.7 mm/a reaches surface watercourses as run-off, i.e. the mean annual run-off (MAR) of this catchment is 30.7 mm/a.

The study area includes the Rietspruit and its tributaries, namely the Witpoortspruit (passing the Witpoortje SDA), the Withokspruit, an unnamed stream referred to as the “Sewage Stream”, and another unnamed stream flowing from west to east into the Rietspruit referred to as the “Windmill Stream”. The Rietspruit flows into the Klip River after collecting flow from its downstream tributary, the Natalspruit, with its tributary, the Elsburgspruit. All these streams drain the Witwatersrand and all of them are associated with present and historic gold mining.

Witpoortspruit

The Witpoortspruit flows past the southern part of the Witpoortje Vent Shaft in a northeast to southwest direction. It drains a surface area comprising of mostly mining and industrial areas, but also contains some high-density residential areas (e.g. Minnebron and Sunair Park) and some agricultural smallholdings. Historic mining activities have impacted on this stream, with hardly any section of the stream not significantly transformed by mining activities.

Withokspruit

The Withokspruit, into which the Witpoortspruit drains, rises within a large, high-density residential area. This area is located to the east of the Ergo Plant and south of the N17 motorway. After leaving the residential area in a westerly direction it enters the Withok Estate, an agricultural holdings area, where the Witpoortspruit joins the Withokspruit. Downstream from the confluence of the these two streams, the Withokspruit continues in a southerly to southwesterly direction past two active mine tailings dams (one of which is constructed within one of the Withokspruit's tributaries), through another agricultural area (Suidwyk, Waterlands and Mapleton AH) to its confluence with the Rietspruit immediately opposite (north of) the largest of the two tailings dams.

Natalspruit

The Natalspruit, the second largest collector in the Rietspruit catchment in this drainage region, rises in Alberton. Its main collector and its tributary, the Elsburgspruit draining the CBD area of Boksburg, flows in a southerly direction through the Boksburg Lake and then the Cinderella Dam. The Elsburgspruit then flows under the N3 motorway at the Elsburg Tailings Complex, where it flows into the Natalspruit immediately south of the N3 motorway. The Natalspruit then continues southwards past a heavy industrial area (Wadeville) and through a high-density residential area (Vosloorus to the east and Thokosa and Katlehong to the west of the stream) up to its confluence with the Rietspruit.

“Sewage Stream”

This is the stream flowing to the east of the Windmill Shaft SDA. This stream does not have a name, but due to the massive raw sewage flow in this stream it is referred to by this name for the purpose of this study. The Sewage Stream rises in the

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high-density residential area of Windmill Park and flows past the Windmill SDA to its confluence with the Rietspruit. A sample was not collected from this stream due to the extremely high health danger associated with the stream.

“Windmill Stream”

This stream does not have a name and is referred to by this name for the purpose of this study. The Windmill Stream rises at a landfill site, which seems to have been constructed across the upper reaches of this stream. The stream flows in an easterly direction (past the south of the proposed Windmill Shaft SDA) to its confluence with the Rietspruit immediately downstream from the confluence of the "Sewage Stream" with the Rietspruit. Any spillage emanating from the eastern part of the Windmill Shaft SDA will find its way to this stream. There is a farm dam in this stream directly south of the Windmill Shaft SDA, which is used for the watering of farm animals, mainly cattle.

Rietspruit

The Rietspruit rises in Tambotieville in Brakpan and then flows in a southerly direction between the Brakpan Airfield to its west and the Leeupan to its east. It continues southwards under the N17 motorway, through the parking area of the Carnival City Casino complex, through the Van Wyk Dam and onto the area covered by the farm, Witpoortje 117 IR. It continues in a southerly direction past the "Sewage Stream" up to its confluence with the Withokspruit at a large tailings dam complex of Ergo. Thereafter it gradually turns in a southwesterly direction and continues past its confluence of the Natalspruit at the southern tip of Katlehong and Vosloorus. The Rietspruit then continues almost due east to its confluence with the Klip River. The Klip River is a tributary of the Vaal River, with its confluence with the Vaal River in the Vaal Barrage Dam Lake.

Average flow in the streams

There is a single DWS flow gauging station, Station C2H136, in the Rietspruit. This gauging station is located right at the outlet of quaternary catchment C22C, i.e. immediately upstream from the Rietspruit's confluence with the Klip River. This gauging station has only been operational since 2011 and thus has very limited time coverage. The flow records are shown in Table 4 and in Figure 22 and Figure 23 (where the actual flow records in Table 3 are used).

Figure 22: The monthly seasonal flow pattern of the Rietspruit

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Figure 23: The annual flow in the Rietspruit

Table 4: The existing flow records of Gauging Station C2H136 in the Rietspruit

Water quality

Four water quality samples were collected during a site visit on 25 June 2019 at the following locations:

 Sample Witpoort 01 – at the Witpoortspruit, a short distance upstream from the proposed Witpoortje Vent Shaft.  Sample Witpoort 02 – at the Witpoortspruit, downstream from the proposed Witpoortje Vent Shaft SDA at a wetland upstream from the culvert under 18th Street.  Sample Rietspruit 01 – at the Rietspruit, immediately upstream from its confluence with the “Sewage Stream.”  Sample Windmill 01 – at the “Sewage Stream”, no sample was collected due to the associated health hazard  Sample Windmill 02 – at the Windmill Stream, south of the proposed Windmill Shaft SDA.

The water quality monitoring results for the samples collected were compared to the South African National Standard, SANS 241-1:2015 in Table 5. The results indicate impacts from anthropogenic activities and historic gold mining on the surrounding the watercourses. The Witpoortspruit, passing the Witpoortje Vent Shaft SDA, showed the highest gold mining impact. Pollution, possibly emanating from the leachate ponds of the landfill site, was evident in the Windmill Stream.

Table 5: Surface water quality monitoring results for the samples collected from the streams associated with the ERPM Ext 2 Mine Sample ID / Witpoort 01 Witpoort 02 Rietspruit 01 Windmill 02 SANS 241:2015 (Edition 2) Determinant Macro, Physical and other important mining-related determinants Standard Limits Risk pH (at 25°C) 4.2 7.6 7.7 8.0 ≥5.0 -≤9.7 Operational Conductivity (mS/m) 190 131 59 196 ≤170 mS/m Aesthetic 0-50: Soft, 50-100: Moderately soft, 100- 150: Slightly hard, 150-200: Moderately Total Hardness (mg/l) 722 494 164 459 hard, 200-300: Hard, >300: Very hard (DWAF1996) Total Alkalinity (mg/l) <3.5 86 74 369 WAD Cyanide (mg/l) <0.5 <0.5 <0.5 <0.5 ≤200 µg/l Acute health Acute health: ≤500, SO (mg/l) 958 511 143 <40 (13)* 250 and 500 mg/l 4 Aesthetic:≤250

NO3 (as N) (mg/l) 1.3 2.1 <0.5 4.2 ≤11 mg/l Acute health Cl (mg/l) 73 56 39 324 ≤300 mg/l Aesthetic

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Sample ID / Witpoort 01 Witpoort 02 Rietspruit 01 Windmill 02 SANS 241:2015 (Edition 2) Determinant Ca (mg/l) 190 132.0 36.0 70.0 <150 mg/l Mg (mg/l) 60 40.0 18.0 69.0 <70 mg/l Na (mg/l) 103 73.0 36.0 216.0 ≤200 mg/l Aesthetic K (mg/l) 16 11.0 6.5 20.0 <50 mg/l Ammonia (mg/l) <0.5 <0.5 <0.5 0.7 ≤1.5 mg/l Aesthetic Chronic health:≤400, Mn (µg/l) 11 867 5.2 3.2 2.3 100 and 400 µg/l Aesthetic:≤100 Chronic Fe (µg/l) 165 1.5 14.0 13.0 300 and 2000 µg/l health:≤2000, Aesthetic:≤300 Uranium (µg/l) 83.0 53.0 14.00 8.20 ≤30 µg/l Chronic health Micro Determinants Aluminium (µg/l) 5 489.0 18.0 8.7 15.0 ≤300 µg/l Operational Antimony (µg/l) 0.05 0.05 0.08 0.20 ≤20 µg/l Chronic health Arsenic (µg/l) 0.80 0.30 0.50 1.40 ≤10 µg/l Chronic health Barium (µg/l) 10.00 5.9 18.0 241.0 ≤700 µg/l Chronic health Beryllium (µg/l) 4.30 0.12 0.09 0.10 Bismuth (µg/l) 0.005 0.01 0.01 0.01 Cadmium (µg/l) 1.320 0.03 0.02 0.01 ≤3 µg/l Chronic health Tot. Chromium (µg/l) 1.370 0.2 0.2 1.0 ≤50 µg/l Chronic health Cobalt (µg/l) 847.0 38.0 2.0 0.9 ≤500 µg/l Copper (µg/l) 118.0 1.6 1.2 2.8 ≤2000 µg/l Chronic health Lanthanum (µg/l) 64.0 0.08 0.02 0.08 Lead (µg/l) 0.99 0.03 0.03 0.03 ≤10 µg/l Chronic health Lithium (µg/l) 27.0 9.84 1.79 1.12 Mercury (µg/l) 0.5 0.5 0.4 0.5 ≤6 µg/l Chronic health Molybdenum (µg/l) 0.100 0.60 0.30 1.10 Nickel (µg/l) 2 185.0 64.0 7.1 18.0 ≤70 µg/l Chronic health Platinum 0.02 0.04 0.02 0.02 Selenium 6.11 4.67 0.09 0.88 ≤40 µg/l Chronic health Tellurium 0.03 0.04 0.03 0.01 Thallium 0.09 0.02 0.01 0.03 Tin 0.11 0.10 0.09 0.14 Titanium 0.83 1.4 <0.01 0.3 Vanadium 0.05 0.0 0.1 6.8 ≤200 µg/l Chronic health Zinc 811.0 4.9 1.0 0.7 ≤5000 µg/l Aesthetic

* Orange exceeds health concentration, yellow exceeds aesthetic or other non-health concentration, but complies with the health concentration and green indicates compliance with SANS 241-1:2015.

Noise

The following information was obtained from the Sound Level Survey conducted by IMA Trader in August 2019 (Appendix 13).

Sound level survey

A baseline ambient sound level survey was undertaken to quantify the sound pressure levels at selected monitoring sites within the proposed mining right area and rural areas surrounding the mining right area. The measurement sites were selected taking into account the location and layout of the SDAs and the locations of potential, representative nearby sensitive receptors (Table 6 and Table 7).

Surveys were conducted over one night-time period and two day-time periods. SANS 10103:2008 defines the day-time period to be between 06:00 and 22:00 and the night-time period to be between 22:00 and 06:00. The sound level surveys at ERPM Ext 2 MRA were conducted as follows:

 Day-time survey on 23.05.2019 – mine non-operational (baseline assessment): 15h20 – 15h40  Day-time survey on 24.05.2019 – mine non-operational (baseline assessment): 10h00 – 13h45  Day-time survey on 20.06.2019 – mine non-operational (baseline assessment): 13h00 – 16h50  Night-time survey on 20.06.2019 – mine non-operational (baseline assessment): 22h00 – 02h30  Day-time survey on 21.06.2019 – mine non-operational (baseline assessment): 09h30 – 14h50

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All sound level measurements at all selected sites were recorded over 15-minute periods.

Table 6: Sound level measurement sites near the Windmill Shaft SDA Monitoring SANS Land-use Location Reason for selection site Classification 26°18’28.34” S WM-SL1 Located within the proposed Windmill SDA Currently rural 28°17’01.19” E 26°19’06.32” S Commercial chicken farm property (Eggbert Eggs - Maye Serobe Laying Site) WM-SL2 Rural 28°17’24.44” E south-east of the proposed Windmill SDA 26°20’14.77” S Commercial chicken farm property (Eggbert Eggs - Rebafenyi Rearing Site) WM-SL3 Rural 28°17’33.59” E located south-east of the proposed Windmill SDA 26°18’31.28” S Residential small-holding farm property immediately east of and adjacent to the WM-SL4 Currently rural 28°17’17.27” E proposed Windmill SDA 26°17’56.25” S Residential small-holding farm property (located nearby to proposed access WM-SL5 Currently rural 28°16’36.40” E route to Windmill SDA) and directly north-west of the proposed Windmill SDA 26°17’20.54” S Located it the area that has been approved for the Helderwyk Integrated Mega WM-SL6 Currently rural 28°17’16.83” E Human Settlement, north-east of the proposed Windmill SDA

Table 7: Sound level measurement sites near the Witpoortje Vent ShaftSDA Monitoring SANS Land-use Location Reason for selection site Classification 26°17’56.96” S WP-SL1 Residential/commercial property directly south of the proposed Witpoortje SDA Rural 28°20’50.56” E 26°17’38.57” S WP-SL2 Residential property immediately west of the proposed Witpoortje SDA Rural 28°20’43.59” E Suburban districts 26°16’58.66” S WP-SL3 Residential property directly north-east of the proposed Witpoortje SDA with little road 28°21’05.80” E traffic 26°17’36.59” S WP-SL4 Old mine pit area immediately east of the proposed Witpoortje SDA Rural district 28°21’15.88” E 26°17’36.01” S WP-SL5 Within the Witpoortje SDA Currently rural 28°20’53.63” E 26°17’55.09” S B-SL1 Residential small-holding farm property located between the two proposed SDAs Rural district 28°18’58.77” E 26°17’36.62” S B-SL2 Informal residential community located between the two proposed SDAs Rural district 28°18’40.79” E 26°17’42.85” S Open grassland located between the two proposed SDA’s (Windmill shaft SDA B-SL3 Rural district 28°19’08.77” E and Witpoortje vent shaft SDA)

The following is relevant relating to the current day-time ambient noise levels within and nearby the proposed ERPM Ext MRA:

 WM-SL1 and WM-SL4 represent the ambient sound level environment associated with the Windmill SDA. The sound

level environment can be described as quiet noise environment (LAeq 33.2 – 39.2 dBA) for most of the time, but

influenced by intermittent loud noises (LAmax 57.4 –60.9 dBA) generated by aeroplanes overhead and barking dogs.  WM-SL2 and WM-SL3 represent the ambient sound level environment associated with the two Eggbert Eggs facilities located to the south of the Windmill SDA. The sound level environments at these facilities can be described as

medium noise environments (LAeq 43 – 52.8 dBA) as a result of the chicken house extractor fans, dogs barking and staff talking.  WM-SL-6 represents the ambient sound level environment associated with the Helderwyk Integrated Mega Human Settlement area to the north of the Windmill SDA. The sound level environments in this area can be described as

medium noise environments (LAeq 40.7 dBA) as a result of the influence of traffic noise generated on the M43.  WP-SL5 represents the ambient sound level environment associated with the Witpoortje SDA. The sound level

environment can be described as medium noise level environment (LAeq 47.1 dBA) for most of the time, but influenced

by intermittent loud noises (LAmax 63.5 dBA) generated by aeroplanes overhead and traffic on the N17 and R23.  WP-SL1 and WPSL-2 represent the ambient sound level environment associated with the rural small-holdings to the west of the Witpoortje SDA. The sound level environments associated with these small holdings can be described as

low to medium noise environments influenced by local traffic (LAeq 36.7 – 48.8 dBA).  WP-SL3 represents the ambient sound level environment associated with the nearest residential area to the north of the Witpoortje SDA. The sound level environment associated with this are can be described as medium noise

environment (LAeq 44.9 dBA) typical of a suburban residential area.

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 B-SL1, B-SL2 and B-SL3 represent the ambient sound level environment associated with the undeveloped area in the centre of the EPRM Ext MRA. The sound level environment associated with this area can be described as medium

noise environment (LAeq 43 - 47 dBA) influenced by overhead aeroplanes and off-road motorbikes.

The following is relevant relating to the current night-time ambient noise levels within and nearby the proposed ERPM Ext MRA:

 WM-SL4 represents the ambient sound level environment associated with the Windmill SDA. The night-time sound

level environment can be described as quiet noise environment (LAeq 30.2 dBA).  WM-SL2 and WM-SL3 represent the ambient sound level environment associated with the two Eggbert Eggs facilities located to the south of the Windmill SDA. The night-time sound level environments at these facilities can be described

as quiet to medium noise environments (LAeq 30.2 – 47.4 dBA) as a result of the chicken house extractor fans, dogs barking and staff talking.  WM-SL5 represents the sound level environment to the north of the Windmill SDA. The night-time sound level

environment can be described as medium noise environment (LAeq 47.4 dBA) influenced by traffic on the M43.  WP-SL5 represents the ambient sound level environment associated with the Witpoortje SDA. The night-time sound

level environment can be described as medium noise level environment (LAeq 47.1 dBA) influenced by local traffic on

Denne Road (LAeq 46.5 dBA).  WP-SL1 and WPSL-2 represent the ambient sound level environment associated with the rural small-holdings to the west of the Witpoortje SDA. The night-time sound level environments associated with these small holdings can be

described as a medium noise environments (LAeq 46.3 – 54 dBA) influenced by traffic on Denne Road and Koot Street.  WP-SL3 represents the ambient sound level environment associated with the nearest residential area to the north of the Witpoortje SDA. The night-time sound level environment associated with this are can be described as medium

noise environment (LAeq 54.0 dBA) typical of a sub-urban residential area.

Socio-economic

The following information was obtained from the Social Impact Assessment undertaken by Prime Resources in August 2019 (refer to Appendix 14). The City of Ekurhuleni IDP (CoE) Integrated Development Plan (IDP) (2016/17 – 2020/21) (2018/2019 Review); Ekurhuleni Metropolitan Municipality, Regional Spatial Development Framework: Region E, 2015; Rand West City Local Municipality 2018/19 IDP; ERPM Extension Area 1 (Pty) Ltd: Social and Labour Plan (2018-2022); Gauteng Infrastructure Funding Summit, Mega Projects and Ekurhuleni Growth and Development Strategy (GDS) 2025 were consulted to informt the socio-economic context.

Several site visits were undertaken to provide an understanding of the socio-economic landscape. The locations of various settlements and businesses in proximity to the mine were mapped, and photographed.

Geographical and Administrative context

The CoE is one of the most densely populated areas in the Gauteng province. As of 2016 there were approximately 3.3 million people living within CoE, making it the 4th largest municipality in the country. In-migration of people is a key feature of growth in the CoE. The economy is large and diverse and contributes about 6% to the Gross Domestic Product (GDP) of South Africa and 18% to Gauteng’s economic output. Manufacturing in the CoE accounts for about 21 % and finance accounts for about 22% of its GDP. Large scale goods and commodities production takes place in CoE. Additionally, 14% of the CoE is regarded as high potential land suitable for agricultural production.

CoE has the highest unemployment rate in Gauteng compared to other metros at 29.72%, a figure which has been rising steadily since 2009. The IDP has identified the social development strategic tensions relating to progressive de- industrialisation, low economic growth, high unemployment, high levels of poverty and inequality, household food security and a lack of investment in economic infrastructures critical for the CoE.

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The MRA is situated within Region E of the CoE and is made up of wards 74, 82, 99 and 105, which can be found within the south-eastern section of the metropolitan council area (refer to Figure 24). Region E is bordered by the Lesedi Local Municipality along its southern and eastern borders. The region comprises Duduza, Tsakane, Kwa-Thema and parts of Brakpan. Prominent land uses in Region E include residential (low to high income), mining (and closed mines) and mining related legacy issues such as large tailings complexes. There is also industrial development concentrated around Nigel, southern Springs, Dunnotar Airport; vacant and undeveloped agricultural land; as well as areas demarcated for conservation such as the Marievale Conservation Area. According to the IDP, the CBDs in the Ekurhuleni Municipality are largely in a state of decay and are in dire need of maintenance and upgrade. Region E is predominantly bound by the N17 to its north.

Figure 24: Regional map of Ekurhuleni (EMM, 2015)

Statistical profile of Region E

Region E is home to an estimated 503 000 people, which makes the region the third largest in the municipality. The MRA and SDA fall within the boundaries of wards 105, 99, 82 and 74. According to the Region E SDF (2015), unemployment in the region is high, and participation in the labour force is low. Ward 82 contains the agricultural smallholdings of Withok Estates and a portion of Tsakane. Ward 99 is made up of the majority of the MRA, the existing ERGO tailings dam and a portion of Villa Liza high density suburb. Ward 105 contains the residential areas of Dalpark Ext. 1, Minnebron, Sallies Village and Denneoord. Ward 74 contains the suburbs Tornado, Selcourt and portion of Springs.

Ward 99 is the most populated ward in the Region, and has the least number of people that were born in Gauteng. Ward 105 is the least populated ward in the Region (refer to Table 8). The dominant language profile in Ward 105 is Afrikaans, whereas it is IsiZulu in the remaining wards (Figure 25). Most of the occupants in all wards are in possession of a Grade 9 and higher, however ward 105 occupants were found to be the most educated (Figure 26). With regards to household utilities, ward 82 occupants have the best access to regular refuse removal, flush or chemical toilets, and piped water. The ward also has the least number of informal dwellings. Wards 74 and 82 have a higher prevalence of informal dwellings, and the least access to proper household utilities (Figure 27). The highest employment level and annual household income is noted in ward 105, followed by ward 82 and ward 74. Ward 99 had the lowest employment level and the highest percentage of people occupying the lower annual household income categories (Figure 28).

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Table 8: Statistical profile of Ward 105, 99, 82 and 74 of Region E Category Ward 105 Ward 99 Ward 82 Ward 74 Total population 22 035 43 871 28 765 28 203 Number of households 7 126 13 965 8 157 10 220 Density (people per km2) 633 506 1 124 976 Female 50 45 51 53 Male 50 55 49 47 Black African 24 93 80 80 Coloured 2 6 18 1 Indian or Asian 3 0 0 0 White 70 1 2 18 0 - 18 25 32 32 26 18 - 64 68 67 65 69 Over 65 8 1 4 5 Born in South Africa 90.4 81.9 95.5 92.3 Born in Gauteng 67 39 78 61

Figure 25: Language profile

Figure 26: Education profile

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Figure 27: Household utilities

Figure 28: Employment and annual household income Local context

The MRA encompasses the boundaries of the farms Witpoortje 117 IR, Rooikraal 156 IR, Glen Roy 132 IR and Withok 131 IR and falls over wards 74, 82, 99 and 105. The largest formal residential area within the MRA is that of Geluksdal. This area is host to its own clinic, library, metro police station, municipality complex and sports field. To the north of Geluksdal is the industrial suburb of Laborê, which makes up the bulk of the area’s manufacturing capacity. Most of the land within the northern and eastern sections of the MRA comprise of farm plots, with mixed land uses such as residential, and small holding agricultural activities. Other surrounding residential areas include Tsakane to the south-east, Kwa-Thema to the east, Dawn Park to the west and Sonneveld, Minnebron and Sunair Park to the north (refer to Figure 29).

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Figure 29: Location of ERPM Ext. 2 relative to surrounding wards and existing and proposed residential areas

Visual Aesthetics

The following information was obtained from the Visual Imapct Assessment undertaken by Prime Resources in August 2019 (refer to Appendix 15).

The area is predominantly grassland, mining, plantation/woodlots, low shrubland and wetlands. There are distinct mining- related features that allow for a wide spectrum of users or viewers to recognise the areas, indicating that the areas have a strong mining sense of place. Dominating the south-eastern horizon from the proposed Windmill Shaft SDA is that of the Brakpan/Withok TSF, standing at a height that ranges from 50 to 70 m, and occupying a footprint of approximately 9 km2. This TSF obstructs a significant portion of the horizon.

The landscape quality of the surrounding MRA is considered to be moderate. The character of the MRA can be described as modified with some natural features such as scattered plantations, watercourses and associated wetlands interspersed with agriculture, grazing and historic mining features. The area is generally flat with a few low rolling hills and no dominant natural landscape features. The vegetation is consistent in type and colour. The area contains several artificial structures such as the Rooikraal Landfill Site, an unnaturally pink Calcine dump, various other large mine dumps (the Brakpan/Withok Tailings Storage Facility (TSF) and the Rooikraal TSF), chicken houses, powerlines and railway lines. The landscape quality of the proposed SDA is also considered to be low and it is therefore expected that the proposed surface infrastructure will have a low impact on the visual aesthetics as compared to other landscape features already present in the area.

Terrestrial Ecology

The following information was obtained from the Terrestrial Ecological Assessment conducted by Scientific Terrestrial Services in July 2019 (refer to Appendix 16).

A desktop study was undertaken where background data and digital satellite images were consulted in order to distinguish broad habitats, vegetation types and potentially sensitive sites. Subsequently, an on-site visual assessment was conducted

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on 9th May 2019 to confirm the assumptions made during the desktop study and to determine the ecological status of the habitat associated with the study area.

The study area falls within the Tsakane Clay Grassland in the Mesic Highveld Grassland Bioregion of the Grassland Biome. The ecosystem is currently poorly protected, which means that less than 50% of the biodiversity target has been met. Some sections of the Witpoortje Vent Shaft fall within the RE of the CR Kliprivier Highveld Grassland Ecosystem as per the National Threatened Ecosystems Database (2011). Additionally, the eastern portion of Witpoortje Vent Shaft is considered to be a CBA important for orange-listed plant habitat, red-listed bird habitat and primary vegetation. The western portion of the Vent Shaft is considered to be an ESA. The majority of the Witpoortje Vent Shaft (associated with the Kliprivier Highveld Grassland) as well as a portion of the eastern boundary of the Windmill Shaft are of Highest Biodiversity Importance (i.e. areas where mining is not legally prohibited or mining projects may be significantly constrained or may not receive necessary authorization). The eastern boundary and small portion of the southern boundary of the Witpoortje Vent Shaft is of Moderate Biodiversity Importance (i.e. ESAs, VU ecosystems and focus areas for protected area expansion) (refer to Figure 30 and Figure 31).

Floral Assessment

During the field assessment the Eragrostis chloromelas Grassland and the Secondary Grassland habitat units were identified. The latter is further subdivided into the Degraded Secondary Grassland and Hyparrhenia hirta Secondary Grassland.

Eragrostis chloromelas Grassland

This habitat unit is associated with the Witpoortje Vent Shaft, and has not been associated with historic ground clearing activities. However, edge effects associated with clearing activities in surrounding areas have resulted in the degradation of this habitat, mainly through the spread and establishment of alien invasive plants (AIP). Floral species of conservation concern (SCC) observed within this habitat unit include Eucomis autumnalis. This habitat unit also provides suitable habitat for the floral SCC Hypoxis hemerocallidea. These species are of Least Concern (LC) nationally, but are classified as Declining in Gauteng. The floral diversity of the habitat unit is considered to be moderately low. The grass layer was dominated by Eragrostis chloromelas, with several common, widespread grass species indigenous to the Tsakane Clay Grassland also observed, namely Eragrostis plana, Themeda triandra, Cynodon dactylon and Hyparrhenia hirta. The diversity of herbs within the habitat unit is also considered to be moderately low, however an assessment during the summer months may reveal a slightly higher herb diversity.

Secondary Grassland

This habitat has undergone extensive modification and a fundamental shift from its original state, but has been allowed to return to a ‘grassland’ state. Secondary grasslands look like primary grasslands, but differ in terms of species composition, vegetation structure, ecological functioning and ecosystem services. As such, two secondary grassland habitat units were noted within the study area:

Degraded Secondary Grassland

This secondary grassland habitat unit is associated with the Witpoortje Vent Shaft and likely formed as a result of earth moving activities within the area prior to 2008, as well as hardened infrastructure associated with the historic farmhouse. Although the area has been allowed to return to a vegetated state, historic disturbances are still evident on site. This habitat is also characterized by bare soils and AIP species. A single individual of the floral SCC Hypoxis hemerocallidea was observed within this habitat unit. The floral diversity is considered to be moderately low with domination by the grasses Aristida congesta subsp. congesta, Eragrostis chloromelas and Hyparrhenia hirta. The diversity of herbs is considered low, comprising of AIP species such as Verbena bonarieinsis, Gomprena celosioides and Tagetes minuta. The diversity of the woody component was, however moderately high with a number of AIP and garden ornamental trees observed such as Acacia decurrens, Acacia longifolia, Acacia podalyriifolia, Eucalyptus camaldulensis, Solanum mauritianum and Tipuana tipu amongst others. A few indigenous woody species were also observed, namely Gomphocarpus fruticosus, Seriphium plumosum, and Vachellia karroo.

Hyparrhenia hirta Secondary Grassland

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This secondary grassland habitat unit is associated with the Windmill Shaft. Digital satellite imagery between 2008 and 2010 shows that the Windmill Shaft was historically cultivated. The areas has not been cultivated since 2009, and has been allowed to return to a grassland state. Floral diversity for the habitat unit is considered to be moderately low. The grass layer was dominated by the grass Hyparrhenia hirta, often dominant in old cultivated fields, or areas associated with overgrazing. Other common grass species such as Aristida congesta subsp. congesta, Cynodon dactylon and Hyparrhenia tamba were also observed. The herbaceous layer was of limited diversity and abundance and comprised predominantly of AIP species such as Solanum elaeagnifolium, Tagetes minuta, and Schkuhria pinnata as well as the widespread indigenous species Helichrysum rugulosum and Hilliardiella oligocephala. The woody composition was limited to a single Searsia pyroides individual as well as a few individuals of the shrub Pollichia campestris.

Faunal Assessment

Faunal species observed within the habitat units described above were noted during the site assessment. The habitat units were assessed in terms of suitability for faunal species relating to food and water resources and overall habitat potential. This is discussed below:

Eragrostis chloromelas Grassland

This habitat unit is considered to be of intermediate importance and sensitivity. Due to no current or historical earthmoving activities being noted within this habitat, the overall habitat integrity was noted to be higher than the surrounding areas. The herbaceous layer has been subjected to grazing activities, but it was not considered significant enough to result in extensive habitat disturbance. Overall the Eragrostis chloromelas Grassland provides suitable habitat and food resources for several avifaunal, insect and small mammal species. It is further possible that small to medium size grazing mammals may also periodically utilise this area whilst foraging. No faunal SCC were observed during the site assessment, however it is considered possible that the faunal SCC Mystromys albicaudatus (White-tailed Mouse, EN) and Atelerix frontalis (Southern African Hedgehog, NT) may occur within this habitat.

Degraded Secondary Grassland

This habitat unit is considered to be of moderately low ecological importance and sensitivity for faunal species. It is associated with extensive historic earth moving activities that has resulted in the extensive loss of the topsoil and subsequently faunal habitat. Currently, the area has been left to naturally revegetate, however this has been slow due to the extent of the disturbance. As a result, the area is dominated by AIP species, with large tracts of bare soil still evident. The habitat is not capable of supporting a high diversity or abundance of faunal species, with many of the species observed being that of common and widespread insects, avifauna and small reptiles. No faunal SCC were observed during the assessment, however Mystromys albicaudatus (White-tailed Mouse, EN) and Atelerix frontalis (Southern African Hedgehog, NT) may forage within this habitat periodically as they move across from the neighbouring Eragrostis chloromelas Grassland in search for food.

Hyparrhenia hirta Secondary Grassland

This area is dominated by the grass Hyparrhenia hirta, and is associated with historical cultivation activities which appear to have ceased approximately 10 years ago. This has resulted in a predominantly homogenous grass cover, of which large areas are harvested by local community members. Consequently, the faunal diversity is considered limited and restricted to the more common and widespread species that are often found in disturbed areas and habitats in close proximity to urban zones. No faunal SCC were observed during the site assessment. Although no signs of Atelerix frontalis (Southern African Hedgehog, NT) were observed within the study area, it remains a possibility that this species may utilise both the study area and larger surrounding areas.

Reports of the African Grass Owl (Tyto capensis) residing within the vicinity of the proposed Witpoortje Vent Shaft were received during the public participation process. In South Africa the species is considered to be vulnerable with the population estimated to consist of less than 5 000 individuals. Preferred habitat includes patches of tall, rank grass, sedges or weeds. These dense patches of vegetation are utilised by the birds for roosting and nesting, often close to wetlands. The nests, located on the ground, are susceptible to predation, trampling by grazing animals, and fires. The African Grass Owl breeds

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in autumn and early winter (peaking March – April), when the grass cover is at its thickest, rainfall at its highest and rodent populations at their largest. Incorrect burning practices, specifically the burning of veld at the incorrect time of the year when Grass Owls are breeding, lead to the failure of many nesting attempts. Overgrazing and trampling of remnant grassland patches may lead to low reproductive success as well as abandonment of territories. Risks to the species also result from habitat degradation and vehicle strikes.

The area is also associated with giant bullfrogs (Pyxicephalus adspersus) which are listed as protected in the list of Critically Endangered, Endangered, Vulnerable and Protected Species (GNR151 of 2007, as amended) in terms of the National Environmental Management: Biodiversity Act, 2004. Although bullfrogs require grassland habitats for foraging they are more associated with pans, wetlands and other aquatic systems.

Figure 30: Ecosystem types of the project area

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Figure 31: Vegetation types of the project area

Aquatic Ecology and Wetlands

The following information was obtained from the Freshwater Ecological Assessment conducted by Scientific Aquatic Services in June 2019 (refer to Appendix 17).

Initially, Scientific Aquatic Services undertook a desktop study where various notational and provincial databases were consulted. This was followed by an on-site assessment and watercourse delineation, which was undertaken on 9th May 2019. The investigated area extended 500 m beyond the proposed mining infrastructure in order to identify wetland habitat that may be affected by the project in accordance with Government Notice (GN) 509 of 2016 as it relates to the NWA.

The project area is located within the Highveld Ecoregion, and the C22C quaternary catchment of the Vaal catchment. A Channelled Valley Bottom (CVB) wetland was identified within the investigation area of the Witpoortje Vent Shaft (Figure 32), and a Hillslope Seep (HSS) wetland was identified within the investigation area of the Windmill Shaft (Figure 33). In addition to the two wetlands, the Rietspruit River exists approximately 1.1 km southeast of the Windmill Shaft, however no National Freshwater Ecosystem Priority Areas (NFEPA) rivers exist within the project area.

Channelled Valley Bottom wetland

A Channelled Valley Bottom (CVB) is a valley-bottom wetland with a river channel running through it. The CVB wetland, associated with the Witpoortje Vent Shaft, is located within the eastern and southern portions of the investigation area and drains in a south westerly direction towards an unnamed tributary of the Rietspruit River.

The wetland is primarily hydrologically driven by overland flow from the greater catchment. The hydrological regime of the wetland has been largely modified as a result of:

 Modifications to the active channel by the construction of artificial instream impoundments, including a trench that has been excavated along the north western boundary of the wetland, concentrating the flow of water and resulting in erosion;

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 Increased water inputs from altered runoff patterns in the greater catchment due to the extensive mining activities in the area, some of which traverse the wetland; and  The construction of informal and municipal road and pipeline crossings which have altered flow patterns.

The wetland vegetation community is considered to be modified due to proliferation of alien and invasive plant species within the permanent, seasonal and temporary zones of the wetland. Despite these modifications to the vegetation community, the wetland is well vegetated with various indigenous species such as Phragmites australis, which plays an important ecological role for wetlands as it offers shelter and nesting material for birds and other faunal species. According to the Gauteng C-Plan (2011), the CVB wetland is situated within a CBA considered important for “Orange” listed plant habitat, “Red” listed bird habitat and for primary vegetation.

The PES category of the wetland is D (Largely modified) the hydrological processes and vegetation of the wetland have undergone alteration due to extensive historical and current and mining activities. Informal and municipal road and pipeline crossings have resulted in soil disturbances, and the proliferation of alien invasive plant species.

Ecoservice provision was rated as intermediate. Although ecological integrity of the CVB wetland is significantly decreased, the wetland still provides an intermediate to moderately high level of ecoservices such as streamflow regulation, erosion control and the assimilation of nitrates, phosphates and toxicants. This is primarily due to characteristics of the wetland such as moderately high surface roughness (extensive vegetation cover) which aid in the provision of these services.

The EIS category of the wetland is C (Moderate). This is due to the hydro-functional importance of the system which has the ability to regulate streamflow, assimilate nitrates, phosphates and toxins, and erosion control.

In terms of the water quality, pH of 7.48; electrical conductivity (EC) of 207 mS/m and a temperature of 12.6 °C was recorded. The pH fell within the ideal range limit, whereas EC fell within the unacceptable range limit (According to the Resource Water Quality Objectives (RWQO) of South Africa (DWA, 2011)). The water quality is indicative of impacts on the system.

The historic construction of artificial impoundments within the active channel of the wetland, as well as infilling and excavation related to mining activities, have impacted on the geomorphological processes of the wetland. Increased water inputs, and thus increased sediment inputs, arising from the road infrastructure that traverse the system has likely resulted in greater sediment loads within the wetland.

Hillslope Seep wetland

A Hillslope Seep (HSS) wetland is a wetland area located on (gently to steeply) sloping land, dominated by the colluvial (i.e. gravity-driven), unidirectional movement of material down-slope. Seeps are often located on the side-slopes of a valley, but they do not, typically, extend into a valley floor. The HSS wetland associated with the Windmill Shaft is located along the northern boundary of the investigation area, outside the proposed infrastructure footprint, and drains in a northerly direction.

The PES category of the wetland is C (Moderately modified). The HSS wetland has been impacted on by informal farm roads which traverse the wetland, and historical and current agricultural activities within the greater catchment.

The ecoservice provision was rated as moderately low due to its decreased ecological integrity. However, some ecoservices such as erosion control and streamflow regulation are provided.

The EIS category of the wetland is D (Low/marginal). The wetland is not considered important in terms of direct human benefits. However, it is considered of low/marginal hydro-functional importance. No surface water was present from which water quality parameters could be measured.

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Figure 32: CVB wetland near the Witpoortje Vent Shaft SDA

Figure 33: HSS wetland near the Windmill Shaft SDA

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Hydropedology

The following information was obtained from the Hydropedological Assessment conducted by Scientific Aquatic Services in July 2019 (refer to Appendix 18).

The assessment was undertaken to investigate the hydropedological properties of the soils in the vicinity of the wetland systems in order to infer the potential recharge mechanisms and destination of the transferred water present in the soils. The aquatic study (discussed above identified two wetland associated with the SDAs.

The Witpoortje Vent Shaft SDA is dominated by soil types regarded as responsive shallow. These soils have limited storage capacity which results in the generation of overland flow after rain events. These soils lead to a rapid runoff response time during intense rainfall events attributed to their shallow nature which inhibits infiltration. The contribution of these soils to wetland recharge is significant during a rainfall event and minimal during drier seasons.

The Windmill Shaft SDA supports responsive shallow soils as well as recharge soils that are characterised by absence of any morphological indication of saturation and are typically associated with deep freely drained soils. The dominant hydropedological pathway for these soils is vertical through and out the profile into the underlying bedrock, recharging groundwater.

Traffic

The following information was obtained from the Traffic Baseline Study and Impact Assessment undertaken by Merchelle’s Collective (Pty) Ltd in July 2019 (refer to Appendix 19).

The proposed underground mine area extends from Barry Marais Road eastwards across Heidelberg Road and towards the Tsakane informal settlement. The Windmill Shaft is to be located to the western limits of the project site, just off Barry Marais Road. The Witpoortje Vent Shaft is located just after the dog leg bend on Koot Street which then becomes Denne Road.

Traffic surveys were undertaken at four intersections:

 R23 Heidelberg Rd and R550 (Springs Rd) – critical junction connecting the site to potential labour source in Tsakane;  R550 (Springs Rd) and unnamed farm access road (Road A) – alternative access to Windmill Shaft from the south;  Barry Marais Rd and Road A/Camora Street – main access to Windmill Shaft;  Barry Marais Rd and R21 Rondebult Rd – critical junction connecting the site to potential labour source in Vosloorus and access from the north; and  Road B – staggered leg of the above junction and provides access from Villa Liza.

The surveys were conducted on Wednesday, 15th May 2019, covering a 12-hour period from 06h00 to 18h00. The surveys consisted of classified, turning movement volume counts. The vehicles recorded were identified as light, minibus-taxi, bus and heavy vehicles per direction in 15-minute intervals.

It was found that Barry Marais Rd carries relatively low traffic volumes, given that most of the population in this region depends on public transport. During the morning peak hour, the main direction of flow is northwards towards work opportunities in the CBDs of Boksburg and Benoni. The afternoon peak reflects commuter traffic returning to the residential areas of Vosloorus and Thokoza. The traffic volumes indicate a minimal percentage of heavy vehicles, being in the region of 2%. The latter indicates the low level of industrialisation and manufacturing land uses in the area. All roads leading to the mine sites are in good condition with recent and current upgrades with asphalt. Road A/Camora Road, the access road to the Windmill Shaft, is an informal gravel road of poor condition. The road is seldom utilised and has overland pipes running along its left-hand side.

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(b) Description of the current land uses

Various planning tools are available for South Africa, Gauteng and the CoE. These tools use GIS data to streamline decision making by assisting in the identification of the current land uses and zoning different areas for various activities. These activities and zones for the proposed SDAs are identified in Table 9 below.

Table 9: Current and planned land use for the SDAs Description Source Windmill Shaft Witpoortje Vent Shaft As confirmed during a site Land use Grazing Disturbed from previous mining operations visit in February 2019 Zone 3: High Control (outside Zone 1) Zone 4: Normal Control This zone is considered sensitive to development Land use GPEMF, 2015 The intention of Zone 4 is the activities and may also have specific values that need promotion of rural development to be protected. Therefore, conservation and related planning that supports agricultural uses tourism and recreation activities are promoted in this tools zone CoE Spatial Development Urban Development Open Space Framework Zoning CoE GIS Website Agriculture Agriculture

Within the MRA there are a variety of land uses ranging from industry, smallholding agriculture, residential as well a landfill site. Within the proposed surface infrastructure area there is a fragmented wetland as well as grazing land used by the local community.

Substation and mobile generator, Portion 35 Witpoortje 117 Dirt road, pipeline and railway line, adjacent to the site

Grazing activities taking place within the Windmill Shaft SDA Eggbert Eggs, Maye Serobe, laying farm, Hamilton Road Rooikraal 156 IR

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Calcine Dump, south of Witpoortje Vent Shaft SDA Mine dump, north of the Calcine Dump

Geluksdal cemetery, located south of the MRA (Withok 131 IR Pipline and dirtroad, corner of Koot Street and Denne Road, near 1615 Geluksdal Ext 1.) the Witpoortje Vent Shaft SDA

Pipline and vegetation on the corner of Koot Street and Denne Road, near the Witpoortje Vent Shaft SDA

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(d) Environmental and current land use map (all environmental, and current land use features)

Figure 34. Location of ERPM Ext. 2 Mine relative to surrounding environmental and current land use features ii) Impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts CAN BE MITIGATED (Provide a list of the potential impacts identified of the activities described in the initial site layout that will be undertaken, as informed by both the typical known impacts of such activities, and as informed by the consultations with affected parties together with the significance, probability, and duration of the impacts. Please indicate the extent to which they can be reversed, the extent to which they may cause irreplaceable loss of resources, and can be avoided, managed or mitigated)

The list below provides a high-level summary and explanation of the risks and impacts that are expected as a result of the project. As far as possible the impact descriptions have been non-technical. For a detailed assessment of the impacts identified see Table 10 and the Impact Assessment Report in Appendix 20. The discussion below focusses largely on the pre-mitigation impact significance, with a comment as to whether the proposed recommendation measures will reduce the significance rating.

Air quality

Coarse Fraction Dust

Coarse fraction dust is the dust that will settle out of the air relatively quickly. Use of the access roads to the SDAs and other activities such as site and vegetation clearing, topsoil handling and the development of the shafts, including blasting and excavations are expected to result in the generation of nuisance dust, which may be experienced by people living near the

project. Dust has a particle size of > 10 microns (PM10) therefore, it is not expected to have a health impact. Fugitive dust is visible and will be nuisance when deposited on objects near the project. If very high rates of dust fallout occur the growth of plants may be affected.

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 Nature: Negative  Consequence: Moderate. The extent of the nuisance impact is dependent on wind speed and direction however it is expected that it will remain a local impact. The duration will continue throughout the life of mine, and will cease when the activities cease, assuming that rehabilitation is effective.  Probability: The probability for nuisance dust to be generated is definite.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to possible, reducing the significance to Low.

Particulate matter < 10 microns (PM10 and PM2.5)

Particulate matter (PM) suspended in the atmosphere with particle sizes of less than 10 microns is inhalable and may cause considerable health problems. This PM is generated by the same processes as the Coarse Dust Fraction (mineral dust) but

may also be generated from exhaust systems and smoke. PM10 and PM2.5 present as smog and only the larger fraction settles out of the atmosphere. A number of health effects (human and animals) have been associated with inhaling fine particulates. Similarly, these fine particulates may clog the stomata in plants leading to poor plant growth.

 Nature: Negative  Consequence: Substantial. The extent of the health impact is dependent on wind speed and direction however it is expected that it will remain a local impact. The duration will continue throughout the life of mine, and will cease when the activities cease  Probability: The probability for fine particulates to be generated and impact on human health is possible.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Volatile organic carbons (VOCs), SO2 and NO2 emissions

VOCs, NOx and SOx emissions generally originate from the burning of fossil fuels and in the mining sector these can be a

result of vehicle exhaust gases (trackless mining equipment) and the generation of electricity. VOCs, NOx and SOx are pollutants which can cause irritation and health issues and be precursors to acid rain. It is expected that these emissions will be released from the underground mine via the Witpoortje vent shaft.

 Nature: Negative  Consequence: Substantial. The extent of the health impact is dependent on wind speed and direction however it is expected that it will remain a local impact. The duration will continue throughout the life of mine, and will cease when the activities cease  Probability: The probability for emissions to be generated and impact on human health is unlikely.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Noise and vibrations

Noise

The noise that is expected to be generated from the project will be nuisance noise from the operation of machinery, equipment and vehicles. It is likely that it would impact on people living close to the SDAs, especially during the construction phase. During the operational phase noise associated with the commuting of workers to and from the Windmill Shaft SDA will be produced. It is expected that the operation of the shaft headgears, winders and fans for the ventilation shaft are expected to produce noise.

 Nature: Negative  Consequence: Moderate. The extent of the nuisance impact is local. The duration will continue throughout the life of mine, and will cease when the activities cease.  Probability: The probability for nuisance noise to be generated is definite.

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 Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to probable, reducing the significance to Low.

Blasting and vibrations

Blasting produces ground vibration, air blast and fly rock which can all be dangerous. Fly rock may directly injure people and animals. Air blast and vibration can have a negative effect on infrastructure, causing cracking and possible collapse. Air blast will be perceptible only for the first 3 - 4 blasts as the shafts are constructed. People and animals within approximately 500 m of the blasting may be startled.

 Nature: Negative  Consequence: Substantial. It is expected that extent of the potential damaging impacts of blasting will be local and occur during the construction phase only.  Probability: The probability for damage to result from blasting is unlikely.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to highly unlikely, reducing the significance to Low.

Soil and land use

Soil is needed for the establishment of plants which in turn support land uses like agriculture and livestock grazing. Soil may be lost directly by constructing infrastructure on top of the soil, poor management of soil stockpiles, or by poor site management resulting in erosion. The integrity of the soil may also be diminished if the soil is contaminated.

 Nature: Negative  Consequence: Substantial. The extent of the loss of soil will be limited to the site and the duration is considered permanent.  Probability: The probability of soil loss occurring is definite.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Archaeology, palaeontology, heritage

Graves were identified in the vicinity of the Witpoortje Vent Shaft SDA. These graves will have to be conserved either through protecting them in-situ or through exhumation, relocation and reinternment.

 Nature: Negative  Consequence: Substantial. The extent of the damage to grave sites or other heritage resources will be limited to local and the duration is considered permanent.  Probability: The probability of damage to heritage resources is unlikely.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Hydrology

Discharge of excess water

The quantity of water in the catchment (contributing to stream flow) may increase should there be a need to discharge excess water to surface.

 Nature: Negative  Consequence: Substantial. It is currently not anticipated that discharge will be undertaken and as such the impact has not been fully assessed. However, should this unforeseen impact occur it will result in changes to the downstream environment of the natural watercourses, in both quantity and quality of the water. Should it occur, it is likely to extend from construction through to decommissioning. The mine has planned for a treatment facility should discharge be required.

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 Probability: Due to the lack of detailed assessment, the probability of discharge occurring is considered probable (precautionary principle).  Significance: The significance is Moderate before and after the implementation of mitigation measures.

Surface water quality

A decrease in water quality in the surrounding surface water systems may occur as a result of contamination by hazardous chemicals and runoff from the WRD.

 Nature: Negative  Consequence: Moderate. Contaminated runoff will be limited to the areas downstream of the mine and will occur throughout the life of mine.  Probability: The probability of contaminated runoff leaving the site and contaminating surface water is possible.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to Unlikely, reducing the significance to Low.

Decant of contaminated groundwater post-closure

Post closure, there is a risk that contaminated groundwater will decant and spill into the surrounding water courses.

 Nature: Negative  Consequence: Severe. The extent of decant is unknown as the possible decant locations are currently unknown. It is expected that the decant positions will be contained within the MRA. Should decant occur, it is likely to continue permanently.  Probability: The probability of decant occurring is currently unknown and therefore considered to be probable (precautionary principle).  Significance: The significance of decant occurring is considered High prior to and with mitigation.

Geohydrology

Groundwater quantity

The void from mining excavations is kept dry through the practice of dewatering where the mine pumps the groundwater out of the surrounding aquifers faster than it can flow in. Dewatering of the upper aquifers drops the level of the groundwater in the immediate area which may affect the supply of groundwater to nearby boreholes as well as groundwater fed rivers and wetlands. This project is expected to have very deep excavations (about 2500 m) and the surface aquifers (active or fractured rock aquifers) will only be affected in the first 100 m during the sinking of the shaft, after which the groundwater levels are expected to return to pre-development levels.

The connectedness of the surface and the deep aquifers is unknown and there is a risk that dewatering of the deep aquifers may result in the dewatering of the surface aquifers.

 Nature: Negative  Consequence: Moderate. Drawdown of groundwater levels in the immediately vicinity of Windmill shaft is not expected to affect any surrounding privately-owned boreholes and is only expected to occur during the first 100m of shaft construction. Should there be a connection between the upper and deep aquifers, the consequence will increase to substantial.  Probability: The probability of drawdown affecting groundwater users or rivers / wetlands is possible. The unknown interconnectedness between the upper and deep aquifers increases the possibility to probable (precautionary principle).  Significance: Significance: The significance is Moderate before and after mitigation.

Generation of Acid Mine Drainage

During operation the dewatering of the underground area will draw mineral-derived contaminants towards the working areas. When the mine is decommissioned it expected that the mining area will slowly be flooded. As the working areas and shafts

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are flooded, contaminants in the water will be mobilised and form acid mine water. This impact depends on the geology, aquifer characteristics and the interconnectivity of the various mines.

 Nature: Negative  Consequence: Substantial. The generation of AMD is expected to extend beyond the boundaries of the MRA over time. The duration of this impact is considered permanent.  Probability: The probability of AMD generation is probable (precautionary principle).  Significance: The significance is Moderate before and after the implementation of mitigation measures.

Socio-economic factors

Employment and stimulation of the local economy

It is estimated that the mine will create at least 976 employment opportunities. The jobs will likely be unskilled and semi-skilled jobs. The mine will provide increased opportunities for Small, Medium and Micro Enterprises (SMMEs) and stimulation of growth in the local area to provide goods and services to the mine and its employees.

 Nature: Positive  Consequence: Severe. The extent of the benefits of employment and SMME opportunities will be felt beyond the boundaries of the MRA, possibly regionally, and will continue for the life of mine and possibly beyond.  Probability: The probability of employment benefits is definite.  Significance: The significance of the impact is considered to be High before and after mitigation.

Downscaling and retrenchment at decommissioning and closure

Once the mine closes, there will be a loss of employment.

 Nature: Negative  Consequence: Severe. The extent of the negative impacts of retrenchment will be felt by employees and their families, possibly beyond the MRA after closure.  Probability: The probability of the negative impacts is considered to be definite.  Significance: The significance of the impact is considered to be High prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Substantial, reducing the significance to Moderate.

In-migration of job-seekers

In-migration of job-seekers into the project area could potentially result in the establishment or expansion of informal settlements, and associated increase in social ills (including crime), and decreased safety and security of residents in both the smallholding residential areas and the high-density areas surrounding the proposed development.

 Nature: Negative  Consequence: Substantial. The extent of in-migration is unlikely to extend beyond the boundaries of the SDAs but is likely to be permanent. It is anticipated that the predicted associated impacts related to informal settlements and social ills will manifest along with in-migration.  Probability: With the probability of in-migration being unknown, a probability of probable has been selected (precautionary principle).  Significance: The significance of the impact is considered to be High before and after mitigation.

Visual Aesthetics

The shaft headgears will be approximately 50 m high and therefore visible to the surrounding area. The WRD is also to remain on-site permanently at the Windmill Shaft SDA. These will result in a change to the visual character of the landscape. Lighting at night may fundamentally change the appearance of the area at night and may be a nuisance to people near to the mine.

 Nature: Negative

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 Consequence: Moderate. The impact of visual intrusion is considered to be a nuisance (largely the night time lighting) but is not expected to extend beyond the local area although the head gears may be visible from further away. The visual intrusion impact will be permanent but have a small footprint.  Probability: The probability of visual intrusion is definite.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Slight, reducing the significance to Low.

Biodiversity

Flora

Clearing during construction will lead to the direct loss of individual plants and grassland habitat. There are individuals of taxa of conservation concern in the area that may be lost however, these are not considered rare or endangered. It is possible that invasive species will flourish in the disturbed areas around the SDAs leading to a further loss of habitat. The influx of people to the area may collect wood, disturbing trees and other woody plants.

 Nature: Negative  Consequence: Moderate. The loss of vegetation and habitat for species of conservation concern will be restricted to the SDAs but the impact will be felt permanently, and the collection of firewood may continue throughout the life of mine.  Probability: The probability of the loss of vegetation is definite.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to Probable, reducing the significance to Low.

Fauna

Loss of fauna and faunal habitat is expected to occur during the construction phase. Although many individual animals are able to move away from construction areas, fossorial animals may be destroyed in their burrows. The SDAs do contain habitat which may support taxa of concern.

 Nature: Negative  Consequence: Substantial. The loss of certain fauna would be restricted to the site (most animals would leave) and the impact would be felt throughout the life of mine but possibly would cease at closure when animals may move back into the area.  Probability: The probability of a loss of animal species is possible.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Aquatic Ecosystems

Aquatic ecosystems may be affected due to direct disturbance or through contaminated (chemical and silt) runoff entering the watercourses.

 Nature: Negative  Consequence: Moderate. The possible contamination of aquatic ecosystems will be local and will occur intermittently throughout the life of the mine.  Probability: The probability of contamination occurring is possible.  Significance: The significance is Low prior to and with mitigation.

Increase in surface water flow

The quantity of water in the catchment (contributing to stream flow) may increase as a result of discharge of excess mine water.

 Nature: Negative

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 Consequence: Substantial. The increase of water in the catchment is likely to be felt locally and possibly beyond, for the duration of the life of mine.  Probability: The probability is currently unknown and therefore considered probable (precautionary principle).  Significance: The significance is Moderate prior to and with mitigation.

Traffic

The construction and operation of the mine will increase the volume of traffic in the surrounding area. Apart from being a nuisance to people living in the area, the increased volume may lead to a decrease in road safety and a deterioration of the road surface.

 Nature: Negative  Consequence: Moderate. The nuisance impact of additional traffic will be local and limited to the road network used to access the mine. The impact will occur throughout the life of the mine.  Probability: The probability of nuisance traffic and potentially additional road safety concerns is probable.  Significance: The significance of the impact is considered to be Low before and after mitigation. iii) Methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks; (Describe how the significance, probability, and duration of the aforesaid identified impacts that were identified through the consultation process was determined in order to decide the extent to which the initial site layout needs revision).

Specialists were appointed to identify potential impacts of the project (refer to Table 11 the list of specialist reports that informed the EIA process), and to rank the impacts to determine significance. iv) The positive and negative impacts

All impacts raised by IAPs were also identified by the specialists have been addressed in Section 3.g.iii). v) The possible mitigation measures

Mitigation measures are listed in Table 10. vi) Motivation where no alternative sites were considered

No alternative sites were assessed. The location of the Windmill Shaft SDA was selected based on a number of factors, including the fact that the mineral resources beneath this site are considered to be of a low grade and locating the vertical shaft complex here would ensure that the shaft pillar does not sterilise any mineral resource. Similarly, no sites were identified to considerably mitigate impacts to the social or biophysical environment. The Witpoortje Vent Shaft is an existing shaft to be refurbished. vii) Statement motivating the alternative development location within the overall site (Provide a statement motivating the final site layout that is proposed)

Alternatives were assessed during the Scoping Phase resulting in the layouts selected to be further assessed during the EIA phase. Specialists assessed the potential impacts of the layouts and from the findings of the assessments no alternatives were recommended. b) Full description of the process undertaken to identify, assess and rank the impacts and risks the activity will impose on the preferred site (In respect of the final site layout plan through the life of the activity. Including (i) a description of all environmental issues and risks that were identified during the environmental impact assessment process and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures)

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An adapted risk assessment methodology was used to determine the significance of the potential impacts of the preferred final layout on the surrounding biophysical and socio-economic environment. The methodology determines consequence and probability, and identifies a relative significance or risk of the potential impact.

The following risk assessment model has been used for determination of the significance of impacts.

Consequence Extreme Human health morbidity /mortality. Loss of species Severe Materially reduced fauna / flora populations, loss of livelihoods, individual economic loss Substantial Material reduction in environmental quality – air, soil, water, habitat, loss of heritage Moderate Nuisance Slight Negative change – with no other consequences

Probability 1 Highly unlikely 2 Unlikely 3 Possible 4 Probable 5 Definite Significance Extreme Moderate High High Fatally flawed Fatally flawed

Severe Low Moderate High High High Substantial Low Moderate Moderate Moderate Moderate Moderate Low Low Low Low Moderate

Consequence Slight Low Low Low Low Low Highly unlikely Unlikely Possible Probable Definite Probability

Fatally flawed Unacceptable level of risk High Requires strict conditions and high levels of compliance and enforcement Moderate Requires conditions and routine inspections Low Little risk of environmental degradation

Impacts of the proposed surface infrastructure and activities associated with the ERPM Ext 2 Mine (refer to Figure 5 and Figure 7) were identified by the relevant independent specialist commissioned for the project, who provided this information to the EAP through the submission of an impact assessment report.

Specialists undertook their own risk assessments for the projects and these were adapted as necessary and incorporated into the impact assessment. Refer to Section 3.ii). for the list of potential impacts identified, and refer to Appendix 20 for the detailed assessment of their significance and the extent to which they can be mitigated. c) Assessment of each identified potentially significant impact and risk (This section of the report must consider all the known typical impacts of each of the activities (including those that could or should have been identified by knowledgeable persons) and not only those that were raised by registered interested and affected parties - the supporting impact assessment conducted by the EAP must be attached as an appendix)

Refer to Table 10 and Appendix 20 for the detailed impact assessment compiled by the EAP, informed by specialist input.

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Table 10: Assessment of potentially significant risks Post-Mitigation Significance Activity Impact Phase Mitigation Significance Rating Rating Air quality  Access roads  Increased vehicle trips generated by the mine  Dampening dust generating surfaces  Site clearing, including the  Applying dust palliatives removal of vegetation and topsoil Nuisance dust emissions  Protecting stockpiles and cleared areas from wind by establishing vegetation  Development of the shaft, Moderate Low towards sensitive receptors or installing windbreaks as necessary including blasting and excavations  Erecting screens around initial blast areas, cover further blasts so that dust  Management of topsoil, settles within the shafts. overburden and waste rock stockpiles Construction  Earthworks during rehabilitation. Operation  Use, storage and handling of Fine particulate matter Decommissioning hazardous chemicals and fuel  Choosing low sulphur diesel for vehicles and machines emissions towards sensitive  Underground activities (including Moderate  Developing a storage and handling plan for the chemicals and fuels to be Low receptors (with potential combustion vehicles) emitting used, ensuring the legal storage of chemical and fuels, and implementing an health impacts) gases through the vent shafts emergency response plan for spills and fires, and training users  Use of internal combustion  Equipping shafts with filters if monitoring results reveal that filters are

vehicles and equipment Emission of NO2, SO2 CO2 necessary to remove pollutants  Use, storage and handling of and BTEX released to the  Making use of mass transport to reduce the number of vehicles Moderate Low hazardous chemicals and fuels atmosphere (with potential  Choosing efficient vehicles and machinery and keeping them in good  Underground activities health impacts) operating condition.  Increased vehicle trips Blasting, noise and vibrations Ground vibration, air blast, fly rock - with the potential to The effects of air blast may be mitigated by covering the first three to four blasts. cause damage to  Blasting to sink shaft Construction Moderate All residents in the area must be made aware of the blasting programme and Low infrastructure, and pose a safe evacuation distances for people and animals (livestock). danger to people and animals  Restrict deliveries to the SDA to day-time hours only  Impose reduced speed limits  Vehicles on access roads  Ensure that all vehicles that access the SDA are in good condition and  Use of equipment and machinery compliant with manufacturers specifications. on site, including reverse beepers Increased noise levels on Construction  Ensuring that construction activities, blasting and rock breaking, demolition  Shaft headgears, winders, site and at adjacent Operation Moderate Low and waste rock management do not occur at night ventilation fans residential property Decommissioning  Maintaining earth moving equipment to ensure compliance with manufacturers  Drilling and blasting specifications  Deposition on WRD  Liaising closely with landowners and if required, implementing acoustic screening between the SDA and residents

ERPM Ext 2 Mine, East Rand, Gauteng 129 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Post-Mitigation Significance Activity Impact Phase Mitigation Significance Rating Rating  Ensuring that drill rigs are in good working condition and muffled where possible  Developing a blasting plan that includes consultation with affected receptors  Training drivers not to over-rev engines, turning off engines when standing for long periods, muffling engines as per manufacturers specifications, servicing vehicles regularly  Designing internal roads for continuous flow to avoid unnecessary reversing.  Minimise the noise level of audible warning devices for the health and safety of employees  Selecting the lower noise producing equipment and ensuring that equipment includes silencers or mufflers were available. Soil and land use  Keeping the infrastructure footprint and the area of disturbance as small as  Vegetation clearing and grubbing possible  Stripping and subsoil stockpiling  Forbidding the use of stockpiled soil for construction  Construction of surface  Identifying locations for soil stockpiles where they will not be disturbed during infrastructure and roads the operational life of the project  Excessive stormwater run-off from  Contractually committing contractors and subcontractors to the Soil constructed hardstanding areas Construction Loss of soil (including soil Management Plan and roads, and within the mining Operation erosion) leading to loss land Moderate  Implementing and maintaining stormwater management measures (such as Low footprint Decommissioning use potential installing erosion control measures)  Removal of surface infrastructure, Closure  Restricting activities to the demarcated areas access roads, etc.  Restricting the height of the topsoil stockpiles to 4 – 5 m  Excessive stormwater runoff from  Vegetating stockpile sides and exposed soils with locally adapted perennial or newly rehabilitated areas which annual grass seed mixtures have not been vegetated or  Implementing an appropriate fertilizer programme if re-vegetation is slow, and vegetation has not re-established stabilising erosion-sensitive areas.  Implementing a Hydrocarbon Management Plan which addresses storage and handling of hydrocarbons  Cleaning up spillages of hazardous material Potential leaks and spills of Construction  Employing good waste management and housekeeping practices chemicals such as hydrocarbons, Soil contamination Operation Moderate  Managing contaminated soil appropriately (remediation or disposal) Low hazardous chemicals and cement. Decommissioning  Ensuring that cement storage and batching occurs on an impermeable surface.  A soil contamination assessment must be carried out at mine closure and remediation measures implemented.  Strategic, planned stockpiling, using the soil stripping guideline presented in Stripping and stockpiling of topsoil Reduced soil quality the Soil and Land Use Survey, ensuring that soil stripping occurs during the and subsoil and other site activities resulting in reduced potential Construction Moderate dry winter months (or ensure that soil is reasonably dry), and effective Low including heavy vehicles and earth for vegetation establishment Operation stockpile management. moving machinery on site and rehabilitation  Soil contamination assessment must be carried out after stockpiling.

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Post-Mitigation Significance Activity Impact Phase Mitigation Significance Rating Rating  Implementing the measures described in the Final Rehabilitation Ineffective rehabilitation and further Sites are incompatible with Decommissioning and Closure Plan Post-closure Moderate Low degradation of soil quality future land use  Appropriate remedial measures as advised by an appropriately qualified contamination specialist Archaeology and Palaeontology Potential damage to  A chance finds procedure shall be implemented archaeological and  Fencing the grave site area and developing a management plan for the Project activities Construction Moderate Low paleontological artefacts and sustainable preservation thereof, or the remains could be exhumed and desecration of graves relocated and reinterred Hydrology Dewatering of the shaft and mining Loss of surface water and Construction  Sealing off individual high yielding inflow zones intercepted during excavation resulting in localised groundwater Low Low wetland volumes Operation and mining drawdown Construction Discharge of surplus underground Contamination of surface  Treatment of water before it is discharged Operation Moderate Moderate water water  Grouting ingress points into the mine Closure Construction  Installing appropriate pollution control dams and clean and dirty water Contamination of surface Contaminated runoff from site Operation Moderate separation Low water resources Closure  WRD should be designed and managed to control contaminated runoff Contamination of surface  Develop a numerical groundwater model within five years of operations (and water, damage to aquatic life updating it every five years) and planning discharge options for decant water Water decanting from mine after Closure in streams, and degradation High at least 10 years prior to closure High closure Post-closure of the Vaal River water  Ensuring that a suitable water use is identified for the treated water quality  Managing the groundwater levels through pumping and treatment plants Geohydrology

 Seal off individual high yielding inflow zones intercepted during excavation. Pumping of water to surface to Loss of groundwater Construction Moderate  Develop groundwater model to determine potential linkages between upper Moderate ensure dry working conditions. volumes in upper aquifer Operation and deeper aquifers

Construction  Appropriate water and hazardous chemical management Seepage from WRD, topsoil Contamination of Operation Moderate  Seal off individual high yielding inflow zones Low stockpile and mining area groundwater Closure  Appropriately lining the stockpiles to limit seepage

 Develop a numerical groundwater model within five years of operations (and updating it every five years) and planning discharge options for decant water Contamination of Closure at least 10 years prior to closure Generation of Acid Mine Drainage Moderate Moderate groundwater Post-closure  Ensure that a suitable water use is identified for the treated water  Managing the groundwater levels through pumping and treatment plants

Social

ERPM Ext 2 Mine, East Rand, Gauteng 131 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Post-Mitigation Significance Activity Impact Phase Mitigation Significance Rating Rating  Prioritize persons with requisite skills from the surrounding areas for employment opportunities  Employment  Maximising the potential benefits to the local economy by ensuring that that  Increased opportunities local labour and service providers are utilized wherever possible for SMMEs and  Implement a Stakeholder Engagement Plan to allow communication of the stimulation of the local Construction High Positive recruitment process with community members High Positive economy Operation  Identify suitable HDSA and locally based companies to provide local  Skills development for procurement to the mine Employment opportunities and employees and  Implement the Procurement Progression Plan detailed in the SLP Implementation of the SDP community members  Encourage employees that are not resident in the area to rent accommodation locally  Provide employees with transportation into and out of the mine area Establishment or expansion  Maintain consultation with the CoE regarding the monitoring of informal of informal settlements, and Construction settlement creation High High associated increase in social Operation  Encourage contractors to provide transport for their employees, ensure that ills (including crime) recruitment is not conducted at the mine gate  Ensure that mine security patrols the perimeter areas  Negative economic impact on agricultural smallholdings within the  Implement the mitigation measures listed for air quality, noise, blasting, visual vicinity of the mine intrusion, and the influx of job-seekers  Reduction in property Construction  Establish a CESF Operation of the mine values adjacent to the Operation Moderate  Ongoing open communication between the mine and all stakeholders near the Low project Closure mine  Loss of sense of place  Make all blasting monitoring reports available to any stakeholders for  Increase in insurance negotiations with insurance companies if necessary premiums for homeowners  Implement measures in the SLP relating to employee education and upskilling, Decommissioning or downscaling at Retrenchment Closure High including future forums, and offering a post-retrenchment programme to equip Moderate the mine retrenchees with knowledge and skills Establishment of tuck shops and Construction canteens near the mine and along Nuisance and safety impacts Low None Low Operation the transport route

Increased security presence at the Construction Cessation of illegal mining Low Positive Low Positive mine Operation None

Visual

ERPM Ext 2 Mine, East Rand, Gauteng 132 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Post-Mitigation Significance Activity Impact Phase Mitigation Significance Rating Rating  Implementing the mitigation measures related to dust generation  Avoid unnecessary removal of trees along the boundaries of the SDAs Site activities, including headgears Construction  Plant indigenous fast-growing trees along the mine boundary and WRD Visual intrusion, nuisance Operation Moderate Low  Avoid the use of highly reflective material Night time lighting Closure  Avoid unnecessary illumination, limit “light spill”  Shape the WRD to achieve stabilisation and to blend in with the natural topography; establish vegetation on the crests Beneficial to the overall Removal of the shaft headgears visual quality of the Closure Low Positive None Low Positive surrounding landscape Rehabilitation may be unsuccessful Permanent change in the Closure Low  Re-implement rehabilitation until closure objectives have been met Low or ineffective visual character of the area Aquatic Ecology  Construct clean and dirty water separation systems, erosion protection  Loss of habitat for wetland  Limit vegetation clearing and soil disturbance species Construction  Demarcate no-go areas at least 100m from the delineated edge of wetlands Site activities  Contamination of the Operation Moderate (no activities or stockpiles) Low nearby surface water / Closure  Limit stockpile height to 2m wetlands  Undertake concrete mixing in bunded areas  Implement dust suppression Terrestrial Ecology  Loss of floral habitat  Demarcate no-go zones beyond the original development area integrity and species Site activities, especially clearing Construction  Prohibit the collection of flora and firewood diversity including species vegetation. Operation Moderate  Implement an alien invasive species plan Low of conservation concern Ineffective rehabilitation Closure  Developing a floral rescue and relocation plan  Loss of habitat for fauna,  Re-implement rehabilitation until closure objectives have been met. species diversity and SCC Traffic Traffic congestion and  Make public transport available Additional vehicle trips potentially unsafe driving Low  Improve lane capacity to impacted intersections Low Construction conditions  Implement signalisation of access intersection (i.e. Barry Marais Rd/Road A) Operation Deterioration in pavement Increase in heavy vehicle volumes Closure  Not overloading trucks, and ensuring that wheel/axle loading are in quality resulting in unsafe Low Low during construction accordance to legislation driving conditions

ERPM Ext 2 Mine, East Rand, Gauteng 133 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 d) Summary of specialist reports (This summary must be completed if any specialist reports informed the impact assessment and final site layout process and must be in the following tabular form - attach copies of Specialist Reports as appendices)

Table 11: Specialist reports that informed the EIA process Report Author Appendix Air Quality IMA Trader 20 cc Appendix 6 Blasting Blast Management & Consulting Appendix 7 Soil and Land use Prime Resources (Pty) Ltd Appendix 8 Archaeology and Cultural Heritage Archaetnos Culture & Cultural Resource Consultants Appendix 9 Palaeontology Prof Marion Bamford - University of the Witwatersrand Appendix 10 Groundwater / Geohydrology Future Flow Groundwater & Project Management Solutions Appendix 11 Hydrology African Environmental Development Appendix 12 Noise IMA Trader 20 cc Appendix 13 Socio-economic Prime Resources (Pty) Ltd Appendix 14 Visual Aesthetics Prime Resources (Pty) Ltd Appendix 15 Terrestrial Ecology Scientific Terrestrial Services Appendix 16 Aquatic Ecology and Wetlands Scientific Aquatic Services Appendix 17 Watercourse Rehabilitation and Scientific Aquatic Services Appendix 17.1 Management Plan Hydropedology Scientific Aquatic Services Appendix 18 Traffic Merchelle’s Collective (Pty) Ltd Appendix 19

ERPM Ext 2 Mine, East Rand, Gauteng 134 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Table 12: Specialist recommendations considered in the EIA process Specialist Reference to applicable recommendations that section of report where List of studies have been included in specialist Recommendations of specialist reports undertaken the EIA report recommendations have (mark with an x where been included. applicable)

 Black-top or stabilise gravel access roads by laying down suitable wearing course to prevent excessive dust entrainment by the passage of vehicles. Consider regular wetting or suppression dust generation through application of surfactants. Reduce vehicle speed along gravel access roads to 20 km/h during dry windy conditions. Consider tarring the access road to the Windmill SDA as this route will be in use for the proposed 45 year lifespan of the mine.  Avoid site clearing during the drier winter months. Keep areas of clearing to a minimum required for site establishment. Cleared areas should be developed as soon as possible after clearing. Exposed areas of soil should be wetted down during dry conditions to reduce dust entrainment  Topsoil stockpiles must be located away from the boundaries of the SDAs that are located close to residential properties. Topsoil stockpiles must be forcibly revegetated with indigenous vegetation shortly after being formed if not to be reused immediately or covered with a suitable material to prevent dust entrainment. If dust entrainment is observed during dry windy conditions, suppression with water must be undertaken.  Blast management plan to be implemented. Screens to be erected around initial blasting for shafts. Thereafter, the openings of shaft can be covered over until dust has settled after the blast.  On excavation of overburden and waste rock, ensure weathered subsoil is placed at the bottom of the stockpiles and is covered over by coarser rock fraction. Ensure overburden stockpiles are created as far away as reasonably possible from residential properties.  Only vehicles and equipment that comply with the relevant emission standards may be used. Regular maintenance of vehicles and equipment as per manufacturers’ specification. Vehicles and equipment must not be permitted to idle when not in use for Air Quality Management extended periods of time. Use low sulphur fuel. Measures (Table 15 - Part  A storage and handling plan to be developed for the chemicals and fuels to be used. Must ensure legal storage, training for B) users and emergency response plans for spills and fires etc. Air Quality  Emissions monitoring to be undertaken at shafts to determine compliance with NAAQS at fenceline and beyond using screen X Air quality Monitoring model. Confirm with passive sampling at fenceline and community. Ventilation capacity to be increased and / or upcast shafts Programme (Section 1.i.k- to be fitted with filters if monitoring or modelling results reveal exceedances of NAAQS at sensitive receptors Part B; Table 28 and Table  Preferably undertake demolition in the wetter seasons. If dry and dust is seen to be a problem, wetting down of demolished 29) debris stockpiles may be required until removed from site - alternatively cover debris stockpiles with suitable covering. Remove from site for legal disposal as soon as possible  Wetting down of the work areas for rehabilitation may be required to suppress dust. Revegetation of these areas must be undertaken as soon as possible to ensure any dust nuisance is a short-term impact.  Ensure that dust generation from the waste rock dumps is managed when required through the wetting of the waste rock to reduce dust entrainment during handling.  During the planning phase, a waste specialist must be appointed to identify the wastes anticipated to be generated during closure and develop a waste management plan to ensure proper storage, handling, treatment and disposal and this plan must include managing any emissions to atmosphere. The mine must ensure that air quality at the boundary of the SDAs and in adjacent community areas remains compliant with the National Ambient Air Quality Standards for PM10, PM2.5, NO2, SO2 and Benzene. The Air Quality Monitoring Plan must be implemented at the mine. The mine management must prevent unacceptable dust entrainment from the access roads to the Windmill and Witpoortje MRAs, particularly if these roads are to remain unpaved, gravel roads. The following mitigation measures are recommended for consideration:  Vehicle speed restrictions: implementing a low (20 – 30 km/h) speed limit on unpaved roads will lower the degree of pulverisation and dust entrained into the atmosphere by the passage of the vehicles.

ERPM Ext 2 Mine, East Rand, Gauteng 135 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

 Wearing course material (if access roads are to remain gravel): a road engineer must advise on the correct wearing course material to lay down on the internal haul roads to prevent/reduce dust entrainment as a result of vehicles. Certain materials are less likely to be compacted into fine dust by the passage of vehicles.  Wheel wash facilities (if surfaces are paved) may prevent the track out of dust from unpaved surfaces onto paved surfaces.  Wind reduction controls such as tree lanes or wind breaks alongside access roads will protect the unpaved surfaces from high winds and excessive dust entrainment. Vegetative barriers also act as filters for dust by reducing wind energy and limiting long- range transport.  Surface treatment – the following surface treatment of unpaved haul roads should be considered: o Wetting of haul roads with water; o Chemical dust suppressants; o Tree and synthetic polymer emulsions; o Bitumen, tars and resins. The following dust management techniques must be applied to exposed areas of soil or rock:  Areas denuded of vegetation must be kept to a minimum.  Exposed areas should be rehabilitated as soon as operations permit.  Indigenous vegetation should be permitted/encouraged to grow on topsoil stockpiles  Exposed areas which are required for operations and cannot be avoided should be compacted and treated to prevent dust entrainment.  If complaints are received from residents close to the SDAs, then the use of a screening berm must be considered between the SDA and the complainants. Such a berm must be high enough to screen the SDA activities from the nearby adjacent neighbours and obstruct the direct movement of dust towards the neighbouring properties. The screening berm must either be immediately vegetated or covered with a suitable geofabric to prevent dust entrainment from the berm. Berms not only prevent the direct transport of dust, but also cause particles to fall out of suspension on-site by increasing the wind energy required to move the air stream over the berm.  Air quality monitoring at the outlet vent shafts must be undertaken to determine the concentration of all applicable pollutants (PM10 and PM2.5, NO2, SO2 and VOCs) once the mine is in operation to determine the concentration of these pollutants in the air discharge from the underground mining. The resulting air quality data must be used to model the pollutant dispersion plumes from the vent shafts and the predicted concentrations at identified sensitive receptors (using the appropriate Tier of modelling practice – screening (Tier 1) may be sufficient). The resultant model predictions, along with ambient air quality monitoring data must be used to determine whether ventilation capacity is adequate for underground and surface release; filtration or other mitigation methods must be implemented at the vent shafts if necessary. General operations management measures:  All vehicles and equipment must meet required emission specifications and must be serviced in accordance with the manufacturers’ specifications.  No fires may be burnt on site.  Vehicles should not be left to idle when not in use.  Low sulphur fuel must be used for vehicles and engines.  All vehicles travelling on gravel roads must obey the posted road speeds. If necessary, speed humps should be constructed to ensure speed reduction.  If the waste rock dump becomes a source of entrained dust, then wetting may be required during the winter months. Encouraging vegetation growth will also assist.  All site staff must receive training on how to reduce dust and vehicle emissions. Management actions:  Appointment of internal Environmental Officer (EO) who will be required to monitor the construction and operational phases of the development of the mine and assist management with implementation and monitoring of air quality management  Update the AQMP to ensure that all conditions of any instrument of environmental legislation (e.g. permits, licenses etc.) issued for this project are incorporated.  The AQMP must be made binding to the main contractor as well as individual contractors and should be included in tender documentation for the construction contract.  AQMP must be made available to the main contractor as well as individual contractors, as well as other relevant role-players.  The requirement of the AQMP must be incorporated into the induction and training programme.

ERPM Ext 2 Mine, East Rand, Gauteng 136 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

 Employees directly responsible for potentially causing air quality impacts must receive job specific training to ensure they know how to manage those impacts.  A road engineer must be appointed to determine the appropriate surface for the access roads, taking into consideration the planned 45 year life of the mine i.e. paved versus gravel.  Access roads must be surfaced as per the road engineer’s specifications.  Dust and mud should be controlled at vehicle exit and entry points to prevent the dispersion of dust and mud beyond the mine boundaries on public access roads. Facilities for the washing of vehicles can be considered at entry and exit points. Other options to remove mud can be investigated and considered  It may be necessary to cover the waste rock stockpiles with a geofabric to prevent dust entrainment or indigenous vegetation should be permitted to establish.  The mine will have to apply for the necessary authorisations as prescribed in the various acts, and specifically Mine Health and Safety Act Reg 4.16.  Blast designs can be reviewed prior to first blast planned and done. Specific attention should be given to expected outcomes using the final design. This needs to be compared with this report for conformance.  Calculated minimum safe distance is 87 m. The final blast designs that may be used will determine the final decision on safe distance to evacuate people and animals. This distance may be greater pending the final code of practice of the mine, preparation of a risk assessment to review safe distance and responsible blaster’s decision on safe distance. The blaster has a legal obligation concerning the safe distance and he needs to determine this distance.  A risk assessment should be conducted to determine final exclusion zone.  The M43 road and a gravel road are in the vicinity of the project area and needs to be considered. The M43 road is at closest point at 1552 m in the vicinity of the Shaft A underground area. The gravel road is at closest distance of 226 m from the nearest shaft area. Expected ground vibration levels at all roads are within the recommended limits. No specific actions are required for these roads.  The option of photographic survey of all structures up to 1000 m from the shaft areas is recommended. The mine will be operating Blasting and Subsidence for a significant number of years. This will give advantage on any negotiations with regards to complaints from neighbours on Management Measures structural issues due to blasting. This process can however only succeed if done in conjunction with a proper monitoring program. (Table 18 - Part B) It is expected that ground vibration levels will be significantly less than proposed limits at 1000 m but this process will ensure Blasting X record of the pre-blasting status of the nearest structures to the shaft areas. At 500 m the expected level of ground vibration will Blast / Vibration Monitoring be perceptible. Programme (Section 1.i.k-  Comply with the ground vibration and air blast levels limits recommended for blasting operations in this area. Part B; Table 28 and Table  A further consideration of blasting times is when weather conditions could influence the effects yielded by blasting operations. It 29) is recommended not to blast too early in the morning when it is still cool or when there is a possibility of atmospheric inversion or too late in the afternoon in winter. Do not blast in fog. Do not blast in the dark. Refrain from blasting when wind is blowing strongly in the direction of an outside receptor. Do not blast with low overcast clouds. These ‘do nots’ stem from the influence that weather has on air blast. The energy of air blast cannot be increased but it is distributed differently and therefore is difficult to mitigate.  It is recommended that a standard blasting time is fixed and blasting notice boards setup at various routes around the project area that will inform the community of blasting dates and times.  Third party consultation and monitoring should be considered for all ground vibration and air blast monitoring work. This will bring about unbiased evaluation of levels and influence from an independent group. Monitoring could be done using permanent installed stations. Audit functions may also be conducted to assist the mine in maintaining a high level of performance with regards to blast results and the effects related to blasting operations.  Video of each blast will help to define if fly rock occurred and from where. Immediate mitigation measure can then be applied if necessary. The video will also be a record of blast conditions. Topsoil should be stockpiled separately to subsoil as described below. The upper surface soil and topsoil is of variable thickness and Soil Management Measures is absent in some places. Soil stripping should only occur in areas that will contain infrastructure and ideally should take place when (Table 21 - Part B) the soil is dry to reduce moisture encouraged compaction. Soil and Land Soil stripping should take place in three stages: X Soil Monitoring Programme use 1. The surface soil horizons, which contains the seed bank, must be removed and stockpiled. Typically, this would be 50 - 100 mm (Section 1.i.k- Part B; Table thick. 2. The rest of the “A” horizon, the portion of the surface soil that contains the organic matter, must then be removed. Depending 28 and Table 29) on the age, erosion exposure and rainfall regime, the “A” horizon thickness in total may reach 400 - 600 mm in thickness.

ERPM Ext 2 Mine, East Rand, Gauteng 137 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

3. The usable non-plinthic “B” horizon materials must then be removed. These materials are physically suitable for rehabilitation Water Management but contain little or no organic matter and, accordingly, will not supply planted crops or grasses with nutrients if used untreated Measures (Table 24 - Part as topsoil. Fertilisers will need to be used as per specialist advice in using this soil as topsoil during rehabilitation. B) Soil disturbance loss control measures:  Keep the infrastructure development footprint and the area of disturbance as small as practically possible through careful project Hydrocarbon Management design, planning and management Measures (Table 25 - Part  Forbid the use of stockpiled soil for construction and conserve stockpiled soil for use in the closure and rehabilitation phase of B) the project  Develop a stormwater management strategy for the sites prior to construction  Identify locations for soil stockpiles where they will not be disturbed during the operational life of the project, these areas should be as flat as possible  Contractually commit contractors and subcontractors to the Soil Management Plan and impose financial penalties for non- conformance Soil erosion control measures:  Implement the Soil Management Plan  Implement stormwater management measures during soil stripping operations, to attenuate stormwater volumes and decrease water velocity  Install erosion control measures, such as erosion control berms and run-off control measures  Clearly demarcate areas for construction activities and restrict activities to the demarcated areas  Only clear vegetation in areas intended for infrastructure development  Stockpile soil, where possible, for post-mining rehabilitation  Protect all stockpiles by a berm wall to deflect stormwater runoff and prevent erosion of stockpiled material  Restrict the height of the topsoil stockpiles to 4 to 5 m  Vegetate stockpile side slopes and exposed soil with locally adapted perennial or annual grass seed mixtures as soon as possible  Maintain and upgrade stormwater management measures installed during construction, to attenuate stormwater volumes and decrease water velocity  Plan to ensure a free draining, rehabilitated landscape at closure  Carry out effective stockpile management throughout the operation phase.  Implement erosion prevention measures until vegetation has re-established. Establishment will be considered complete when over 70 % aerial cover is achieved  Design and shape the final landform to ensure the site is free draining, incorporating adequate stormwater management measures. If needed, the design should include contoured terraces to reduce velocity and spread volume of run-off water. Terracing entails creating level embankments at different elevations across a slope, along its elevation contours, in order to minimize run-off and soil erosion. The different terrace levels would promote efficient water infiltration into the soil and minimise erosion and siltation impacts after closure  Monitor erosion-sensitive areas and repair, until the area is stable and vegetation is established. Soil contamination control measures:  Implement the Hydrocarbon Management Plan which includes appropriate storage and handling of hydrocarbons  Clean up spillages of hazardous material (including cement) immediately; contaminated soil should be considered hazardous waste and stored appropriately  Either remediate contaminated soil on site (in a facility designed for this process) or dispose of it at an appropriately licensed landfill site  Cement storage and batching must take place on an impermeable surface  Follow general maintenance and safety precautions to prevent diesel and hydraulic fluids contaminating soil. If a spill occurs it must be reported and addressed immediately  Employ good waste management (hazardous and general waste) and housekeeping practices. There must be a bunded waste storage area on site that has an impermeable surface and a sump, and the area must be covered with a roof or water proof sheeting  Carry out a soil quality assessment at decommissioning to verify that the soil is not contaminated before re-spreading the soil for rehabilitation. This assessment must entail a thorough site inspection, soil sampling, as well as soil chemical analyses for

ERPM Ext 2 Mine, East Rand, Gauteng 138 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

heavy metals and other routine parameters such as pH, EC etc. in order to compare with the analysis results from the baseline assessment. This will determine if further analyses need to be carried out, especially if any visual stains or hydrocarbon odours are observed during the inspection. Soil compaction mitigation measures:  Undertake strategic, planned stockpiling to retain soil quality and fertility  Use the soil stripping guideline during clearing activities related to construction and any subsequent expansion activities  Strip soils during the dry winter months (or ensure that the soil is reasonably dry) to limit moisture-encouraged compaction - i.e. do not strip during or after rainfall / wet dust suppression. Rehabilitation measures:  Assess soil fertility when stockpiled soils have been replaced during rehabilitation, to determine the level of fertilisation required to sustain normal plant growth  If insufficient topsoil is available for rehabilitation, subsoil can be treated and vegetated under instruction of a suitably qualified restoration ecologist or botanist  Deposited soil should be ripped to reduce compaction during rehabilitative actions; and  Monitor soil quality and re-application of soil ameliorants post-closure  If re-vegetation is slow (can be assessed after the first rainy season) an appropriate fertilizer programme must be implemented at in consultation with a suitably qualified botanist / ecologist and unhealthy or dead plant material must be replaced  Erosion-sensitive areas must be monitored and any damage caused by erosion must be repaired. Regarding the graves that were located on site, two possibilities exist. The first option would be to fence the graves in and have a management plan drafted for the sustainable preservation thereof. This should be written by a heritage expert. This usually is done when the graves are in no danger of being damaged, but where there will be a secondary impact due to the development activities. The second option is to exhume the mortal remains and then to have it relocated. This usually is done when the graves are in the area to be directly affected by the development activities. For this a specific procedure should be followed which includes social consultation. For graves younger than 60 years, only an undertaker is needed. For those older than 60 years and unknown graves Archaeology and an undertaker and archaeologist is needed. Permits should be obtained from the Burial Grounds and Graves unit of SAHRA. 30 X Cultural Heritage The type of development makes it possible to keep the graves in situ. It is therefore recommended that it be included in the Heritage, Archaeology and development planning and that Option 1 be implemented. Palaeontology Management Site no. 1 and 2 are of negligible heritage importance. It may be demolished upon approval by the relevant heritage authority. Measures (Table 16 - Part It should be remembered that due to archaeological sites being subterranean in essence, it is possible that all cultural sites may not B) have been identified. Care should therefore be taken when development work commences that, if any more artefacts are uncovered, a qualified archaeologist be called in to investigate. Based on experience and the lack of any previously recorded fossils from the area, it is very unlikely that any fossils would be preserved in the loose soils. No fossils are preserved in the igneous rocks but there is a very small chance that trace fossils might Palaeontology be found in the hard sandstones as these have been reported from the Malmani Subgroup. The project can therefore proceed and X the geologist or responsible person on site for the construction of the mineshafts should look out for stromatolites. A Fossil Chance Find Protocol should be added to the final EMPr. It is recommended that a regional groundwater investigation be done to assess:  The presence of geological structures connecting the underground mine to surface that could lead to decant on surface once Water Management the groundwater levels have recovered to near pre-development levels; Measures (Table 24 - Part  The interconnection between the different mines in the area (ERPM Ext 2, ERPM Ext1, the South East Vertical Shaft, the B) Hercules Shaft, the Central Shaft, the Rose Deep compartment, and others and how that influences the decant potential, locality of expected decant points, decant volumes and decant qualities. Surface Water and Management measures include: Groundwater Monitoring Groundwater /  Perform geochemical assessment of the material that will be stored on the topsoil stockpile and the WRD to calculate the waste Programme ((Section 1.i.k- Geohydrology X classification and determine the lining requirements of the stockpile areas at the hand of Regulation 635 and 636 of the Waste Part B; Table 28 and Table Act; 29)  Proper lining of waste facilitates according to Regulation 636 of the Waste Act;  Proper removal of, and rehabilitation of, water management dams and surface stockpiles during decommissioning where Hydrocarbon Management possible; Measures (Table 25 -Part B)  Sloping, capping and vegetating of remaining surface stockpiles. This will reduce rainfall recharge and thus also the volume of seepage from the stockpiles to the underlying aquifers.

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 Surface storage facilities should be cleared and remediated where possible (WRD and topsoil stockpiles etc.). Surface stockpiles Socio-economic that cannot be cleared should be sloped, capped and vegetated to reduce rainfall recharge and the subsequent leach volumes Management Measures from the surface storage facilities to the underlying aquifers. (Table 20 - Part B)  It will be impossible to prevent and rehabilitate the impacts of contaminant migration away from all the pollution sources (underground mine, surface stockpiles etc.). Therefore, it is recommended that the groundwater monitoring program be Socio-economic Monitoring continued for a period of at least 5 years after mine closure to monitor the contaminant migration. Based on these results Programme (Section 1.i.k- remediation requirements can be identified and a remediation plan put in place. Part B; Table 28 and Table  The contaminant migration simulation results show that it is expected that there will be an impact on the surface water courses 29) in the area. Therefore, it is recommended that the streams be monitored and management systems be put in place. This could include cut-off trenches down gradient of the pollution sources and management of the seepage.  A water monitoring program that incorporates the proposed operations, with focus on the possible sources of impact, should be put in place. The sources of impacts include the underground mining areas as well as surface stockpile areas such as the topsoil and WRD stockpiles should be targeted. The monitoring program should include:  Dedicated groundwater monitoring boreholes should be installed: o Down gradient of the topsoil stockpile and WRD areas (approximately 30 m depth or 5 m into competent rock); o In the vicinity of the Windmill Shaft A and Shaft B (approximately 80 m depth); and o In the vicinity of the Witpoortje vent shaft (approximately 80 m depth).  Hydrocensus points which lie close to the zones of impact and could possibly be at risk: HBH1, HBH4 and HBH9.  During the 47 years of mining, streams must be monitored regularly for their chemical, toxicological and biological properties and the results compared with the results from the streams upstream from the mine's discharge point. Corrective action must be taken if required.  All water pumped and discharged from mine must be sampled/analysed on a monthly basis and analysed by an independent SANAS-accredited analytical laboratory. In addition to the monthly sampling, a competent person at the mine must be made responsible for determining the EC and pH of the water being pumped from the mine to the treatment plant and the water released from the treatment plant on a daily basis.  Wherever possible, fissure water ingress points must be grouted to prevent, or at least reduce, water ingress into the mine to a maximum of 3 Ml/day.  It will be necessary to treat mine water underground in a treatment plant to protect the pumping system.  A non-hazardous, disinfection method must be applied if the water is indeed going to be recirculated underground at ERPM X2.  Heath & safety regarding sanitation and waterborne disease underground must be considered when the drinking water and X underground toilets are designed.  Ensure that proper and private toilet facilities are used underground and that these facilities are close to the workplace to prevent Hydrology people from using alternate methods.  Ensure that a safe water supply is available at the workplace in such a way that it is a preferred source of drinking water when compared to the mine service water. Educate workers of the dangers of drinking mine service water instead of the drinking water (which in many mines is only available at the station). Also disinfect mine service water using non-hazardous disinfectants.  Regarding the handling of decant water from the mine, closure must be planned for at least 10 years prior or longer if possible. The water treatment process must continue for years, decades or even centuries after mine closure. There must be sufficient funds in the trust to finance the water treatment after closure.  Remove mine water as soon as possible to prevent it from becoming contaminated.  Ensure that the mine water being discharged into the Rietspruit is treated to the standard in the WUL.  It is recommended to add an additional PCD for the WRD at Windmill Shaft and move the explosives handling area slightly to The recommendations the northeast. regarding the PCD have  The PCD for the site (excluding the WRD) should have a capacity of 10 380 m³ at the Windmill SDA. X been incorporated into the site layout / design of the  A much smaller PCD (of ~1 958 m³) will be required for the WRD at the Windmill SDA Windmill Shaft SDA. Noise mitigation measures Noise  Appointment of internal Environmental Officer (EO) who will be required to monitor the site and assist management with the X implementation and monitoring of the noise impact management

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 Update the Noise Management Plan to ensure that all conditions of the Authorisation issued for this development have been incorporated.  Drivers must be trained not to over-rev engines and to avoid unnecessary reversing. Engines and equipment to be powered off when standing for extended periods of time - no idling. Strict speed limits to be applied on the mine.  During the transfer of waste rock to stockpiles or the loading of waste rock onto the back of trucks, drop heights should be minimised to control and reduce the generation of excessive noise.  Waste rock vehicles will be regularly maintained in accordance with manufacturers’ specifications.  Drivers must adhere to speed limits through residential areas.  Engines must be muffled as per manufacture's specifications.  Blast designs and procedures must be developed to keep noise and blasting to a minimum without compromising blast requirements  Blast designs must consider appropriate drilling grid, charge size, charging plan, blasting ratio, charge stemming and delay interval.  Delayed / micro-delayed or electronic detonators must be used.  No blasting to occur on Weekends or Public Holidays or at night.  Blasting will be undertaken following a planned schedule and the local community will be informed of this in advance. Notify community of intention to drill for setting up to blast. Noise Management  Drill rigs must be in good working condition and muffled where possible. Measures (Table 19 - Part  Temporary noise screens may need to be erected around drilling operations. B)  Blast procedure to be implemented and to include notification of nearby community.  Noise levels of the blast will be monitored and the results will be used to inform future blast design. Noise Monitoring  Ongoing public relations must be undertaken for the SDAs. Residents must be afforded a simple route to register complaints or Programme (Section 1.i.k- concerns and be ensured of prompt and adequate mitigations. Part B; Table 28 and Table  The EO must undertake daily inspections to encourage implementation of the requirements of the Noise Management Pan. 29)  The EO should undertake internal compliance audits every 6 months to determine compliance.  Noise Impact Monitoring should be undertaken.  Noisy equipment and vehicles must be regularly maintained in accordance with manufacturers’ specifications.  Vehicle speeds must be limited to 30 km/h on internal unpaved haul roads.  During the transfer of waste rock for the purposes of closing the shafts and the loading of waste rock onto the back of trucks, drop heights should be minimised to control minimise the generation of excessive noise.  Drivers must adhere to speed limits through residential areas.  Noise Impact Monitoring during closure must be undertaken until closure is complete. No further noise monitoring is anticipated once closure is complete.  No construction may occur at night.  Refrigeration units, compressors and generators, ventilation fans and head gear and winders that do not exceed a 85 - 90 dBA noise output should be used.  Acoustic barriers should be established between equipment and the off-site receptors.  It must be ensured that all employees are suitably equipped with hearing protection for the jobs they are to perform and that their hearing health is monitored as per the required legislation.  Ongoing liaison with the affected receptors must be maintained. Mitigation measures include:  Implementing the SDP. Socio-economic  Maximising the potential benefits to the local economy by ensuring that local labour and service providers are utilised wherever Management Measures possible throughout the various phases of the life of mine. (Table 20 - Part B)  Following a predetermined recruitment process conducted from a centralized recruitment office located off site.

Socio-economic  Developing a Stakeholder Engagement Plan (SEP). X Socio-economic Monitoring  Implementing the measures in the SLP relating to employee education and upskilling to mitigate the impacts of unavoidable job Programme (Section 1.i.k- losses. Part B; Table 28 and Table  Adhering to the measures detailed in the SLP regarding the management of downscaling and retrenchment.  Prioritizing training opportunities for people living in the area that will be impacted by the proposed development. 29)  Prioritizing training and employment opportunities for the youth (18-34 years).

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 Identifying and using suitable HDSA and local companies and SMMEs that could provide local procurement to the mine as required for the mining operations.  Implementing the procurement processes detailed in the SLP.  Encouraging employees not resident in the area to rent locally, and prohibiting squatting in mine lease areas or along the transport route.  Strictly adhering to the mitigation measures laid out for noise, air and blasting.  Employees should be transported into and out of the secured mine area by taxi, and should be encouraged to take advantage of the transport service being provided by the mine.  Ensuring information dissemination, recruitment and supply chain transparency;  Developing and implementing influx management and security arrangements; The ERPM Ext 2 SLP Human Resources Development (HRD) Programme details the following initiatives to be implemented at the ERPM Ext 2 Mine when it commences:  Skills Development Plan;  Career Progression Plan;  Mentorship Plan;  Internship/Learnership Plan and Bursary Scheme;  Employment Equity (EE) Plan;  LED Programme: Resource Centre and Early Childhood Development (ECD) centre;  Downscaling and Retrenchment Plan. It is recommended that ERPM Ext 2 Mine develops a SEP with the following objectives:  Identification of stakeholders;  Disclosure of planned project activities;  Identification of concerns and grievances from stakeholders;  Harnessing of local expertise and knowledge from stakeholders;  Ongoing disclosure of project activities and monitoring results; and  Response to grievances and enquiries (via the Grievance Mechanism).  It is recommended that ERPM Ext 2 Mine establishes a Community Engagement and Security Forum to ensure that stakeholders are notified and consulted throughout the LoM. The mine must develop and implement a community health and safety policy which should include the following:  Road safety rules to be applied to all mine vehicles.  An Emergency Preparedness and Response Plan (EPRP) for the proposed road connection and for the mine that details the agreed protocols, process, engagement and investigation processes for various relevant potential emergencies. This should cover all incidents presenting risks to public safety and the affected communities in proximity to ERPM Ext 2 Mine.  Ensure that a medical emergency response service is available in case of accidents occurring along the tailings pipeline (either to Knights Plant or ERGO Plant), and develop a clear policy for the management of project-related accidents in the community during all phases of the project.  Response procedure and action plan to deal with any potential social unrest that takes place in the vicinity of the mine.  Guidelines for interaction between contractors/employees and the community.  A grievance mechanism is to ensure timely redress to any grievances raised during all phases of the project. The primary objective is to ensure that people affected by the mining activities can present their grievances to mine management for consideration and redress if necessary. The grievance process will also ensure that all complaints raised by the affected parties are addressed in an appropriate and timely manner, with corrective actions being implemented where necessary, and the complainant being informed of the outcome.  A management plan should be compiled by a heritage expert detailing the protection, access to, and management of the graveyard site near Witpoortje Vent Shaft.  All personnel (including contractors) involved in the construction and operation of the project must undergo a training and awareness programme on health, safety, environmental and social requirements and obligations prior to commencing activities. Community Health and Safety Training will assist ERPM Ext 2 Mine in raising awareness with the local communities regarding project-associated risks. The objectives of this training will be:  Raising awareness associated with all project activities;  A road safety awareness campaign;

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 Identification of dangerous / hazardous site activities, including tailings pipelines, transport routes and infrastructure such as water bodies.  A Socio-Economic Monitoring Programme will monitor the progress and effectiveness of proposed socio-economic mitigation measures and ensure stakeholder input is considered as part of the ongoing implementation process. Ongoing stakeholder engagement will play a key role in monitoring impacts and the effectiveness of mitigation and management strategies. Section j)ii) Conditions that  An agreement should be reached with the landowner / tenant of the two farmhouses located near Windmill Shaft SDA regarding X must be included in the the potential impact associated with air blast during the initial stages of construction authorisation  The extent of the areas to be disturbed should be limited to areas which are essential. Dust suppression measures as per the air quality specialist recommendations must be implemented to ensure that dust does not have a negative visual impact. Management measures:  Avoid the unnecessary removal of vegetation, especially trees, along the boundaries of the SDAs, where these partially or totally screen infrastructure components  Plant indigenous fast-growing trees along the mine boundary between sensitive receptors and SDAs  Keep vertical dimensions of tall infrastructure to the minimum heights possible and keep the surface infrastructure layout to the smallest possible footprint  Signage related to the proposed development as well as contractors’ signage must be discrete  The use of highly reflective materials should be avoided. Alternatively, reflective materials should be painted a dark grey, brown or green colour, to minimise visibility and avoid reflectivity. Visual Management Visual  The operations should be kept in a tidy state e.g. prevent litter, to minimise further visual impact. X Measures (Table 23 - Part Aesthetics  Completely remove all structures during decommissioning, and rehabilitate all disturbed areas. B)  Shape the waste rock dump to achieve deposit stabilisation and to blend with the natural topography as much as possible, however avoid increasing the affected surface footprint as far as possible;  Subsoil and topsoil will be placed on the dump; and  Vegetation should be established on the crests of the dump with a grass mixture dominated by local climax species and vegetation that provides screening should be established.  Avoid unnecessary illumination  Provide lights with cover fittings that limit lateral and upwards “light spill”, and position lights to shine towards the intended areas of illumination rather than using floodlights. Limit the heights at which lights are positioned will reduce “light spill”.  Make use of Low-Pressure Sodium lighting or other types of low impact lighting. Low wattage bulbs can be used to further reduce the impact.  Motion sensor activated lighting could be used instead of lights that illuminate continuously. Management Measures (Flora):  All mitigation measures as stipulated in the freshwater ecological report (SAS, 2019) are to be implemented in line with the mitigation measures as discussed in this report.  The construction footprint must be kept as small as possible in order to minimise impact on the surrounding environment. As such, construction activities must not encroach upon natural areas surrounding the study area.  It is recommended that the Eragrostis chloromelas Grassland Habitat be excluded from development and zoned as a Biodiversity Management conservation area as this site had a notably higher diversity of faunal species as well as being considered important for faunal Measures (Table 17 - Part B) Terrestrial SCC such as Mystromys albicaudatus (White-tailed Mouse, EN) and Atelerix frontalis (Southern African Hedgehog, NT). Suitable rehabilitation actions and long-term management plans must be implemented for this habitat unit through the construction, Ecology (Fauna X operation and decommissioning of the shafts in order to minimise edge effects and retain/improve the habitat integrity. Biodiversity Monitoring and flora)  No hunting or trapping of faunal species is to be allowed by construction personnel. Programme (Section 1.i.k-  Although not favoured and likely will result in an increase impact scoring, should development be planned within the Eragrostis Part B; Table 28 and Table chloromelas Grassland Habitat, it is recommended that a pre-construction walkdown be undertaken in order to find and relocate 29) individuals of Atelerix frontalis (Southern African Hedgehog, NT). Burrows must also be sought out, marked and assessed for the presence of Atelerix frontalis (Southern African Hedgehog, NT) by a suitably qualified specialist. If individuals are observed they are to be carefully relocated to an area outside of the development footprint but of similar habitat.  With regards to the orange listed plant species i.e. Eucomis autumnalis and Hypoxis hemerocallidea individuals encountered during the site assessment:

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o No collection of floral SCC, or any other plant material must be allowed by construction personnel; o During the surveying and site-pegging phase of surface infrastructure, all floral SCC and protected species that will be affected by surface infrastructure must be marked; o Removal of these individuals should be avoided, where possible. All individuals situated within the shaft footprint area should however be rescued and either relocated to (As per personal communication with Calvin Jonhasi Production Scientist: Soil Ecology at GDARD on 04/12/17).: . Suitable similar habitat within the study area but outside the shaft footprint, . if areas surrounding the shafts be landscaped, these species can be planted within landscaped areas; or . Relocated to a registered nursery, the ARC or SANBI as a last resort. o It should be noted that any individuals removed from the study area and not relocated to an area/facility listed above, may require permits from the GDARD, o The rescue and relocation plan should be overseen by a suitably qualified botanical specialist; and o Should any other floral SCC be encountered during the construction and of the development all activities should be stopped immediately, and a suitably qualified specialist be consulted as to the possibility of rescue and relocation of the species encountered;  Removal of vegetation should be restricted to what is absolutely necessary;  Informal fires by construction personnel should be prohibited, and no uncontrolled fires whatsoever should be allowed;  Alien vegetation must be removed and controlled within the study area to prevent spread to the surrounding areas during both the construction and operational phases, with specific mention of Category 1b and 2 species in line with the NEMBA Alien and Invasive Species Regulations (2016). As such an AIP Control Plan should be compiled prior to commencement of construction works and implemented through the construction of the shafts;  Care should be taken during the construction and operation phases to limit edge effects on the surrounding natural habitat particularly watercourses in the surrounding landscape; this can be achieved by o Demarcating all footprint areas during construction activities; o No construction rubble or cleared alien invasive species are to be disposed of within these areas, and should be taken to a registered waste disposal facility; o All soils compacted as a result of construction activities should be ripped, profiled and reseeded;  Upon completion of construction activities, it must be ensured that no bare areas remain, and that indigenous species be used to revegetate the disturbed area. Recommended seed mix: Reclamation mixtures for rehabilitation of damaged veld and disturbed areas – available from http://mayford.co.za/veld-grass/. Management Measures (Fauna):  The operational footprint must be kept as small as possible in order to minimise impact on the surrounding environment;  All mitigation measures as stipulated in the freshwater ecological report (SAS, 2019) are to be implemented in line with the mitigation measures as discussed in this report;  Edge effects of all operational activities, such as erosion and alien plant species proliferation, which may affect adjacent natural areas, need to be strictly managed adjacent to the project perimeter. Specific mention in this regard is made to Category 1b and 2 species  Ongoing alien and invasive vegetation monitoring and eradication should take place throughout the operational phase of the development; Implementation of the AIP control plan must be continued through the operational phase in order to monitor and control alien floral recruitment in disturbed areas;  Vehicles should be restricted to travelling only on designated roadways to limit the ecological footprint; X  Any disturbance of sensitive faunal and floral habitat and SCC must be actively avoided during the operational phase of the development;  No informal fires are allowed;  No hunting/trapping or collecting of faunal species is allowed;  Rehabilitation of natural vegetation should proceed in accordance with a rehabilitation plan compiled by a suitably qualified botanical specialist. This rehabilitation plan should consider all development phases of the project indicating rehabilitation actions to be undertaken during and once construction has been completed, ongoing rehabilitation during the operational phase of the project as well as rehabilitation actions to be undertaken during closure phases. It is strongly recommended that small scale rehabilitation be undertaken within the Eragrostis chloromelas Grassland Habitat to restore the habitat integrity and likelihood of this habitat housing floral and faunal SCC in the long term

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 Rehabilitation must be implemented at all times, and disturbed areas must be rehabilitated as soon as such areas become available. This will not only reduce the total disturbance footprint but will also reduce the overall rehabilitation effort and cost. Management Measures (Fauna and flora):  All shaft infrastructure footprints should be rehabilitated in accordance with a rehabilitation plan compiled by a suitably qualified specialist;  Any natural areas, including watercourses, beyond the shaft footprint that have been affected by the mining operation must be rehabilitated using indigenous grass species. All rehabilitated areas should be rehabilitated to a point where natural processes will allow the pre-development ecological functioning and biodiversity of the area to be re-instated (natural reference state);  Rehabilitation efforts must be implemented and monitored for a period of at least five years after decommissioning and closure;  Edge effects of decommissioning and closure activities, such as erosion and alien plant species proliferation, which may affect adjacent natural areas, need to be strictly managed adjacent to the project footprint areas. Specific mention in this regard is made to Category 1b and 2 species;  Ongoing alien and invasive vegetation monitoring and eradication should take place throughout the closure/ decommissioning X phase of the development, and the project footprint areas and immediate surrounding area (50m from the perimeters) should be regularly checked during the decommissioning phase for alien vegetation proliferation to prevent spread into surrounding natural areas;  The AIP plan compiled for the construction and operational phases must include decommissioning requirements and must be updated every second year to ensure site specific actions are implemented. The AIP control plan must be implemented for a period of at least 5 years after decommissioning and closure, or until indigenous basal cover is sufficient to prevent proliferation of AIPs; and  It must be ensured that decommissioning related activities are kept strictly within the shaft footprint, and care should be taken not to damage/ harm floral SCC during the closure phase of the proposed mine shafts. This is of specific importance to the intermediate Eragrostis chloromelas Grassland Habitat.  Care should be taken during the proposed development not to destroy any floral SCC individuals, and all individuals within the shaft footprint should be rescued and relocated to similar suitable habitat outside of the shaft footprint by a suitably qualified X botanical specialist.’’ Mitigation measures:  No construction may take place within the wetlands or 100m GN704 Zone of Regulation. Additionally, the wetlands and 100m GN704 Zone of Regulation must be demarcated as a no-go area;  No stockpiles are to be permitted within the 100m GN704 Zone of Regulation;  Exposed soil and stockpiles must be protected from wind by covering with a suitable geotextile such as hessian sheeting, and ensure no stockpiles are higher than 2m;  Dust suppression measures must be implemented throughout construction to prevent excessive dust which may smother Biodiversity Management wetland vegetation; Measures (Table 17 - Part  Clean and dirty water areas should be kept separate; B)  The dirty water systems should be adequately sized as per the GN704 Regulatory Requirements, to prevent failure thereof and ultimately, discharge of contaminated water into the wetlands; Biodiversity Monitoring Aquatic Ecology  Any PCDs must have capacity to cater for a 1:50 year flood occurring over a 24 hour period and must be lined with an appropriate Programme (Section 1.i.k- liner; X and Wetlands Part B; Table 28 and Table  Clean water captured in the clean water system should be returned back into the surrounding wetland systems. However, the 29) wetlands must be protected against erosion arising from the discharge of clean water in a concentrated manner;

 The clean water outlet should be constructed with the use of energy dissipating structures to slow down the velocity of water inflow into the wetland; Watercourse Rehabilitation  A site-specific rehabilitation plan, including an alien invasive plant (AIP) management plan, must be compiled and implemented. and Management Plan AIPs should be removed by hand and no machinery should be allowed in the wetlands; and (Appendix 17.1)  The 100m GN704 Zone of Regulation must be rehabilitated with indigenous vegetation, thus incorporating faunal and floral habitats. This will ensure that the current levels of ecological service provision of the wetlands are maintained and where feasible, improved.  Ensure contractor laydown areas are placed outside of the wetlands and the associated 100m GN704 Zone of Regulation. A designated area should be approved by the Environmental Control Officer (ECO) prior to use;  Ensure that indiscriminate vehicle driving does not occur within the wetlands or the 100m GN704 Zone of Regulation;

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 Dust suppression measures must be implemented throughout construction to prevent excessive dust which may smother wetland vegetation.  No indiscriminate movement of machinery or personnel is allowed within the wetlands or associated 100m GN704 Zone of Regulation. Careful planning of all construction machinery must be undertaken beforehand to ensure that the minimum impact on the wetlands occur;  No stockpiles are to be permitted within the 100m GN704 Zone of Regulation  Exposed soil and stockpiles must be protected from wind by covering with a suitable geotextile such as hessian sheeting;  Ensure no stockpiles are higher than 2m  Any concrete mixing/temporary storage must be undertaken in bunded areas or on batter boards only. Care must be taken to prevent any spillage within the wetlands or surrounding environment;  Strict monitoring of the footprint area and the height of the Waste Rock Dumps (WRDs) should be implemented to prevent encroachment thereof into the 100m GN704 Zone of Regulation or into the wetland, particularly in the case of the Witpoortjie Shaft, where the eastern portion of the shaft surface development area falls within the 100m GN704 Zone of Regulation of the CVB wetland.  Dirty water areas should be kept as small as possible and should be expanded progressively to ensure that the volume of clean surface runoff supplying the wetlands is optimised;  The dirty water systems should be adequately sized as per the GN704 Regulatory Requirements, to prevent failure thereof and ultimately, discharge of contaminated water into the wetlands;  After construction of the outlet, the area surrounding the outlet should be re-seeded with indigenous wetland vegetation.  Excavated materials should not be contaminated and mixture of the lower and upper layers of the excavated soil should be kept to a minimum;  All exposed soil must be protected for the duration of the construction phase in order to prevent erosion and sedimentation of the downgradient wetlands.  Pollution prevention through infrastructure design, to prevent, eliminate and/or control potential pollution of soils, groundwater and surface water should be implemented;  A monitoring programme to detect, manage and prevent the pollution of soils, surface water and groundwater, as well as wetland monitoring, should be implemented.  Proactive monitoring to ensure structural integrity is maintained must be done.  Infrastructure be regularly inspected for leaks, or more often should there be any sign or reports of a leak.  Should leakage occur, all possible steps are to be taken to prevent the pollution of the downgradient wetland systems during repair.  Any areas where decant points may be determined by a geohydrological assessment need to be carefully managed throughout the life of the operation.  Water levels need to be strictly managed to ensure they are kept below any decant level while ensuring that a significant cone of depression impact does not take place.  If decant does occur, all water is to be treated to the background water quality values prior to release into the receiving freshwater environment.  The clean and dirty water separation systems should be regularly inspected to ensure that there is no mixing of clean and dirty water and that the systems are functioning efficiently.  The energy dissipating structures at the clean water outlets should be regularly inspected to ensure that the release of clean water into the wetlands has not resulted in erosion.  No hard infrastructure should be allowed below the 100m GN704 Zone of Regulation.  The final backfilled landscape should be free draining so as to allow recharge of the wetlands in the landscape and the greater catchment. The post-closure recharge of the catchment should also be as near natural as possible;  Ensure that soils are replaced in the correct layers, ripped and re-profiled post-closure, and that vegetation is restored to a point where succession will lead to the same conditions as the pre-mining state as a minimum.  Rehabilitation measures stipulated in the Environmental Management Programme (EMP) must be implemented. Implementation must be overseen by a suitably qualified Environmental Site Officer (ESO) with wetland rehabilitation experience and the ESO must sign off the rehabilitation before the relevant contractors leave site.  Avoid wetlands and interflow soils (soil/bedrock) soils as far as practically possible. Soil Management Measures Hydropedology X  All development footprint areas to remain as small as possible and disturbance of soil to be limited to what is absolutely essential. (Table 21 - Part B)

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Soil Monitoring Programme (Section 1.i.k- Part B; Table 28 and Table 29) It is recommended that the access road from Barry Marais Rd. to the Windmill Shaft be stabilised and that the remainder of the roadbed from the Windmill Shaft to the R550 I/S is graded to fix any ditches or potholes. Based on the traffic evaluation, the following network improvements are necessary:  The Barry Marais Rd. & Camora St./Road A I/S currently experiences significant delay on the side road approaches. Due to the high traffic flow on Barry Marais Rd., vehicles from the side road have difficulty in entering the traffic stream, and the problem is exacerbated since the majority of vehicles from Camora St. turn right in the PM Peak hour. Various lane improvements were modelled; however, it did not alleviate the delay on the side roads. The intersection was subsequently upgraded to a signalised intersection, with capacity upgrades to Barry Marais Rd. which was previously free flow, in order to process the through volumes on the main road at a comparable LOS. The signal should be on a semi-fixed timing plan with the side roads on a vehicle actuated phase (only when a vehicle is present will the side road phase activate) to account for the low traffic volumes during the off-peak hours. The recommended improvements are as follows: o New signal installation at the intersection o Short right turn lane on Camora St. o Extend existing left turn lane on Barry Marais Rd. northbound to 120m and reconfigure lane movements to also include the through movement  The Barry Marais Rd./R21 Rondebult Rd. I/S currently operates just within capacity. Once additional traffic volumes and traffic Traffic Management growth is added to the background traffic, the intersection fails to meet the LOS D criteria. Additional through lanes were Measures (Table 22 - Part subsequently added to Barry Marais Rd. and the signal timings optimised to process the traffic flows at an acceptable LOS. B) Recommended improvements are as follows: Traffic o Additional short through lane (120m) and short receiving lane (60m) on Barry Marais Rd. northbound X Traffic Monitoring o Additional short right turn lane (60m) on R21 Rondebult Rd. and short receiving lane (60m) on Barry Marais Rd. southbound Programme (Section 1.i.k- o New right turn phase for the right turn movement on Barry Marais southbound approach – new signal heads required Part B; Table 28 and Table  Grade and stabilise Road A up to the Windmill Shaft. Grade the rest of Road A to the R550 I/S if this is used as an alternate 29) access point to the site.  Road pavement appears to be in a satisfactory condition on Barry Marais Rd. (no potholes or cracking observed upon a cursory inspection). Mitigation measures:  Make available public transport such as a bus service to/from the mine for staff from surrounding settlements to reduce number of car and minibus taxi trips on the network and subsequent reduction in CO2 emissions.  Lane capacity improvements to impacted intersections to reduce delays and overall journey time.  Signalisation of access intersection (Barry Marais Rd./Road A I/S) to reduce delays and improve safety by reducing the number of conflict points  Trucks should not be overloaded and wheel/axle loading should be in accordance to legislation (TMH 3)  Stabilised roadbed. Monitoring:  Monitoring of queue lengths at the access intersection to ensure improvements are effectual.  Monitoring of truck loading for compliance  Monitoring of dust levels

ERPM Ext 2 Mine, East Rand, Gauteng 147 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 e) Environmental impact statement i) Summary of the key findings of the environmental impact assessment

All the potential impacts identified, for each phase of the LoM, with a significance rating of Moderate or higher after the implementation of mitigation measures were considered key and are discussed below.

Negative Impacts

 Discharge of surplus groundwater resulting in the decrease of surface water quality and an impact on aquatic ecosystems. Although it is not expected that there will be any discharge as the current proposal is for the excess water to be transferred to and used by ERGO, there is a risk that more than anticipated water will be encountered during mining. This is due to the uncertainty regarding the volumes of water that may be encountered during mining at this depth. The mitigation measures for this impact include the sealing of ingress points into the mine as far as possible, in order to reduce the potential excess volumes of water that will need to be catered for. The treatment of groundwater prior to discharge has also been allowed for (water treatment plant), but additional investigation and modelling is required in order to determine these volumes. Agreements will also need to be put in place with water off-takers such as ERGO. This impact will cease after operation as the mine will no longer need to dewater the workings.  The possible decant of water from the mine post-closure will be a permanent impact affecting the surface, groundwater and aquatic ecosystems. The extent to which decant may occur is unknown and further investigation is required to determine the potential for decant as well as the location of possible decant points. Current proposed management measures include the containment and treatment of this decant water, assuming that it will be fairly contaminated, prior to discharge.  Generation of Acid Mine Drainage. Further investigations and modelling of groundwater flow are required in order to determine the rate at which the underground workings will be flooded once the dewatering ceases, which will determine the extent to which AMD will be generated after closure.  The in-migration of job seekers into the project area is unknown, difficult to quantity, and difficult to manage. Mitigation measures to prevent this impact from occurring have been recommended, but this impact will require careful monitoring and action to prevent the establishment or expansion of informal settlements.  During the decommissioning or downscaling at the mine there will be a loss of employment / retrenchment. Mitigation measures include ongoing skills development, training, and preparation for retrenchment – all occurring throughout the life of the mine.

Positive Impacts

 Employment, stimulation of the local economy, skills development and training. ii) Final Site Map (Provide a map at an appropriate scale which superimposes the proposed overall activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers)

Refer to Figure 34 for a composite map which superimposes the proposed overall activity and its associated structures and infrastructure on the environmental sensitivities. iii) Summary of the positive and negative implications and risks of the proposed activity and identified alternatives

A summary of the positive and negative impacts of the proposed ERPM Ext 2 Mine is provided Table 10 and described in Section 3.ii). No alternatives were identified during the EIA phase. f) Proposed impact management objectives and the impact management outcomes for inclusion in the EMPr (Based on the assessment and where applicable the recommendations from specialist reports, the

ERPM Ext 2 Mine, East Rand, Gauteng 148 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

recording of proposed impact management objectives, and the impact management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation)

Refer to Section 1.d) of the EMPr (Part B of this document) and Table 13 for the proposed impact management objectives and the impact management outcomes. g) Final proposed alternatives (Provide an explanation for the final layout of the infrastructure and activities on the overall site as shown on the final site map together with the reasons why they are the final proposed alternatives which respond to the impact management measures, avoidance, and mitigation measures identified through the assessment)

Specialists assessed the potential impacts of the layouts and from the findings of the assessments no further alternatives were identified during the EIA phase. The findings indicated that the layouts would not result in any fatal flaws in terms of environmental and socio-economic impacts if the recommended mitigation measures (refer to Section 4(g) of the EMPr Part B) are implemented. h) Aspects for inclusion as conditions of Authorisation (Any aspects which have not formed part of the EMPr that must be made conditions of the Environmental Authorisation)

None, as all the relevant aspects have been included as commitments as per this EMPr (Part B of this document) in terms of mitigation (detailed in Section 4(g)), monitoring (detailed in Section 6); as well as within the Closure Plan (Appendix 21). i) Description of any assumptions, uncertainties and gaps in knowledge (Which relate to the assessment and mitigation measures proposed)

Project description

At this stage of the project, the information regarding the construction, operation and closure of the project is conceptual. Ideally, detailed design of the above and below ground works would be used to influence the assessment of the impacts. However, the level of detail was sufficient for the main, significant impacts to be addressed in the assessment.

TSF and Processing Plant

 It is assumed that because a suitable processing plant is located within a viable distance from the site, that the development of a new processing plant and tailings facility will not be necessary for the project.  The processing of ore, tailings disposal and the potential expansion of an existing TSF was not considered as part of this EIA as the Processing Plant, TSFs and associated pipelines are owned and operated by ERGO.  The capacity of the existing Processing Plant, TSFs and associated pipelines to cater for the slurry and additional tailings resulting from this project has not been investigated nor commented on.

Air Quality

 Monitoring and modelling results and significant experience at similar facilities have been used to determine the likely nature and extent of the potential air quality impacts. The confidence of predictive modelling for a range of fugitive sources relating to passive surface operation emission sources and venting from underground mine shafts is very low using US EPA or Australian NPA emission rate calculations.  Reasonable conclusions can be reached on the basis of sources, proximity, wind field and receptors that have all been factored into this initial assessment towards the establishment of an Air Quality Management Plan. Such an AQMP must remain dynamic and informed by the recommended monitoring programme as the mining area develops more formally.

Blasting and subsidence

 The anticipated levels of ground vibration estimated in the study were calculated using standard accepted methodology according to international and local regulations.

ERPM Ext 2 Mine, East Rand, Gauteng 149 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

 Assumption was made that the predictions are a good estimate with significant safety factors to ensure that expected levels are based on worst case scenarios. These will have to be confirmed with actual measurements once the operation is active.  Sufficient data is not available from this operation as no blasting activities are currently being done.  A final shaft blast design was not available at the time the report was compiled. However, the design used for the evaluation of impacts is expected to be similar to the final design.  In terms of potential surface subsidence and the risk of undermining surrounding residential area, a detailed assessment by a specialist rock engineer was not undertaken. In general, mining-induced surface subsidence becomes less of a problem as the depth of mining increases, however the risk of mining-induced seismicity as a result of deep mining activities exists which can cause ground vibrations and damage to surface structures.

Soil and Land Use

 The data provided has been developed from a desktop study and is based on available data. The impacts that were identified are based on the understanding of the project as provided by the proponent.

Heritage

 Due to archaeological sites being subterranean in essence, it is possible that all cultural sites may not have been identified.

Palaeontology

 Based on the geology of the area and the palaeontological record, it is assumed that the formation and layout of the dolomites, sandstones, shales and sands are typical for the country and may contain stromatolites which are trace fossils. The overlying modern soils would not preserve fossils.

Noise

 The environmental sound level impact assessment only takes in to consideration noise generated by the surface infrastructure and operations of the mine and not the underground mining. Underground mining is considered as occupational noise and considered sufficiently deep to not have significant surface impacts.  No data was available regarding the noise levels that this operation could produce. Anticipated noise generation measurements from mine operations were determined from a literature search and combined with measurements from other similar mining operations. These were used to calculate ‘worst case’ expected noise outputs from the proposed mine surface operations.  The noise decay calculator applied in this study did not consider the absorptive or deflective aspect of various objects between the mine and the receptors and will also likely reflect a ‘worst case’ scenario.  The study does not consider the psycho-acoustic impacts of noise (how humans perceive various sounds and the psychological affects thereof).

Socio-economic

 The Community Survey 2016 is the most current source of official statistics and this been used to generate a baseline profile of the district and the area directly surrounding the project. The 2011 South African Census was also used to supplement information from the 2016 Community Survey. This data may now be out of date to some degree and may no longer accurately reflect the current socio-economic profile.  The risk of subsidence is considered to be low due to the depth of mining (approximately 1 800 mBC), so a subsidence study was not conducted as part of the EIA. Similarly, the influence from blasting for underground mining was not assessed due to the depth of mining.  The cumulative or extended (time-wise) emissions/ impacts from the use of existing ERGO Processing Plant, TSFs and associated pipelines by ERPM Ext 2 Mine was not considered as part of this EIA and should be considered prior to construction.

ERPM Ext 2 Mine, East Rand, Gauteng 150 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

Visual

 Visual perception is a subjective experience. As such, it is influenced largely by personal values. Such differences in perception are greatly influenced by culture, education and socio-economic background. A degree of subjectivity is therefore bound to influence the rating of visual impacts. In order to limit such subjectivity, a combination of quantitative and qualitative assessment methods has been used.  It is assumed that the data used in this study provided by the technical team and others is accurate.

Hydrogeology

 The surface streams in the area are structurally controlled and water losses to those structures are possible. Therefore, it is possible that decant from the mine can occur via these geological structures. Decant positions may be influenced by interconnection with the ERPM Ext 1 mine area, and by extension interconnection to the South East Vertical Shaft, the Hercules Shaft, the Central Shaft, the Rose Deep compartment, and others. Due to the complexity of the karstic geology, the interconnection between different underground mines, and the internal operations of each of the mine in terms of plugging of levels etc., it is not possible to currently identify extent or position of decant with the level of information that is available. It is recommended that a detailed regional assessment of the different interconnected mines and the geological information available from each of the mines be done in order to be able to identify decant positions and volumes to an acceptable level of confidence.  Once the excavations reach the karstic dolomitic aquifer it is not possible to calculate the expected groundwater inflows. This is due to the heterogeneous nature of the karstic host rock where the excavation can move from competent zones, which have a very low transmissivity and very low associated groundwater flows (< 1 L/s), into karstic channels with extremely high transmissivities and very high flow rates (>100 L/s) within less than 1 m. Very little information is available on the overlying karstic aquifer or individual geological structures that could control groundwater inflows. At this stage it is unknown whether the excavation will pass through high yielding karstic channels. The mine inflow is based on mining operations of around 1 000 m below surface. It is unknown whether this inflow will extend down to 2 000 and 2 500 m below surface. The impacts of the mine dewatering on the overlying aquifers could not be predicted. It is anticipated that at that depth, groundwater will flow along discrete geological structures that act as groundwater flow paths therefore, regional or general dewatering of the host geology is expected to not occur.

Terrestrial Ecology

 The ecological assessment was confined to the study area and did not include the neighbouring and adjacent properties; these were however considered as part of the desktop assessment.  With ecology being dynamic and complex, some aspects may have been overlooked. It is, however, expected that most floral and faunal communities have been accurately assessed and considered.  Due to the nature and habits of most faunal taxa, it is unlikely that all species would have been observed during a field assessment of limited duration. Therefore, site observations were compared with literature studies where necessary.  Sampling by its nature means that not all individuals are assessed and identified. Some species and taxa within the study area may have been missed during the assessment.  The data presented in the study are based on one site visit, undertaken on the 9th May 2019. A more accurate assessment would require that assessments take place in all seasons of the year. However, on-site data was significantly augmented with all available desktop data. Together with the project experience in the area, the findings of this assessment are considered to be an accurate reflection of the ecological characteristics of the study area.

Hydrology

 The stream flowing to the east of the Windmill Shaft SDA does not have a name and was not sampled as flow in this stream mostly comprises of raw sewage due to broken/blocked sewage pipeline.  There is a single DWS flow gauging station, Station C2H136, in the Rietspruit. This gauging station is located right at the outlet of quaternary catchment C22C, i.e. immediately upstream from the Rietspruit's confluence with the Klip River.

ERPM Ext 2 Mine, East Rand, Gauteng 151 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

This gauging station has only been operational since 2011 and thus has very limited time coverage. In fact, it does not even cover a full 11-year solar cycle. Therefore, flow data from this catchment is limited, in order to determine a flow pattern over time with a reasonable measure of accuracy, one needs to cover at least one solar cycle (preferably more than one).  There are no rainfall or evaporation records for the ERPM Ext 2 study area. It was therefore necessary to access the DWS National Database to acquire this data.  A variety of models were used for the hydrology study, these models all need input data. Justification for using the data in the model are provided in the hydrology report.  The actual volume of groundwater encountered near the surface remains an unknown until actual sinking of the shafts begins.

Aquatic Ecology and Wetlands

 Due to the degree to which the site has been disturbed, the watercourse delineations as presented in this report are regarded as a best estimate of the watercourse boundaries, based on the site conditions present at the time of assessment. GPS technology is inherently inaccurate and some inaccuracies due to the use of handheld GPS instrumentation may occur.  Freshwater and terrestrial zones create transitional areas where an ecotone is formed as vegetation species change from terrestrial to obligate/facultative species. Within this transition zone, some variation of opinion on the watercourse boundary may occur.  With ecology being dynamic and complex, certain aspects may have been overlooked.

Hydropedology

 Hydropedological science and research is rapidly evolving and there are currently no standard methods to assess and/or model the recharge capacity of soils. As a result, the findings of this assessment are therefore a mix of qualitative and quantitative results and based on the specialist’s training, opinion and experience with the hydrological properties of the identified soil types.  Sampling by definition means that not all areas are assessed, and therefore some aspects of soil and hydropedological characteristics may have been overlooked in this assessment.  A hydropedological classification of soils outside of the ERPM Expansion were also verified in order to understand the hillslope processes. Hydropedological soil types outside of the ERPM Expansion were not mapped as part of this study but were considered in developing the conceptual model of the hydropedological flow paths of the landscape.  The effects of climate change dynamics were not considered as part this assessment. It is acknowledged that this might exacerbate the anticipated reduction in water inputs and the resultant hydrological function of the remaining wetlands beyond the extent of the proposed development. j) Reasoned opinion as to whether the proposed activity should or should not be authorised i) Reasons why the activity should be authorized or not

The findings of the EIA indicated that the layout would not result in any fatal flaws in terms of environmental and socio- economic impacts, if the recommended mitigation measures (Section 4(g) of the EMPr Part B of this document) are implemented. ii) Conditions that must be included in the authorisation

 Land use agreements between the Applicant and affected landowner(s) must be finalised prior to the commencement of construction.  A land use application must be submitted to the Local Authority in terms of the Spatial Planning and Land Use Management Act, 2013 (Act 16 of 2013), and approval obtained before undertaking further mining activities. This is in order to inform and acquire the land use rights for mining.

ERPM Ext 2 Mine, East Rand, Gauteng 152 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

 Water, sanitation and electricity service level agreements must be obtained.  A WULA must be submitted to the DWS, and approval obtained before commencing with any water use related activities.  ERPM Ext 1 must apply for the necessary nuclear authorisation prior to conducting work in affected areas.  Further discussions must take place between the Applicant, the Municipality and property developers in order to discuss future development plans in the area.  ERPM Ext 1 must confirm that ERGO has sufficient capacity at their existing Processing Plant, TSFs and associated pipelines to manage and process the ore and additional tailings material from ERPM Ext 2 and ERPM Ext 1 must draw up a suitable agreement with ERGO for the processing of the ore and for the tailings disposal.  Further investigation is required into the risk of potential surface subsidence and undermining of the surrounding residential areas. A detailed assessment by a specialist rock engineer must be undertaken and appropriate management and mitigation measures commensurate to the level of risk must be put in place and implemented.  Further investigation is required into the potential for decant of groundwater (regional groundwater model) and groundwater volumes to be encountered during mining (local groundwater model). More detailed geohydrological information is required prior to construction. Appropriate management and mitigation measures commensurate to the level of risk must be put in place and implemented.  Should PR243 be granted as a Mining Right, and be incorporated with MR150 and MR151 (adjacent mining rights), a Section 102 process should be followed to consolidate a suitable EMPr that addresses the full extent of potential impacts (including cumulative impacts) from all three mining rights.  The commitments as per this EMPr (Part B) in terms of mitigation (detailed in Section 1(f)) as well as monitoring (detailed in Section 1. (g)) must be adhered to.  Rehabilitation and closure must be undertaken as per the Closure Plan (refer to Appendix 21) and as agreed with the CA (DMR), as per the EA.

(1) Specific conditions to be included into the compilation and approval of EMPr

All recommended measures have been included as commitments in this EMPr (Part B) which must be adhered to.

(2) Rehabilitation requirements

Rehabilitation requirements have been provided for in the Closure Plan (refer to Appendix 21) which must be adhered to. k) Period for which the Environmental Authorisation is required

The period for which authorisation is 58 years and it is estimated that construction will commence in 2022 therefore final closure is expected in 2080. l) Undertaking (Confirm that the undertaking required to meet the requirements of this section is provided at the end of the EMPr and is applicable to both the Environmental Impact Assessment report and the Environmental Management Programme report)

The undertaking (Part B, Section 2) is applicable to both the EIAR (this section, Part A) and the EMPr (Part B). m) Financial Provision (State the amount that is required to both manage and rehabilitate the environment in respect of rehabilitation)

As per the NEMA Regulations on Financial Provisioning (GN1147 of 2015 and GN667 of 2019) the sum of the financial provision has been included in the EMPr.

The financial provision for the final rehabilitation, decommissioning and closure (Total 1) of the mining activities related to the disturbance that will occur in the first year of operation of the proposed ERPM Ext 2, has been calculated to be R 7,384,237 (value as per date of assessment - 2019).

ERPM Ext 2 Mine, East Rand, Gauteng 153 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

The financial provision for the residual environmental impacts (Total 2) that are expected to manifest in the future based on an unscheduled closure on the anticipated disturbed area for the first year of operation is calculated as R 1,062,818.

The total amount to be set aside for closure and rehabilitation of the activities proposed in the first year of operation of the proposed ERPM Ext 2 (Total 1 + Total 2 = sum (1 + CPI plus 2%) x VAT), is R 8,447,055. i) Explain how the aforesaid amount was derived

As per GN1147 of 2015 and GN667 of 2019 the financial provision must be determined through a detailed itemisation of all activities and costs based on actual market related rates for implementing activities for annual rehabilitation, final rehabilitation, decommissioning and closure and remediation of latent or residual environmental impacts. Costs must be calculated for the rehabilitation, remediation, maintenance and long-term monitoring activities undertaken by a third party. The degree of accuracy of the costs is dependent on the time to the end of life of the mine, with the accuracy of -50% to +50% for the end of operation > 30 years from the year of assessment.

As per GN667 of 2019, the determination of the financial provision for new operations must include the costs associated with rehabilitation and management of impacts arising from:

 The anticipated disturbance of the first year of mining operations;  The residual and latent impacts associated with the anticipated disturbance for the first year of mining operations; and  The impacts of inflation on the costs of a third-party closure. Therefore, in order to calculate the costs to be set aside by ERPM Ext 1 for rehabilitation, decommissioning and mine closure of ERPM Ext 2, which is a new operation, the following formula was used:

Total 1 + Total 2 = sum (1 + CPI plus 2%) x VAT

 Total 1 reflects the costs calculated in the final rehabilitation, decommissioning and mine closure plan for the rehabilitation and impact management related to the disturbance that will occur in the first year of the operation; and  Total 2 reflects the costs calculated in part 2 of the risk assessment report for the determination of residual and latent liability, which are the costs calculated for the management and rehabilitation of residual and latent impacts that are expected to manifest in the future based on an unscheduled closure on the anticipated disturbed area for the first year of operation. The Guideline for Evaluation of the Quantum for Closure-Related Financial Provision compiled by the then Department of Minerals and Energy (DME) (now DMR) was used to inform the itemised breakdown. The guideline rates were however adjusted using market related contractor rates to provide actual costs for decommissioning and rehabilitation.

Identification of the extent of the disturbance through measurement of areas, volumes and lengths of proposed infrastructure and developments for each applicable closure component were calculated using the proposed high level mine plan. Since ERPM Ext 2 is a new mine and the construction stage will take approximately 6 years, the closure plan currently includes the costs for the rehabilitation of activities which are planned for the first year of construction only:

 Removal of access roads – rip, doze and shape roads, placement of topsoil and establishment of vegetation  Removal and rehabilitation of buildings – Dismantling and removing of buildings, rip levelled land, and vegetation establishment  Sealing of shaft B – Remove associated infrastructure, seal shaft  Rehabilitation of WRD – profiling of disturbed areas, and establishment of vegetation on dump  Rehabilitation of PCD – removal and disposal of single HDPE liner, backfilling of the final void, profiling and establishment of vegetation  General rehabilitation – general ripping, profiling of disturbed areas, establishment of vegetation and reinstatement of drainage lines  Removal of fences – dismantling of security fence.

ERPM Ext 2 Mine, East Rand, Gauteng 154 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019 ii) Confirm that this amount can be provided for from operating expenditure (Confirm that the amount, is anticipated to be an operating cost and is provided for as such in the Mining work programme, Financial and Technical Competence Report or Prospecting Work Programme as the case may be)

Financial Provision is provided for as a regulatory cost (under the environmental cost category) in the Mining Work Programme (Regulation 11 (1) (g)(vi). n) Deviations from the approved scoping report and plan of study i) Deviations from the methodology used in determining the significance of potential environmental impacts and risks (Provide a list of activities in respect of which the approved scoping report was deviated from, the reference in this report identifying where the deviation was made, and a brief description of the extent of the deviation)

The methodology used in determining the significance of impacts or risks has been amended since the Scoping Phase. This was to present a simpler risk-based assessment, considering impacts in a manner that assesses the significance of impacts relative to each other. It also assisted with the removal of potential specialist and consultant bias and rated the uncertain risks / impacts more highly than those which could be fairly accurately predicted and mitigated. ii) Motivation for the deviation

The deviation assisted with the relative assessment of impact significance, removing possible specialist and consultant bias. o) Other Information required by the competent Authority i) Compliance with the provisions of sections 24(4)(a) and (b) read with section 24 (3) (a) and (7) of the National Environmental Management Act (Act 107 of 1998). the EIA report must include the:-

(1) Impact on the socio-economic conditions of any directly affected person (Provide the results of Investigation, assessment, and evaluation of the impact of the mining, bulk sampling or alluvial diamond prospecting on any directly affected person including the landowner, lawful occupier, or, where applicable, potential beneficiaries of any land restitution claim, attach the investigation report as an appendix and confirm that the applicable mitigation is reflected herein)

Directly affected persons include:

Landowners of the properties where the surface infrastructure is to be located

The landowners of the properties where the surface infrastructure is to be located have been identified as Eggbert Eggs (Portion 5 of the farm Witpoortje 117 IR) and Ms Suzanne Weitze (Portion 19 of the farm Witpoortje 117 IR). . It is anticipated that a suitable lease / purchase / compensation agreement will be drawn up between ERPM Ext 1 and the landowners for the use of this land.

Adjacent Landowners and Occupiers and Surrounding Communities (including Geluksdal, Laborê, Tsakane, KwaThema, Withok Estates, Dawn Park, Windmill Park, Villa Lize, Sonneveld, Minnebron and Sunair Park)

Potential negative impacts include:

 Once the mine closes, there will be a loss of employment.  In-migration of job-seekers into the project area could potentially result in the establishment or expansion of informal settlements, and associated increase in social ills (including crime), and decreased safety and security of residents in both the smallholding residential areas and the high-density areas surrounding the proposed development.  Rural residences to the immediate east and north of the Windmill SDA will be affected by dust generated during the development of the SDA as well as from the access roads during the construction and operational phases of the mine. The dust generated as a result of traffic on the unpaved access road to Witpoortje SDA has the potential to

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impact negatively on the rural smallholding located due west of the SDA. The dust impacts will be most prevalent during the drier winter months but may also occur during other extended dry periods. The dust impacts are unlikely to cause health impacts but could be regarded as a ‘nuisance’ by the residents.  Surrounding ambient noise levels will increase as a result of operation activities which is likely to cause nuisance to residents specifically at night.  Due to the depth of the proposed mine there is not expected to be any risk of subsidence.  The proposed shafts may have negative visual impacts for adjacent residents having partially obstructed permanent views of the shaft areas. Residents living on the gravel road adjacent to the Windmill Shaft SDA would be the most affected receptors due to the unobstructed nature of the surrounding environment, and lack of screening vegetation.  The construction and operation phases of underground mining at ERPM Ext 2 is predicted to have little to no impact on the quantity and quality of water in privately owned boreholes in the vicinity of the Windmill SDA and the Witpoortje SDA.

Potential positive impacts include:

 Employment opportunities (It is estimated that the mine will create at least 976 employment opportunities), skills development and increased opportunities for SMMEs and stimulation of growth in the local area to provide goods and services to the mine and its employees.  Contribution to the local economy as construction and operation activities will stimulate the local manufacturing and service sectors, providing new business opportunities.  Reduction in illegal mining activities and increased security presence.

Land Claimants

Land claim enquiries were submitted to the Office of the Regional Land Claims Commissioner: Gauteng Province. The following is the outcome of the enquiry (refer to Appendix 5):

 Farm Witpoortje 117 IR – A claim was lodged (portions not specified) between 1 July 2014 and 27 July 2016 (therefore considered a “new” claim)  Farm Withok 131 IR – Claims have been lodged (portions not specified) between 1 July 2014 and 27 July 2016 (therefore considered a “new” claim)  Farm Glen Roy 132 IR – No land claims have been lodged  Farm Rooikraal 156 IR – No land claims have been lodged  Geluksdal Agricultural Holding Ext 1, 2 and 3 – No land claims have been lodged  Labore Agricultural Holdings Ext 1 and 2 – No land claims have been lodged

According to the Regional Land Claims Commissioner, ERPM is not required to notify the claimant (and contact details of the claimant would not be made available) as section 11 (7) of the Restitution Act does not apply.

Detailed socio-economic impact assessment

The socio-economic study identifies the impacts on the socio-economic conditions of directly affected persons. The study provides more detail and attaches a likelihood and significance value to each of these impacts. Refer to Appendix 14 for the detailed socio-economic impact assessment.

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

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Heritage and Archaeology

According to the Heritage Impact Assessment, dated June 2019 (Appendix 9), one site of high heritage significance was identified within the footprint of the proposed Witpoortje Vent Shaft SDA. The site contains at least 48 graves. Nine of these are marked, and the rest are unmarked. The oldest date of death indicated is 1889 and the youngest is 1920. This means there two of the categories of graves are present being unknown graves and heritage graves (older than 60 years).

The first option would be to fence the graves in and have a management plan drafted for the sustainable preservation thereof. This should be written by a heritage expert. This usually is done when the graves are in no danger of being damaged, but where there will be a secondary impact due to the development activities. The second option is to exhume the mortal remains and then to have it relocated. This usually is done when the graves are in the area to be directly affected by the development activities. For this a specific procedure should be followed which includes social consultation. For graves younger than 60 years, only an undertaker is needed. For those older than 60 years and unknown graves an undertaker and archaeologist is needed. Permits should be obtained from the Burial Grounds and Graves unit of SAHRA. The type of development makes it possible to keep the graves in situ. It is therefore recommended that it be included in the development planning and that Option 1 be implemented.

Palaeontology

According to the palaeontology study, dated June 2019 (Appendix 10), the Witpoortje Vent Shaft SDA is on ancient volcanic rocks of the Klipriviersberg Formation and is non-fossiliferous. The Windmill Shaft SDA is positioned on non-fossiliferous Jurassic dolerite dyke but the north east corner is on dolomite of the Malmani Subgroup that might preserve trace fossils, namely stromatolites. No fossils or stromatolites have been reported from this area but because there is a small chance of finding fossils mitigation measures for chance finds have been included in the EMPr [this document, Section 4(g)]. p) Other matters required in terms of sections 24(4)(a) and (b) of the Act (the EAP managing the application must provide the competent authority with detailed, written proof of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or feasible alternatives, as contemplated in sub-regulation 22(2)(h), exist. - the EAP must attach such motivation as an appendix)

Site, layout, technological and operational alternatives were assessed for the project during the Scoping Phase as required by section 24(4)(b)(i). No further alternatives have been assessed as part of the EIA phase. The layouts (refer to Figure 5 and Figure 7) were selected as the preferred layouts. This EIAR addresses the following requirements in terms of sections 24(4)(a) and (b) of the Act:

Section Description of how the aspect has been Contents of NEMA addressed Section 24(4)(a) Procedures for the investigation, assessment and communication of the potential consequences or impacts of activities on the Refer to Section 3.iii) for the methodology used for the 24(4)(a) environment – assessment of impacts. must ensure, with respect to every application for an EA: The Scoping Report and EIAR were made available to all the relevant organs of state: the CoE as the relevant municipality; DAFF as the authority for agricultural land and forestry; DWS for activities requiring a WUL; GDARD as the authority regarding Coordination and cooperation between organs of state in the environmental matters; PHRAG (via SAHRIS) as the 24(4)(a)(i) consideration of assessments where an activity falls under the authority regarding cultural heritage matters; DRDLR jurisdiction of more than one organ of state; as the authority regarding land affairs; Gautrans as the road authority; Eskom as the authority relating to electricity infrastructure; and the Gauteng Department of Community Safety as the authority regarding community safety - for comment during the PPP. The DMR remains the CA. That the findings and recommendations flowing from an The findings and recommendations of specialist 24(4)(a)(ii) investigation, the general objectives of integrated environmental investigations, and general objectives and the management laid down in this Act and the principles of principles of environmental management, were

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Section Description of how the aspect has been Contents of NEMA addressed environmental management set out in section 2 are taken into addressed in this EIAR and EMPr. Refer to Section account in any decision made by an organ of state in relation to any 1.f) of the EMPr - part B of this document. proposed policy, programme, process, plan or project; Refer to Section 3.i)(1) for a detailed description of the That a description of the environment likely to be significantly 24(4)(a)(iii) baseline environment likely to be affected by the affected by the proposed activity is contained in such application; project. Investigation of the potential consequences for or impacts on the Refer to Section 3.ii) and Appendix 20 for the 24(4)(a)(iv) environment of the activity and assessment of the significance of assessment of the potential impacts. those potential consequences or impacts; and Public information and participation procedures which provide all IAPs, including all organs of state in all spheres of government that Refer to Section 3.ii) which details the Scoping phase 24(4)(a)(v) may have jurisdiction over any aspect of the activity, with a and EIA phase PPP followed. reasonable opportunity to participate in those information and participation procedures; and Where EIA has been identified as the environmental instrument to EIA has been identified as the environmental 24(4)(A) be utilised in informing an application for EA, subsection (4)(b) is instrument therefore (4)(b) is applicable. applicable Section 24(4)(b) Must include, with respect to every application for an EA and where 24(4)(b) applicable: Investigation of the potential consequences or impacts of the Alternatives have been investigated and assessed for alternatives to the activity on the environment and assessment of 24(4)(b)(i) the project, including the option of not implementing the significance of those potential consequences or impacts, the activity. Refer to Section 3.vi) and 3.vii). including the option of not implementing the activity; Mitigation measures for potential impacts identified Investigation of mitigation measures to keep adverse 24(4)(b)(ii) have been identified. Refer to Section 1.f) of the consequences or impacts to a minimum; EMPr- Part B of this document. Investigation, assessment and evaluation of the impact of any proposed listed or specified activity on any national estate referred The NHRA has been taken into account, and a 24(4)(b)(iii) to in section 3(2) of the National Heritage Resources Act, 1999 (Act heritage assessment has been undertaken. Refer to No. 25 of 1999), excluding the national estate contemplated in Section 3.i)(1) and Appendix 9. section 3(2)(i)(vi) and (vii) of that Act; Reporting on gaps in knowledge, the adequacy of predictive The gaps have been identified as informed by the 24(4)(b)(iv) methods and underlying assumptions, and uncertainties specialist studies. Refer to Section 3.i). encountered in compiling the required information; Management and monitoring measures have been specified in sections 1.f) and 1.i.g) of the EMPr - Part Investigation and formulation of arrangements for the monitoring B of this document respectively. Implementation and and management of consequences for or impacts on the suitability of the EMPr will be audited every second 24(4)(b)(v) environment, and the assessment of the effectiveness of such year as required by Regulation 55 of the MPRDA as arrangements after their implementation; well as per the frequency indicated in the ROD as per of Regulation 34 of the NEMA EIA Regulations, GNR982 of 2014 (as amended by GNR326 of 2017). Consideration of environmental attributes identified in the 24(4)(b)(vi) compilation of information and maps contemplated in subsection (3); and Refer to Section 3.i)(1) for maps indicating The Minister, or an MEC with the concurrence of the Minister, may geographical areas, including the sensitivity, extent, compile information and maps that specify the attributes of the interrelationship and significance of such attributes 24(3) environment in particular geographical areas, including the informed by maps compiled by relevant departments. sensitivity, extent, interrelationship and significance of such attributes which must be taken into account by every CA. Listed activities for the ERPM Ext 2 Mine have been identified. The EIA has been identified as the environmental instrument in terms of NEMA. An AEL is not required as per NEMAQA. A WML is required Provision for the adherence to requirements that are prescribed in as per NEMWA. Permits may be required as per 24(4)(b)(vii) a specific environmental management Act relevant to the listed or NEMBA for the SCC identified. The area does not fall specified activity in question. within a protected area as per NEMPAA. A WUL is required and a Pre-Application Water Use Enquiry has been submitted to DWS via the e-WULAAS online system.

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PART B ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

1) DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME

a) Details of the EAP (Confirm that the requirement for the provision of the details and expertise of the EAP are already included in PART A herein as required)

The details of the EAP are provided in Part A, Section 3.

b) Description of the Aspects of the Activity (Confirm that the requirement to describe the aspects of the activity that are covered by the environmental management programme is already included in PART A herein as required)

The aspects of the activity covered by the EMPr are detailed in Part A, Section a)d).

c) Composite Map (Provide a map at an appropriate scale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffers)

Refer to Figure 34.

d) Description of Impact management objectives including management statements i. Determination of closure objectives (ensure that the closure objectives are informed by the type of environment described herein)

The current preferred option for closure of the mine is to rehabilitate the areas disturbed by mining activities to an acceptable and sustainable end land-use, in line with planning objectives where possible.

The current closure vision is to:

 Develop a landform that is free draining, with established (in terms of re-vegetation), self-sustaining vegetation;  Develop a landscape that is aesthetically acceptable (i.e. as inconspicuous as possible in relation to the existing landscape);  Ensure that closure supports sustainable end land uses considering pre-mining conditions and are in agreement with commitments to stakeholders;  Ensure that community safety is not adversely impacted (i.e. the area is stable and that shafts are sealed effectively); and  Ensure adherence to local, provincial and national regulatory requirements.

The shafts will be sealed and the WRD at Windmill Shaft is to remain in situ at closure. Infrastructure determined to be required for residual pollution control will also remain post-closure, such as the pollution control dam. Refer to the closure plan for the infrastructure to remain post-closure.

Although the shafts will be sealed during the closure phase, the land use at the Windmill Shaft (specifically around the sealed shafts and WRD) will not be appropriate for urban development due to potential safety concerns associated with the historical mining. The proposed final end land use for the disturbed areas is industrial and / or large commercial development or low intensity grazing and/or wilderness.

The Closure Plan (Appendix 21) provides specific goals for each of the above-mentioned aspects to achieve the main closure objective for the proposed ERPM Ext 2 Mine.

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ii. The process for managing any environmental damage, pollution, pumping and treatment of extraneous water or ecological degradation as a result of undertaking a listed activity

The potential for decant to occur post-closure, as well as the probable locations of decant points, are currently unknown. Further investigation is required and a regional numerical groundwater model must be developed. Based on current information, the management of impacts as a result of undertaking a listed activity will be as per the measures detailed in the EMPr (Part B of this document) in Section f).

iii. Potential risk of acid mine drainage (Indicate whether or not the mining can result in acid mine drainage)

The following information was provided by the hydrology specialist (Krige, 2019) and the hydrogeology specialist study (Prinsloo, 2019). The proposed ERPM Ext 2 shafts will be deep and the underground workings are expected to contain high concentrations of dissolved sulphide and iron in their reduced state. Once mining introduces water, oxygen and oxidising conditions to the rocks deep below the surface and/or when these rocks are brought to surface, the acid mine drainage reactions may start depending on the composition of the rock. The leaching of sulphate from the Witwatersrand rocks will continue during underground mining and in the WRD on surface. The surface deposits (including the tailings dam) will further continue producing AMD for extended periods, well after mining has ceased. After closure, the groundwater will rise along with the dissolved minerals and may eventually decant onto surface.

iv. Steps taken to investigate, assess, and evaluate the impact of acid mine drainage

A geohydrology specialist study and a hydrology specialist study were undertaken to understand the impacts associated with the proposed mine. The mine will be deep and therefore, other deep mines in the Witwatersrand area are used to investigate the impact of the proposed project. Other, similar sites indicate that the material experienced at such depths can be expected to be acid generating. Furthermore, the quantity of groundwater inflow may between 16 000 and 28 000 m3/day but further investigations are required to gain more confidence in the volumes of groundwater to be encountered underground, and the potential contamination of the groundwater via the formation of AMD (Future Flow, 2019). The impact assessment has considered that the probability of AMD being generated and decanting on surface is probable, based on the precautionary principle. It is therefore identified as a key finding of the impact assessment and requires further investigation.

v. Engineering or mine design solutions to be implemented to avoid or remedy acid mine drainage

A treatment plant will be installed during the construction phase of the project. Additional investigations into improving confidence in the volumes and potential for decant of groundwater will be undertaken, and will inform the selection / design / location of the water treatment plant. All excess water will need to be treated prior to discharge. Appropriate liners will be used for all stockpiles and waste facilities.

vi. Measures that will be put in place to remedy any residual or cumulative impact that may result from acid mine drainage

A management strategy will need to be incorporated into the mine design once the potential for decant of contaminated water has been confirmed. An appropriate water treatment facility will need to be put in place based on the findings of further investigation.

vii. Volumes and rate of water use required for the mining operation

Due to the heterogenous character of the rock, estimates of volume of water that will be encountered varies considerably. At this stage the exact quantity of water is unknown and further investigations and modelling are required.

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viii. State whether a Water Use Licence has been applied for

A Pre-Application Water Use Enquiry has been submitted to DWS via the e-WULAAS online system.

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i. Impacts to be mitigated in their respective phases (Measures to rehabilitate the environment affected by the undertaking of any listed activity)

Phase of Size and operation in Listed activities APPLICABLE LISTING NOTICE scale of which activity disturbance will take place Listing Notice 2 (GNR984 of 2014) (As amended by GNR325 of 2017) Activity 17 3 850 ha Underground mining Any activity including the operation of that activity which requires a mining right as contemplated in section 22 of the Mineral and Petroleum Resources Construction and (below activities Development Act, 2002 (Act No. 28 of 2002), including associated infrastructure, structures and earthworks, directly related to the extraction of a mineral operation ground resource, including activities for which an exemption has been issued in terms of section 106 of the Mineral and Petroleum Resources Development Act, geology) 2002 (Act No. 28 of 2002). Listing Notice 1 (GNR983 of 2014) (As amended by GNR327 of 2017) Activity 2 (No longer applicable) The development and related operation of facilities or infrastructure for the generation of electricity from a non-renewable resource where- (i) the electricity output is more than 10 megawatts but less than 20 megawatts; or (ii) the output is 10 megawatts or less but the total extent of the facility covers an area in excess of 1 hectare. Surface infrastructure Activity 9(No longer applicable) including The development of infrastructure exceeding 1000 metres in length for the bulk transportation of water or storm water- refrigeration plant, (i) with an internal diameter of 0,36 metres or more; or access shaft and (ii) with a peak throughput of 120 litres per second or more; excluding where- associated head (a) such infrastructure is for bulk transportation of water or storm water or storm water drainage inside a road reserve; or (b) where such development will occur within an urban area. gear, vent shaft,

change house, Activity 10(No longer applicable) administrative The development and related operation of infrastructure exceeding 1000 metres in length for the bulk transportation of sewage, effluent, process water, buildings, waste water, return water, industrial discharge or slimes workshops, water (i) with an internal diameter of 0,36 metres or more; or treatment plant, (ii) with a peak throughput of 120 litres per second or more; excluding where- powerlines (power (a) such infrastructure is for bulk transportation of sewage, effluent, process water, waste water, return water, industrial discharge or slimes inside a Construction and road reserve; or 27 ha supply connection), operation (b) where such development will occur within an urban area. water pipelines, salvage yard, topsoil Activity 14(No longer applicable) stockpiles, The development of facilities or infrastructure, for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in stormwater and containers with a combined capacity of 80 cubic metres or more but not exceeding 500 cubic metres. pollution control infrastructure, bulk Activity 16 The development and related operation of facilities for the desalination of water with a design capacity to produce more than 100 cubic metres of fuel storage, treated water per day. explosives handling area, access roads, Activity 20 (New activity not included in EA application) parking area, a Any activity including the operation of that activity which requires a prospecting right in terms of section 16 of the Mineral and Petroleum Resources stores area and a Development Act, 2002 (Act No. 28 of 2002). backfill / grout plant Activity 25 The development and related operation of facilities or infrastructure for the treatment of effluent, wastewater or sewage with a daily throughput capacity of more than 2000 cubic metres but less than 15000 cubic metres.

Activity 28

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Phase of Size and operation in Listed activities APPLICABLE LISTING NOTICE scale of which activity disturbance will take place Residential, mixed, retail, commercial, industrial or institutional developments where such land was used for agriculture or afforestation on or after 01 April 1998 and where such development: (i) will occur inside an urban area, where the total land to be developed is bigger than 5 hectares; or (ii) will occur outside an urban area, where the total land to be developed is bigger than 1 hectare; excluding where such land has already been developed for residential, mixed, retail, commercial, industrial or institutional purposes.

Activity 30 Any process or activity identified in terms of section 53(1) of the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004).

Activity 6 The development of facilities or infrastructure for any process or activity which requires a permit or licence in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent, excluding (i) activities which are identified and included in Listing Notice 1 of 2014; (ii) activities which are included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental Management: Waste Act, 2008 applies; or (iii) the development of facilities or infrastructure for the treatment of effluent, wastewater or sewage where such facilities have a daily throughput capacity of 2 000 cubic metres or less.

Activity 21

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Phase of Size and operation in Listed activities APPLICABLE LISTING NOTICE scale of which activity disturbance will take place Any activity including the operation of that activity associated with the primary processing of a mineral resource including winning, reduction, extraction, classifying, concentrating, crushing, screening and washing but excluding the smelting, beneficiation, refining, calcining or gasification of the mineral resource in which case activity 6 in this Notice applies.

Listing Notice 3 (GNR985 of 2014) (As amended by GNR324 of 2017) Activity 4(No longer applicable) The development of a road wider than 4 metres with a reserve less than 13,5 metres. In Gauteng – iv. Sites identified as Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs) in the Gauteng Conservation Plan or in bioregional plans; v. Sites identified within threatened ecosystems listed in terms of the National Environmental Management Act: Biodiversity Act (Act No. 10 of 2004). Activity 10(No longer applicable) The development of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 30 but not exceeding 80 cubic metres. In Gauteng – iv. Sites identified as Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs) in the Gauteng Conservation Plan or in bioregional plans; v. Sites identified within threatened ecosystems listed in terms of the National Environmental Management Act: Biodiversity Act (Act No. 10 of 2004); vi. Sensitive areas identified in an environmental management framework adopted by relevant environmental authority; vii. Sites identified as high potential agricultural land in terms of Gauteng Agricultural Potential Atlas; Activity 12 The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan. In Gauteng - i. Within any critically endangered or endangered ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004; ii. Within critical biodiversity areas identified in bioregional plans; Activity 15 The transformation of land bigger than 1000 square metres in size, to residential, retail, commercial, industrial or institutional use, where, such land was zoned open space, conservation or had an equivalent zoning, on or after 02 August 2010. Project activities that Listing Notice 2 (GNR984 of 2014) (As amended by GNR325 of 2017) require a WULA - Activity 6 including dewatering, The development of facilities or infrastructure for any process or activity which requires a permit or licence in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent, excluding abstraction, dust Construction and (i) activities which are identified and included in Listing Notice 1 of 2014; 27 ha suppression, (ii) activities which are included in the list of waste management activities published in terms of section 19 of the National Environmental Management: operation discharge, pollution Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental Management: Waste Act, 2008 applies; or control dam, and (iii) the development of facilities or infrastructure for the treatment of effluent, wastewater or sewage where such facilities have a daily throughput capacity river crossings. of 2000 cubic metres or less.

Refer to Section below for potential impacts, mitigation measures, compliance with standards and time period for implementation for all the activities including the listed activities.

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e) Impact management outcomes (A description of impact management outcomes, identifying the standard of impact management required for the aspects requiring management)

Table 13: Standard guiding impact management outcomes Activity Aspect Potential impact Project phase Mitigation Type Standard to be achieved Vehicles travelling on unpaved Dust generation Air quality Construction;  Control dust generation through monitoring dust fallout and Control the generation of dust and roads, wind erosion of cleared deterioration Operation public consultation monitor the dust fall out. Limit dust areas and stockpiles, blasting  Control dust through the management of dust generating generated to below the threshold as per activities and venting poor activities and application of dust palliatives. the NEMAQA National Dust Control quality air. Regulation Standards for residential areas General operations including Release of emissions Air quality Construction;  Control offsite carbon dioxide emissions by selecting energy Limit the emissions generated to below transport and operation of on and off site deterioration Operation efficient equipment the threshold as per the NEMAQA and machines Closure  Control emissions by selecting low sulphur fuel and other the National Ambient Air Quality behavioural modifications Standards (NAAQS) (GN 1210; 2009)  Control emissions through monitoring and management General operations including Generation of noise Nuisance noise Construction  Modify working hours so that noise generating activities occur Avoid noise disturbance of surrounding machinery and blasting during Operation during the day residents; impact as per the relevant construction  Avoid installing equipment exceed 85 – 90 dBA noise output management plan in the EMPr to  Control noise by installing acoustic barriers achieve noise standards (SANS  Control and minimise nuisance noise through public 10103:2008) must be met. consultation and monitoring Blasting during shaft Air blast and Damage to Construction  Control property damage by monitoring and modifying blasting Minimise vibrations and air blast as per construction vibrations structures and techniques to limit vibration and air blast blasting management plan in the EMPr property  Remedy loss / damage of property by compensating affected and use internationally accepted parties. standards for safe blasting for ground vibration and recommendations on air blast e.g. those published by the United States Bureau of Mines (USBM). Inadequate handling of Pollution of the Soil Construction  Modify handling of waste, chemicals and water to minimise the Avoid pollution of the environment from general waste, chemicals and environment contamination; Operation risk and extent of environmental contamination chemicals, construction materials and water. Biodiversity loss; Decommissioning  Minimise the extent of pollution by installing spill mitigating and waste. Manage the aspects as per Habitat loss; pollution control infrastructure relevant management plans in the Groundwater  Limit the extent of contamination by immediately cleaning EMPr; MSDS must be referred to and contamination spills and restoring contaminated areas hazardous materials stored, handled  Control pollution through management and monitoring and transported as per the Hazardous Substances Act No. 15 of 1973 and relevant Regulations. Clearing and grubbing; Erosion of cleared Soil loss Construction;  Modify the flow of stormwater to avoid bare areas and Avoid soil erosion from uncontrolled Soil stockpiling; areas, stockpiled soil, Operation; stockpiles through design and installation of stormwater runoff, conserve soil in the topsoil Lack of storm water and as a result of Closure infrastructure stockpiles and cleared areas. Design management. diverted stormwater  Control the extent of erosion by limiting the extent of bare and construct water management runoff areas infrastructure as per GN704 of 1999 and the DWA Best Practise Guidelines

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Activity Aspect Potential impact Project phase Mitigation Type Standard to be achieved  Enhance the establishment of vegetation on bare areas and stockpiles  Control erosion through monitoring and management  Remedy and restore areas that have been eroded. Shaft and infrastructure Earthworks Disturbance / loss Construction  Avoid disturbance of heritage objects through monitoring Avoid damage to archaeological construction of objects with  Control through creating awareness of chance finds resources (especially graves) manage heritage value  Modify site layout to avoid graves and any observed objects this aspect as per the relevant heritage value management plan in the EMPr and chance finds procedure prepared in line with the NHRA requirements Storage and management of Acid mine drainage Deterioration of Construction;  Modify the design of mineral waste facilities to limit the Minimise the possibility of acid mine mineral waste with acid from mineral waste surface and Operation; generation of acidic conditions based on geochemical results drainage impacting surface and generating potential facilities groundwater Closure  Control contaminated runoff by directing runoff to PCD groundwater resources by adherence quality  Stop seepage from the waste facility by installing appropriate to GNR 704 of the NWA and liner liners requirements of Regulation 635 and  Control contamination of surface and groundwater through 636 of the Waste Act. monitoring and management. Mine closure Aquifer recharge and Deterioration of Post-closure  Control and remedy decant mine water through monitoring Avoid the decant of contaminated mine development and surface and management and treatment water at surface decant of acid mine ground water; drainage Loss of habitat; Biodiversity loss; Soil loss; Loss of land use potential Shaft construction Dewatering of Lowering of Construction  Control the quality of water by installing a pollution control dam All ground water users impacted shall construction areas groundwater  Remedy the temporary loss of groundwater by supplying be compensated with water of sufficient levels; ground water users with water quality and quantity. Loss of surface  Control quantity of water released to the environment by and groundwater sending excess water to the Ergo Plant quality  Control lowering of water level by monitoring and management. Mine construction and Creation of job Community Construction; Modify recruitment practices to: Reduce the social impacts by following operations opportunities upliftment and Operation;  Prioritise those with the requisite skills from the surrounding the relevant labour laws and enhance development Closure areas for employment opportunities ensure people from the positive impacts by complying with The immediate area are considered for positions Mining Charter and The Social and  Maximise the potential benefits to the local economy by Labour Plan (SLP). ensuring that local labour and service providers are utilized wherever possible throughout the various phases of the life of mine  Reduce the impact of downscaling and retrenchment by imparting skills through the skills development programme  Reduce downscaling and retrenchment on closure.

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Activity Aspect Potential impact Project phase Mitigation Type Standard to be achieved Skills development Closure Modify skills development to reduce the impact of downscaling Impart skill that are marketable in other and retrenchment and prioritise training and skills development for roles as per the Skills Development Plan youth and comply with the requirements of the Skills Development Act 97 of 1998. Increased Growth of SMMEs Construction;  Modify purchasing practices for preferential purchasing and Increase opportunities by to local opportunities Operation; procurement procedure to favour SMMEs, use of Historically businesses and SMMEs by: Closure Disadvantaged South African enterprises, and Black  Meeting the procurement targets Economic Empowerment (BEE) contractors set out in the Mining Charter  Modify housing allowances to encourage people will therefore  Complying with the SLP and be expected to live locally and commute to work daily requirements of the EMPr Visual intrusion, dust Negative Construction;  Remedy through the implementation of the EMPr Control the generation of dust and and noise. economic impact Operation; monitor the dust fall out. Limit dust on agricultural Closure generated to below the threshold as per smallholdings and the NEMAQA National Dust Control businesses in the Regulation Standards for residential vicinity of the mine areas Avoid noise disturbance of surrounding residents; impact as per the relevant management plan in the EMPr to achieve noise standards (SANS 10103:2008) must be met. Minimise visual intrusion as much as possible; manage impacts as per the relevant management plan in the EMPr. Attraction of job seekers into Growth of existing Increase in social Construction;  Remedy through consultation with CoE and ongoing and the Consultation with the City of Ekurhuleni the areas (Migration) informal settlements ills and decreased Operation; monitoring of informal settlement creation shared with the to monitor the growth of informal or establishment of safety and relevant departments settlements and to security patrols new informal security.  Remedy by ensuring mine security patrols monitors the should monitor the perimeter areas settlements. perimeter areas thereby providing an increased security thereby providing an increased security presence presence.  Modify people’s movements by supplying workers with transport and not recruiting at the mine entrance. Blasting Fly rock, air blast and Increase in Construction  Modify by making all blasting monitoring reports available to Minimise vibrations and air blast as per vibration insurance any stakeholders. This will allow stakeholders to use this blasting management plan in the EMPr premiums for information to negotiate with their insurance companies if and use internationally accepted homeowners necessary. standards for safe blasting for ground vibration and recommendations on air blast e.g. those published by the United States Bureau of Mines (USBM). Installation of headgear, Installation of tall Loss / Construction;  Control viewshed buy installing screening and maintaining Minimise visual intrusion as much as buildings and lighting infrastructure (such as deterioration of Operation existing vegetation possible; manage impacts as per the shaft headgear) and viewshed;  Modify infrastructure height by minimising vertical dimensions relevant management plan in the EMPr lighting Light pollution  Control light pollution by limiting lighting to bare minimum required for safety and security.

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Activity Aspect Potential impact Project phase Mitigation Type Standard to be achieved Alien and invasive species Introduction of alien Biodiversity loss; Construction;  Control alien and invasive through monitoring and species Limit and the spread of alien invasive allowed to proliferate and and invasive Habitat Operation; eradication vegetation. Avoid the species; monitor change in land management vegetation through transformation Decommissioning and eradicate alien invasive vegetation disturbance of the species as per the relevant area management plan in the EMPr in line with requirements of CARA and NEMBA Shaft and infrastructure Disturbance of Biodiversity loss Pre-construction  Stop species loss by rescuing and relocating species of Rescue and relocate identified species, construction species of concern concern before construction aim for no net loss of individuals in line  Control loss of rescued individuals through monitoring and with requirements of NEMBA. management Environmental rehabilitation Unsuccessful Biodiversity and Decommissioning  Remedy any areas where rehabilitation has failed Land to be rehabilitated to suit pre- rehabilitation habitat loss Post-closure  Enhance revegetation through soil amelioration and reseeding determined end land use in line with (aquatic and  Control impacts through expedient implementation of Municipal planning objectives as terrestrial); rehabilitation actions agreed upon with the DMR. Soil loss; Alteration of hydrology Transport and logistics Increased light and Damage of road Construction;  Remedy and repair damaged roads Repair and rehabilitate road surfaces heavy vehicle traffic. infrastructure; Operation  Modify existing roads with increased traffic to enhance safety and install sufficient infrastructure to Decrease in road  Control through monitoring and managing traffic volumes ease traffic burden. Implement safety;  Enhance safety by limiting traveling speeds measures as per the relevant Increase in management plan in the EMPr. nuisance traffic

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f) Impact management actions (A description of impact management actions, identifying the manner in which the impact management objectives and outcomes contemplated in the paragraphs above will be achieved)

Table 14 provides the Sections of this report where the impact management actions and monitoring measures may be found for each environmental component. The standards to which impact management will be implemented are found in Table 13.

Table 14: Impact management and monitoring Environmental component or aspect Table containing management actions Air quality Table 15 Archaeology and palaeontology Table 16 Biodiversity Table 17 Blasting Table 18 Noise Table 19 Socio-economic Table 20 Soil Table 21 Traffic Table 22 Visual character Table 23 Water Table 24 Hydrocarbon handling Table 25 General waste handling Table 26 Hazardous substances handling Table 27

The sections below detail the management plans to be implemented to manage the potential impacts of the proposed ERPM Ext 2 Mine on the biophysical and socio-economic aspects of the environment.

Environmental Control Officer

An Environmental Control Officer (ECO) must be appointed to ensure that the various management plans detailed herein are implemented and that the necessary auditing, reporting and monitoring are conducted. The ECO should have an appropriate 3-year Bachelor’s degree / National Diploma in Natural, Engineering or Environmental Sciences or related field and preferably experienced in a related or similar field. Until such time as it is possible to employ a suitably qualified ECO, the services of a contracted specialist team must be employed to perform the necessary management / monitoring procedures. The ECO must undergo rigorous training associated with the management plans and monitoring programmes. The ECO will report directly to mine management to ensure that mitigation measures can be approved and installed expediently.

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Table 15: Air quality management measures Aspect Management measure Responsible party Construction, operation and Decommissioning Phases Adhere to mine health and safety requirements in terms of air quality within the boundaries of the proposed development (above and below ground) Health and safety ECO / Health & Safety Officer and audit compliance regularly. Air quality monitoring Implement the Air Quality Monitoring Programme. ECO / Health & Safety Officer Operation near sensitive Record all complaints relating to dust or emissions. Investigate and implement additional management measures to address complaints if monitoring ECO / Health & Safety Officer receptors indicates excessive dust or emissions. Burning Forbid any burning of any vegetation or waste material. ECO / Health & Safety Officer Implement a policy where energy efficient and low emission machinery is chosen if an option is available. ECO Only use vehicles that comply with the relevant emissions standard, ensure that all vehicles and machines undergo regular servicing. ECO Vehicle operation Limit speed on unsurfaced roads to 20km/h. ECO Limit idling, turn off vehicles and machines when not in operation. ECO Use low sulphur fuel throughout LoM including in underground operations. ECO Construction Phase Implement a blast management plan. ECO Blasting Erect screens around initial blast areas, cover further blasts so that dust settles within the shafts. ECO Limit vegetation clearing to areas required for the construction of surface infrastructure as per the approved layout. Clearing and grubbing Handel soils according to the soil management plan. ECO / Construction manager Phase earthmoving activities to reduce the total exposed area at one time. Only clear areas directly prior to the installation of infrastructure. Stabilise wearing course of roads to prevent excessive dust entrainment. Consider a permanent road surface such as tar of paving for the access road ECO to the Windmill SDA as this route will be in use for the proposed 45 year LoM. Locate stockpiles as far away from residential properties as feasible. Exposed areas Wet or use of chemical dust suppressants / palliatives on exposed areas prior to vegetation establishment. ECO / Construction manager Actively establish vegetation on exposed areas as soon as possible. Use indigenous, fast growing tree species as windbreaks where needed. ECO A weather station must be installed on site to at least monitor wind speed and direction, and rainfall, to assist with interpretation and understanding of Weather stations ECO the monitoring results. The wind speed and direction sensor should be installed at an approximate height of 10 m above the ground. Operational Phase Dust suppression using chemical dust suppressants which are environment-friendly, naturally-derived biodegradable suppressants must be Unpaved roads ECO implemented on unpaved access roads. Undertake air quality monitoring at shafts at the surface.to determine compliance with the NAAQS ECO Shaft venting Equip shafts with filters if monitoring results reveal filters are necessary to remove pollutants to ensure compliance with NAAQS. ECO Decommissioning Phase Rehabilitation Rehabilitate and revegetate SDAs as per the Closure Plan to prevent bare areas which are susceptible to wind erosion. ECO

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Table 16: Heritage, archaeology and palaeontology management measures Aspect Management measure Responsible party Prior to Construction Phase Educate personnel and contractors regarding the possible presence of subterranean archaeological and/or paleontological sites, features or artefacts and the penalties associated with the unlawful removal of these artefacts, as set out in the NHRA as part of environmental awareness training during induction Awareness ECO as well as of the chance finds procedure. Include photographs of stromatolites, plant and other fossils in the training to assist in recognizing the fossil in the sandstones. Fence the graves near the Witpoortje Vent Shaft. ECO and Project Manager Conservation Compile a Heritage Management Plan with input from a heritage expert for the sustainable preservation of the graves identified near the Witpoortje Vent ECO/ Archaeologist Shaft. Construction Phase Assign a designated person (geologist) to give rock and excavations a cursory inspection for archaeological or palaeontological objects. ECO / geologist If objects are suspected, initiate the chance finds procedure:  Immediately stop all activities especially the excavation  Notify the ECO immediately  The ECO must then contact SAHRA to investigate the findings. Excavation  Contact an archaeologist and/or palaeontologist with the input from SAHRA, depending on the nature of the find, to assess the importance and ECO / SAHRA / Archaeologist / rescue them if necessary (with the relevant SAHRA permit) Palaeontologist  No work may be resumed in this area without the permission from the ECO and SAHRA.  Under no circumstances shall any artefacts be interfered with, removed or destroyed. If the newly discovered heritage resource is considered significant a Phase 2 assessment may be required. A permit from the responsible heritage authority will be needed. Any mitigation or management measures recommended by the specialist, after assessment of the find, must be implemented. Monitoring Monitor graves near the Witpoortje Vent Shaft biannually for signs disturbance and maintenance of the surrounding fence. ECO

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Table 17: Biodiversity management measures Aspect Management measure Responsible party Pre-construction Phase Avoid habitat identified as Eragrostis chloromelas grassland in the terrestrial ecology specialist study as far as feasible. Project Manager Project design / No construction, machinery, stockpiling or activities may occur within wetlands or the 100m GN704 Zone of Regulation. Demarcate wetlands and 100m planning Project manager / ECO GN704 Zone of Regulation as no-go areas. Appoint a botanist to survey the area for floral individuals of SCC (namely African potato (Hypoxis hemerocallidea) and Pineapple flower (Eucomis autumnalis)). Botanist should obtain permits as necessary and supervise all rescue and relocation of SCC. A rescue and relocation plan should be compiled with input from a botanical specialist and should be implemented under the guidance of a botanical specialist / horticulturalist:  Rescue all individuals of target species situated in the footprint of planned infrastructure ECO / botanical and faunal Clearing and grubbing  Relocate rescued individuals to a location within the project area where no development will take place or as a last resort a registered nursery specialist (e.g. the ARC or SANBI) Appoint a faunal specialist to find and relocate individuals of SCC in the areas to be cleared (namely Southern African Hedgehog (Atelerix frontalis), African Grass Owl (Tyto capensis) and Giant bullfrog (Pyxicephalus adspersus)). Individuals are to be carefully relocated to an area of similar habitat outside of the development footprint. Ensure that appropriate permits are obtained. Construction Phase Place contractor laydown areas outside of the wetlands and the associated 100m GN704 Zone of Regulation. A designated area should be approved by Site establishment ECO the ECO prior to use. Water management Separate clean and dirty water areas at all times as per the water management plan ECO Clearing Limit vegetation clearing to areas as per the approved layout. Restrict vegetation removal to what is absolutely necessary. ECO / Construction manager Forbid all trapping, hunting or killing of any faunal species by any staff member. Report all dead animals found on site to the ECO, the ECO will identify Human-animal a suitable method of disposing of the carcass which limits zoonosis and unsanitary conditions on site. Pest management will be undertaken by a ECO / Construction manager interaction suitably qualified practitioner. Initial rehabilitation Rehabilitate all disturbed areas through revegetation using indigenous grass species at the end of construction so that no bare areas remain. ECO Construction and Operation Phases Environmental awareness training must be implemented as per the environmental awareness plan educating personnel and contractors on how to interact Awareness ECO with the environment. Prohibit the lighting of informal fires; no uncontrolled fires whatsoever are allowed. Supply workers with appropriate cooking and heating facilities so the Fires ECO / Health & Safety Officer need for open fires and harvesting of wood is reduced. Hydrocarbon Hydrocarbons must be managed according to the Hydrocarbon Management Plan to avoid contamination of the environment. ECO management Waste management Waste must be managed according to the Waste Management Plan to avoid contamination of the environment. ECO Hazardous substance Hazardous substances and hazardous waste must be managed according to the Hazardous Substances / Waste Management Plan to avoid ECO management contamination of the environment. Stormwater An ecologically-sound stormwater management plan must be implemented. Refer to the Water Management Plan. ECO management Alien invasive plant Alien vegetation must be removed from the area and monitored during all phases of the development, with specific attention paid to Category 1b species species monitoring and in line with the NEMBA Alien and Invasive Species Regulations (2016). Special attention should be paid to alien and invasive plant control within areas ECO / Botanist management compacted as a result of construction activities. Edge effects Edge effects need to be actively managed from construction to post-closure (erosion control and alien floral species management). ECO Transport Restrict vehicle movements to designated roadways – no off-road driving is allowed. ECO / Health & Safety Officer Decommissioning Phase Environmental awareness training must be implemented as per the environmental awareness plan educating contractors on how to interact with the Awareness ECO environment.

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Aspect Management measure Responsible party Decommissioning Keep decommissioning related activities strictly within the SDA footprint ECO Alien invasive plant Alien invasive vegetation eradication and monitoring must be conducted as detailed in Biodiversity Monitoring Programme. ECO / Botanist species management Rehabilitation Rehabilitation must be carried out according to the Closure Plan. ECO Rehabilitation The recovery of vegetation must be monitored as per the Biodiversity Monitoring Programme. ECO monitoring Post-Closure Phase Rehabilitation Alien invasive vegetation eradication and monitoring must continue post-closure as per the Biodiversity Monitoring Programme. ECO / Botanist monitoring The recovery of vegetation must be monitored as per the Biodiversity Monitoring Programme for at least five years. ECO / Botanist

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Table 18: Blasting and subsidence management measures Aspect Management measure Responsible party Construction Authorisations Apply for all relevant authorisations prior to blasting. ECO / Health & Safety Officer Cover the first three to four blasts to limit air blast thereafter the nuisance from the air blast will be limited. ECO / Health & Safety Officer A risk assessment should be conducted to determine final exclusion zone before each blast. ECO / Health & Safety Officer Evacuate people and livestock to ensure they are safe distances from the blasting area. ECO / Health & Safety Officer Consider closing and monitoring the M43 road and a gravel road are in the vicinity of the project area. ECO / Health & Safety Officer Blasting Do not blast very early in the morning, too late in the afternoon in winter, or other times when there is a possibility of atmospheric inversion. Do not blast in fog. Do not blast in the dark. Refrain from blasting when wind is blowing strongly in the direction of an outside receptor. Do not blast with ECO / Health & Safety Officer low overcast clouds. These ‘do nots’ stem from the influence that weather has on air blast. The energy of air blast cannot be increased but it is distributed differently and therefore is difficult to mitigate. Fix a standard blasting times and set up blasting notice boards at various routes around the project area that will inform the community of blasting dates ECO / Health & Safety Officer and times. Construction and Operation Based on the findings of the subsidence assessment a suitable subsidence management plan and monitoring programme must be drawn up. Pre-mining conditions of surrounding structure must be determined by land survey and photographic records via structural integrity assessment as Subsidence advised by a structural engineer. ECO / Health & Safety Officer Design extraction systems and excavation sequences to minimize adverse surface effects. Minimise and monitor effects of mining-induced seismicity and vibrations on the surface and surface structures.

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Table 19: Noise management measures Aspect Management measure Responsible party Planning phase Incorporate the noise management requirements into the Induction and training programme. All contractors must be made aware of the management Awareness training ECO requirements, individual roles may require additional training to ensure these mitigation measures are adhered to. Introduce a grievance mechanism whereby noise complaints can be received and responded to. Any complaints must be recorded and the ECO must respond to complaints appropriately in a timeous manner throughout the LoM. Community engagement ECO / Construction manager Establish a community relations committee with members of the affected communities to act as a formal vehicle of communication of issues, concerns and information. If necessary, further monitoring must be conducted and corrective measures investigated and implemented. Project programme Plan construction to ensure that activities, especially surface blasts and waste rock management, only occur during daylight hours. ECO / Construction manager Purchase and install equipment able to achieve a preferable noise output of below 85 – 90 dBA. If equipment is not able to reach these noise standards, Purchasing Procurement Department / ECO noise barriers will be required as part of the project design. Baseline monitoring Undertake baseline noise monitoring at all the proposed monitoring sites prior to construction and throughout operation. ECO / Noise Specialist Construction Phase Project programme Limit construction activities, including deliveries, rock management, drilling and blasting to daylight hours. ECO Design transport routes to be circular to limit reversing. ECO / Project designer Transport Limit vehicle traveling speeds to 30 km/h ECO Noise barriers Where possible, earthworks and material stockpiles should be placed so as to protect the sensitive receptors from noise. ECO Blast procedure to be implemented and to include notification of nearby sensitive receptors. ECO / blasting contractor Develop blast designs and procedures to keep noise and blasting to a minimum without compromising blast requirements ECO / Blasting contractor Consider appropriate blast designs to limit noise including: Blasting  The drilling grid, charge size, charging plan, blasting ratio, charge stemming and delay interval ECO / Blasting contractor  Delayed / micro-delayed or electronic detonators No blasting to occur on Weekends or Public Holidays ECO Blasting will be undertaken following a planned schedule and the local community will be informed of this in advance ECO / Blasting contractor Construction, Operation and Decommissioning Phases Limit idling and switch off equipment when not in use or stationery for long periods. Enclose engine compartments of vehicles. Fit efficient silencers and enclose engine compartments. Damp mechanical vibrations. ECO / Construction / Site Vehicles and equipment Implement systematic maintenance of all forms of equipment and vehicles, including drill rigs. manager Train vehicle drivers / machine operators not to over-rev engines and to avoid unnecessary reversing. Proper design and maintenance of silencers on diesel-powered equipment, systematic maintenance of all forms of equipment, training of personnel to adhere to operational procedures that reduce the occurrence and magnitude of individual noisy events. Reduce noise at source by acoustic treatment, etc. Isolate bin and chute by an acoustic enclosure, etc. Compressors and generators should be installed ECO / Construction / Site Fixed noise sources in separate acoustically treated buildings. manager Standardised noise measurements should be carried out on individual equipment at delivery to construct a reference database. Regular checks should ECO / Construction / Site Inspections be carried out to ensure that equipment is not deteriorating and to detect increases which could lead to complaints. manager Monitoring Monitor noise impacts as per the Noise Monitoring Programme. ECO / Noise Specialist Should monitoring indicate that monitoring objectives are not being met corrective actions must be implemented within a month of the monitoring report Corrective actions ECO being issued to ensure that monitoring objectives are met. General health and Mine Health and Safety and Occupational Health and Safety Regulations relevant to noise management must be adhered to within site boundaries and ECO / Health and safety officer safety compliance thereto audited regularly. (HSO)

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Table 20: Socio-Economic management measures Aspect Management measure Responsible party Prior to Construction Phase Landowner agreement An agreement must be drawn up between ERPM Ext 1 and the affected landowners for the use of the land. Mine Management A stakeholder engagement plan (including a grievance mechanism) must be compiled, to provide a defined process for two-way communication between the community (and the communication of the recruitment process) with stakeholders in the area and the Mine. The grievance mechanism Stakeholder ECO and / or SLP or must prescribe methods for community members to raise complaints (anonymously if they so choose). Complaints must be responded to and engagement plan Community Engagement Officer addressed effectively. Response methods and timeframes must be specified in the grievance mechanism. IAPs must be notified of the stakeholder engagement plan and grievance mechanism. Local engagement structures must be put in place to disseminate accurate information about the project to reduce unrealistic expectations regarding Local engagement ECO and / or SLP or jobs and community benefits, discuss potential impacts and issues relating to the mine including local procurement and recruitment, crime, any structures Community Engagement Officer complaints received as well as potential health concerns. Minutes of meetings should be taken and kept for the LoM. A local procurement policy document that addresses the procurement requirements and procedures must be compiled. The available local suppliers as Local procurement Procurement Department well as their capacity must be evaluated and local suppliers must be preferred where there is local capacity to provide services. A clearly defined recruitment process and registration process for local recruitment must be implemented. The registration process should involve the compilation of a database of people from local communities interested in employment to inform a skills database and identify skills gaps through a skills Recruitment audit. Local recruitment must be preferred where the necessary skills are available locally. HR Officer Recruitment (by the mine and any contractors) must not be conducted at the mine gate so as to dissuade job seekers gathering at the mine gate. All recruitment is to take place through a centralised recruitment office. In-migration ECO and / or SLP or ERPM Ext 1 must compile an in-migration management plan based on discussions through local engagement structures. management plan Community Engagement Officer Construction, Operation and Decommissioning Phases The start of the recruitment process should be advertised in a local newspaper and broadcast on local radio. The advertisements should clarify where all recruitment will take place, how recruitment will take place, the names of contractors involved, and clarification of any third parties that will be involved in Recruitment the process (so as to avoid any opportunistic parties taking advantage of employment seekers). HR Officer Recruitment (by the mine and any contractors) must not be conducted at the mine gate so as to dissuade job seekers gathering at the mine gate. All recruitment is to take place through a centralised recruitment office following the recruitment process. Contractors Contractors must be encouraged to provide transport for their employees, and to discourage settlement within the area. ECO All personnel (including contractors) involved in the construction and operation of the project must undergo a training and awareness programme on Employee awareness ECO health, safety, environmental and social requirements and obligations prior to commencing activities. Training opportunities should be prioritized for people living in the area that will be impacted by the proposed development. Training and employment opportunities should be prioritized for the youth (18-34 years). Implement the Skills Development Plan (SDP) and measures regarding the management of downscaling and retrenchment as detailed in the SLP: Employment and skill  Establishment of Future Forums; HR Officer development  Provide information and counselling for retrenched employees to promote their absorption into the labour market; and  Offer a post retrenchment programme designed to equip retrenchees with knowledge and skills. The impact of retrenchment and downscaling can be mitigated by implementing the measures in the SLP relating to employee education and upskilling. Employee transport and Employees must be transported into and out of the secured mine area by bus or taxi throughout the LoM. HR Officer housing Encourage employees that are not resident in the area to rent accommodation locally. Comply with the Mine Health and Safety Act, No. 29 of 1996 and Regulations as well as the Mines and Works Act, No. 78 of 1973 and Regulations Labour relations Maintain good relationships as well as transparent and two-way communications with employees and workers’ organisations to ensure that strike action HR Officer is avoided where possible. An HR Officer must be based at the site to continuously engage with the employees. Implement the Procurement Progression Plan detailed in the SLP. Procurement Identify suitable HDSAs and locally based companies and SMMEs that currently, or in future, could provide local procurement to the mine as required Procurement Department for the mining operations. The mine should advertise the commencement of the procurement process and invite locally based companies to register

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Aspect Management measure Responsible party their interest. The mine should maintain a database of local companies and prioritise these where possible. Neighbouring mines and Helderwyk Integrated SLP or Community Neighbouring mines and the Helderwyk Integrated Mega Human Settlement need to be made aware of the underground mine plan. Mega Human Engagement Officer Settlement Maintain good relationships as well as transparent and two-way communications with IAPs through local engagement structures to ensure that protest SLP or Community Community engagement action is avoided where possible. Engagement Officer ECO and / or SLP or Complaints Complaints must be addressed adequately through the grievance mechanism and corrective measures implemented where warranted. Community Engagement Officer Insurance premium Blasting monitoring reports must be made available to any stakeholders who request this information. This will allow stakeholder to use this information ECO increases to negotiate with their insurance companies if necessary. A Security Policy must be compiled. Key aspects of this policy include:  Security personnel must be thoroughly vetted, to ensure that none of the individuals hired have been involved in past human rights abuses;  Roles of security personnel must be limited to protecting the work force and safeguarding physical assets; Security ECO  Security personnel must be encouraged to have as little interaction with the community as possible; and  Security personnel need to be properly trained in the use of armed force and violence, as well as conduct towards community members. Mine security patrols must monitor the perimeters of the shaft areas thereby providing an increased security presence. Encourage Municipality involvement in the engagement structures so that any issues raised regarding service delivery can be brought to the attention ECO and / or SLP or Service delivery of the Municipality. Community Engagement Officer No squatting must be permitted on the mine lease area or along the access routes to the mine. The mine must monitor the establishment of new Informal settlements ECO settlements, and employ additional security personnel to police this. Develop and implement a Community Health and Safety Policy. Community health and safety developed and implemented must be implemented to raise awareness associated with all project activities including a ECO road safety awareness campaign; identification of health concerns and associated behaviour, including HIV/AIDS awareness; and identification of dangerous / hazardous site activities, including transport routes and the shafts. Community health and Unfenced areas must have signs warning people of the danger of entering the mining area. ECO safety The entire length of the tailings pipeline must be inspected and maintained regularly. An Emergency Preparedness and Response Plan (EPRP) must ECO be developed and include the potential for tailings spills. The EPRP must communicated to stakeholders, particularly those along the pipeline route. Encourage Municipality involvement in the engagement structures so that any health concerns relating to in-migration can be brought to the attention of ECO and / or SLP or the Municipality. Community Engagement Officer Air quality impacts Measures as per the Air Quality Management Plan must be implemented. ECO Noise pollution Measures as per the Noise Management Plan must be implemented. ECO Measures in the Blast / Vibration Management Plan and Monitoring programme must be implemented ECO An agreement should be reached with the landowner / tenant of the two farmhouses located near Windmill Shaft SDA regarding the potential impact ECO Blasting associated with air blast during the initial stages of construction Ensure that all stakeholders within 1 000 m of any blasting are informed of the proposed blasting design and schedule, at least 2 days prior to blasting ECO Visual intrusion Measures as per the Visual Management Plan must be implemented. ECO Groundwater users Measures as per the Water Management Plan must be implemented. ECO Traffic related impacts Measures as per the Traffic Management Plan must be implemented. ECO Implement the Socio-economic Monitoring Programme to monitor the progress and effectiveness of proposed socio-economic mitigation measures and Monitoring ECO ensure stakeholder input is considered as part of the ongoing implementation process.

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Table 21: Soil management measures Aspect Management measure Responsible party Construction and Operational Phase Design and plan the project in order to keep infrastructure development area as small as practically possible. The design must make provision for stormwater management through all phases of the project Include topsoil stockpiles in the project layout, situate stockpiles in an area that will not be developed or disturbed throughout the project Project manager Planning Ensure that all contractors and subcontractors are aware of the provisions of the EMPr and that stockpiled topsoil is not to be used as construction material. Review and implement the Soil Monitoring Programme ECO Clearly demarcate the infrastructure footprint, limit clearing and grubbing to those areas only ECO / Construction manager Retain vegetation and soil in position for as long as possible, and may only be removed immediately ahead of construction / earthworks in that area ECO / Construction manager Strip and stockpile soil in horizons / layers:  Strip and stockpile vegetation along with topsoil. Typically, this would be the top 50 - 100 mm layer.  Remove the rest of the “A” horizon, the portion of the surface soil that contains the organic matter, typically, this would be 400 - 600 mm thick. ECO / Construction manager Stripping  Remove the usable non-plinthic “B” horizon materials.  Store each soil horizon separately and the placement recorded on the site layout / as built drawings. Conduct stripping and stockpiling correctly, under the supervision of a suitably qualified environmental professional. ECO / Construction manager Handle soils when dry to minimise compaction. If possible, strip soil during the dry winter months to limit moisture-enabled compaction. Only ECO / Construction manager commence dust suppression activities once soil has been stockpiled. Locate soil stockpile areas so that they will not need to be moved during the LoM. ECO / Construction manager Stockpile soils according to soil type and natural horizon sequence. Locate stockpiles on a flat area where erosion and contamination will not occur. ECO / Construction manager Restrict soil storage stockpiles (where feasible) to heights of less than 4 to 5 m so as to avoid damage to the soil seed bank. ECO / Construction manager Stabilise stockpile side slopes at a maximum angle of 1:6. This will promote vegetation growth (use locally adapted perennial or annual seed mixture of ECO / Construction manager Stockpiling grasses) and reduce run-off related erosion. Revegetate stockpiles with indigenous grass cover (at least 70% basal cover; either through natural propagation if the seed bank is sufficient or ECO / Construction manager through seeding) as soon as feasible and retain vegetation cover until soil is required for rehabilitation. ECO / Construction/ Site Limit the movement of equipment, humans and animals on the soil stockpiles to avoid damage to the soils and seed bank. manager Store and handle chemicals on site according to the South African National Standards (SANS). Implement Hydrocarbon Management Plan if soil is ECO contaminated. Immediately clean up spills (hydrocarbons and/or cement) and the contaminated soil should preferably be treated in situ, for example using bioremediation (in a specifically designed facility). The acceptability of this option must be verified by an appropriate soil expert on a case by case ECO / Construction manager basis, before it is implemented. If remediation is not possible, the contaminated soil should be excavated and removed from site, handled accordingly Contamination and discarded as potentially hazardous waste. Carry out a soil contamination assessment after stockpiling and at mine closure. Soil analyses should include pH, EC and the metals, metalloids, hydrocarbons and anions as listed in terms of the “SSV from GNR 331 of 2014 National Norms and Standards for the Remediation of Contaminated ECO Land and Soil Quality” to determine if there are any exceedances relative to the SSV 2 – Commercial and Industrial guidelines. If exceedances are found then appropriate remediation measures must be implemented such that the soil quality is in line with the planned land use for the area. Put in place stormwater management measures as per the EMPr to attenuate stormwater runoff volumes and decrease velocity. ECO / Construction manager Stabilise exposed (bare) areas with vegetation and/or erosion control blankets / geotextiles. Establishing and maintaining vegetation as a soil cover is the most common practical technique for controlling erosion on disturbed soils. Erosion Water flow inhibiting vegetation or biodegradable Jute mesh erosion control blanket should be established on undeveloped (open) areas and along the ECO / Construction/ Site lower ends of the site, in order to retard overland water flow and erosion. These are suitable for short to medium term erosion protection. The effect of manager the Jute mesh can be enhanced by putting it over a loose blanket of thatching grass or reeds, if locally available. A 70 % dead grass or reed cover will slow down flow, minimise wind erosion and suppress weed growth. The open weave nature of the Jute mesh blankets helps retard water flow velocity,

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Aspect Management measure Responsible party while allowing sunlight infiltration to encourage vegetation growth. Alternatively, strips of instant turf can be planted a few meters apart (provided it is an indigenous species) during spring or late summer, with tuft runner grasses in between. Bare soil must not remain exposed for longer than two weeks without the implementation of erosion control measures being implemented. Erosion control of all banks, including the existing eroded drainage channels, must take place so as to reduce erosion and sedimentation. Eroding ECO / Construction/ Site embankments need to be sloped to a gradient of not more than 1:3 and appropriately re-vegetated. Cleared bush and brush can be used for backfill in manager the existing eroded drainage channels. ECO / Construction/ Site Monitor all areas susceptible to erosion (including roads, bare areas and drainage channels) as per the Soil Monitoring Programme. manager Some grasses produce high quantities of standing biomass and if not regularly defoliated they become moribund and die off, decreasing their potential ECO / Site manager to control soil erosion. Areas within the surface infrastructure area where vegetation has not been cleared should be mowed or slashed regularly. Decommissioning Phase ECO / Suitably qualified service Sampling Analyse a representative sample of stockpiled soils prior to rehabilitation according to the Final Rehabilitation Decommissioning and Closure Plan. provider Rehabilitate disturbed sites with stockpiled soil. The utilisable soil removed during the construction phase, must be redistributed in a manner that achieves an approximate uniform, stable thickness, consistent with the approved post development end land use. Attain a free draining surface profile. ECO / Site manager Replaced soils may require both physical and chemical amelioration. Use stockpiled subsoil (Non-plinthic “B” horizon) materials in areas where no topsoil is available for rehabilitation to establish plant growth. Non-plinthic “B” horizon materials are physically suitable for rehabilitation but contain little or no organic matter and, accordingly, will not supply planted grasses with ECO / Suitably qualified service nutrients if used as topsoil. Organic or inorganic fertilisers, as per specialist recommendation, are to be used with regular maintenance as per specialist provider Rehabilitation recommendation until natural nutrient recycling occurs. Soil fertility should be restored. The fertility remediation requirements of the topsoil need to be verified at the time of rehabilitation, and informed by the ECO / Suitably qualified service results of sampling. Input from a soil specialist should be obtained regarding fertility remediation requirements, which should be adhered to prior to re- provider vegetation. The chemical soil composition should be ameliorated to closely match the baseline values, particularly for pH and EC. Soil contaminated with hydrocarbons must be moved to an allocated area where it will be bioremediated or it must be disposed of at an appropriate Suitably qualified service landfill facility. provider Rehabilitated areas should be cordoned off to limit the movement of equipment, humans and animals on the rehabilitated areas. ECO / Site manager Re-vegetation Re-vegetation must be carried out according to the Closure Plan. ECO/ Botanist Post- Closure Phase Monitor the recovery of vegetation biannually for a period of two growing seasons following rehabilitation according to the Terrestrial Ecology (Flora) Monitoring Programme. Monitoring and All areas susceptible to erosion must be monitored according to the Soil Monitoring Programme. ECO / Botanist/ Site manager maintenance A minimum of 70 % aerial cover will be established through vegetation for at least one growing season before rehabilitation can be considered complete.

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Table 22: Traffic management measures Aspect Management measure Responsible party Construction, Operation and Decommissioning Phases Clearly mark access routes and drivers must only travel on designated routes. Install signage and flagmen, where necessary to ensure traffic safety at Access ECO all times. Increase the road network capacity by:  Providing public transport such a bus service to and from the mine site for staff from surrounding communities to limit the number of vehicles on the road Employee transport ECO  Improving the lane capacity to impacted intersections to reduce delays and overall journey time  Signalisation of access intersection (Barry Marais Rd./Road A I/S) to reduce delays and improve safety by reducing the number of conflict points Truck loading Monitor truck loading to ensure trucks are not overloaded and that wheel/axle loading should be in accordance to legislation ECO Speed limit Limit speed of construction vehicles and haul trucks travelling on unpaved roads to 40 km/h. ECO Fleet Vehicles and equipment should comprise of new technology engines to ensure low combustion emissions. ECO Use low-sulphur diesel to fuel vehicles and equipment. Fuel ECO Reduce vehicle idling to a minimum. Vehicle maintenance Implement an inspection and maintenance programme to service vehicles and equipment in accordance with the manufacturer specifications. ECO Train and instruct drivers on driving practices that reduce both the risk of accidents and fuel consumption, including measured acceleration and driving Training within the speed limits. ECO Implement awareness training as per the environmental awareness plan educating contractors and employees of the importance of road safety. ECO / Suitably qualified service An application must be submitted to the Department for a way leave if any part of a proposed service falls within 95 m measured from the centreline of Way leaves provider/ Gauteng Roads and any existing or future road(s)/railway line or within a 500 m radius of any intersection on said road(s)/ railway line. Transport Stabilise gravel roads to decrease dust generation. The road from Barry Marais Road to the Windmill Shaft SDA should be tarred ECO Road surfaces Inspect road conditions to ensure that the road does not deteriorate or become unusable. A representative from the Municipality should be encouraged ECO to participate in the engagement structures so that any issues related to road structure can be brought to the attention of the Municipality. Accidents Record and monitor all traffic accidents and traffic related incidents at the mine, along the access roads and along the transport routes. ECO Designated pick-up and Identify suitable points at established bus / taxi stops or junctions for picking up a dropping off staff. Avoid ad-hoc bus stops. ECO drop-off areas

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Table 23: Visual management measures Aspect Management measure Responsible party Construction Phase Limit the extent of the areas to be disturbed, only that which is essential as per the approved layout ECO / Construction manager Site disturbance Avoid the unnecessary removal of vegetation, especially the existing trees along the where these partially or totally screen infrastructure. ECO / Construction manager Signage related to the proposed development must be discrete. Keep vertical dimensions of tall infrastructure to the minimum heights possible. ECO / Construction manager Visual intrusion Avoid the use of highly reflective materials in construction. Paint colours are to be carefully selected based on the surrounding landscape and are to be in the dark grey, brown or green range, to minimise visibility and avoid reflectivity. Plant indigenous fast-growing trees along the mine boundary between sensitive receptors and shaft areas. ECO Construction, Operation and Decommissioning Phases Dust Implement dust suppression measures as per the Air Quality Management Plan. ECO / HSO Avoid unnecessary illumination. However, safety/security and operational requirements may limit the extent to which this can be implemented. Provide lights with cover fittings that limit lateral and upwards “light spill”, and position lights to shine towards the intended areas of illumination rather than using floodlights. Use downward lighting to prevent nuisance to grass owls. Lighting at night ECO / HSO Limit the heights at which lights are positioned. Make use of Low Pressure Sodium lighting, LED or other types of low impact lighting. Low wattage bulbs can be used to further reduce the impact. Motion sensor activated lighting may be used instead of lights that illuminate continuously. Housekeeping Keep the site in a neat and tidy condition at all times, no litter should be observed on or near the site. ECO Decommissioning Phase Infrastructure removal Completely remove all structures and waste. ECO Rehabilitation Rehabilitate all disturbed areas to reduce visual impacts as per the recommendations in the Closure Plan. ECO

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Table 24: Water management measures Aspect Management measure Responsible party Prior to Construction Phase Ground water inflow Initiate studies to better understand the expected groundwater inflow quantity and quality at depths greater than 1000 mbgl, use this data for the design ECO / hydrogeologist management of water management infrastructure and the location of monitoring points. Develop a feasible, long-term groundwater treatment plan. Ensure that a WUL has been awarded prior to the commencement of any water uses. Ensure that all conditions are strictly adhered to throughout the Authorisation project. ECO No development of activities should take place within 500 m of watercourses prior to being authorised. Stockpiling / waste Perform geochemical assessment of the material that will be stored on the any Waste Rock Dump and topsoil stockpile and to determine the waste ECO / Geochemist / Design management classification and associated lining requirements according to Regulation 635 and 636 of the Waste Act. engineer Implement all measures required by WMLs and WULs. ECO Install groundwater monitoring boreholes as per groundwater monitoring programme and initiate monitoring as soon as feasible. Collect at least one year ECO / Hydrogeologist Monitoring of baseline water quality data prior to construction. Identify surface water monitoring points upstream and downstream of the project. Collect at least one year of baseline data prior to construction. ECO / Aquatic specialist Implement aquatic biomonitoring. Collect at least one year of baseline data prior to construction. ECO / Hydrologist Construction Phase All watercourses are to be considered 'no-go' areas to all personnel Clearly demarcate (on the ground) the construction footprint area and strictly limit all construction activities to within this area. Contractor laydown areas, Access control ECO / Construction Manager resources. Vehicle re-fuelling areas and material storage facilities to remain outside of the delineated freshwater environment. All vehicles must remain on the designated roads and no indiscriminate movement of vehicles within the aquatic environment should be permitted. Suitable flow diversion structures, such as diversion berms and/or collection canals, must be established around the border of the proposed operational ECO / Construction Manager Stormwater runoff areas diverted to flow diffusing infrastructure to release stormwater runoff into the environment preventing erosion. management Construct a pollution control dam to control runoff from the site and waste rock facilities as well as holding groundwater until the shaft collar is in place (if ECO / Construction Manager discharge is required). Handling of construction Prepare concrete on an impermeable surface and clean cement spills immediately. ECO / Construction Manager materials No uncontrolled discharges to any surface water resources must be permitted. Any discharge points need to be approved by DWS. Discharges ECO / Construction Manager Install a water treatment plant to accommodate the expected water inflow if discharge is required. Stockpiling / waste Characterise waste rock extracted from the shafts and handle it accordingly ECO management Install liners as per Regulation 636 of the Waste Act for all stockpile areas. ECO Construction and Operation Phases Best practise Ensure that all Best Management Guidelines as published by the DWS (2005) are adhered to. ECO All clean and dirty water areas need to be clearly separated in line with the requirements of regulation GN704 of the NWA. Dirty water management Contained dirty water must be recycled and utilised within the mine water circuit where possible. ECO The designated dirty water area should be rehabilitated and minimised so as to minimise the potential loss of catchment surface runoff yield. Stormwater runoff Stormwater runoff must be managed appropriately to ensure that the area is not flooded during heavy rainfall events. ECO management Monitor groundwater inflow quality and quantity and handle it according to approved WU ECO Groundwater inflow Seal off individual high yielding inflow zones when intercepted to maintain mine water balance Develop a numerical groundwater model within five years of operation and update the model every 5 years. ECO Allocate dedicated underground areas where oil and diesel are refuelled, with contamination prevention measures such impermeable surfaces, oil sumps, Groundwater pollution bund walls to prevent free flow of spilled product on the mine floor. Clean any spilt product immediately. ECO Implement additional pollution prevention management measures on surface where and when a direct surface infiltration source mechanism is detected. Groundwater levels in designated monitoring boreholes must be monitored monthly. ECO

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Aspect Management measure Responsible party Groundwater level Corrective actions (such as compensation or provision of make-up volumes) must be taken if monitoring shows that groundwater levels have been reduction impacted and are affecting the livelihood of surrounding groundwater users. Monitoring must be conducted as per the relevant monitoring programmes. Monitoring ECO Revisit the surveyed privately-owned boreholes on an annual basis. WUL Ensure that the conditions of any awarded WUL are strictly adhered to. ECO Rehabilitation Refer to the Closure Plan, detailing the rehabilitation management measures. ECO Stockpiling / waste Appropriately remove and rehabilitate water management dams and surface stockpiles during decommissioning where possible. Slope, cap and vegetate ECO management of the WRD. Undertake a detailed regional assessment of the different interconnected mines and the geological information available from each of the mines in order Groundwater decant ECO to identify decant positions and volumes to an acceptable level of confidence and implement recommendations made in the study Monitor groundwater and surface water for a least 5 years after mine closure for contaminant migration. ECO Groundwater ECO / Hydrogeologist / remediation Develop and implement a long-term water treatment plan based on the monitoring results. Geochemist

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Table 25: Hydrocarbon management measures Aspect Management measure Responsible party Construction, Operation and Decommissioning Phases All generators will be placed on drip trays to catch spills and leaks, while all maintenance work on equipment, vehicles, machinery, etc. will be done over a plastic tarpaulin or steel drip trays situated within dirty water catchment areas. Any pumps, machinery or other equipment that require oil, diesel, etc., that are to remain in one position for longer than two days will be placed on drip Drip trays and storage trays which are to be emptied regularly. Any effluent from the drip trays and any spilled oils and fuels will be collected and stored in 210 litre drums ECO / Site manager before being collected and disposed of by a licensed waste removal company. The servicing of vehicles and equipment will only be permitted at designated areas which have impermeable surfaces. Store fuel, oils and other lubricants in a bunded storeroom with a capacity to contain 110 % of the total volume thereof. Ensure that all mechanical equipment and vehicles used are kept in good working order to prevent any leakage of oil, petrol, diesel, hydraulic and other associated fluids. Vehicle and equipment Vehicles must be parked in a designated area and drip trays or tarpaulin must be used to prevent any hydrocarbon spills where necessary. ECO / Site manager maintenance In the event of a breakdown, maintenance of vehicles must take place with care and the collection of spillage should be practiced to prevent the ingress of hydrocarbons into the topsoil. Disposal The Mine must keep copies of all safe disposal certificates on-site. ECO The fuel storage facility and associated bund walls will be maintained according to the SANS for the “storage and distribution of petroleum products in ECO above ground bulk installations” (SANS 10089-1). Fuel and lubricants The contractor(s) supplying fuel and lubricants to the Mine are required to have an emergency management system in place in order to deal with possible vehicle accidents or accidental spillage. This would typically involve emergency teams that would have the capacity to neutralise spills and ECO / emergency personnel begin rehabilitation of the affected area within hours. Keep spill kits or sorp materials on hand to clean up hazardous hydrocarbon spills. Once used, this material will be treated as hazardous waste and ECO disposed of accordingly at a licensed hazardous waste disposal facility. Spills A 210 litre drum for the collection of spilled oils and fuels, together with a drip tray to catch spills and leaks before they can contaminate soil must be ECO available on-site at all times. Implement a spill response plan and train personnel to react efficiently to address any spillage. ECO Decommissioning Phase Spills Fuel storage facilities must be removed immediately upon completion of decommissioning phase. ECO Remediation and Soil contaminated with hydrocarbons must be moved to an allocated area where it will be rehabilitated and soil that cannot be rehabilitated must be ECO rehabilitation disposed of at an appropriate disposal facility.

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Table 26: General waste management measures Aspect Management measure Responsible party Construction, Operation and Decommissioning Phases Awareness Include effective waste management into environmental awareness training given to all personnel and contractors during induction. ECO The mine will ensure that an adequate number of waste drums / bins / skips are available on site, upon a suitably hardened surface. Waste must be Waste drums / bins / stored in a manner that it cannot be washed or blown into the environment. ECO / Site manager skips Waste drums / bins / skips will be collected regularly and disposed of by the appointed contractor at the nearest disposal facility which is suitably licensed in terms of legislative requirements. Domestic waste includes, but is not limited to plastics, cans, food remains and glass. Burning and burying No waste is permitted to be buried or burned on site. ECO Litter The site must be cleaned daily and litter removed and stored in the bins provided. ECO / Site manager Washing The washing of clothing, lunch dishes or vehicles is prohibited on site, except within specifically demarcated areas. ECO Waste streams must be recycled or re-used (where possible) before disposal is considered. Recyclable material must be collected by a licensed Recycling ECO recycling contractor. The volumes being temporarily stored must be monitored on a continuous basis and the relevant contractor contacted to clear the temporary facilities Storage on a regular basis or on an ad-hoc basis if it is evident that the facilities are reaching capacity. Storage must be carried out as per the norms and ECO / Site manager standards should storage thresholds (100 m3 of general waste) be exceeded. Disposal of waste on site must be prohibited. Waste must be collected and disposed of at a licensed disposal facility on a monthly basis, unless Disposal ECO volumes stored require that more frequent removal take place. In order to avoid waste blowing away or falling while stored or transported, the following must be implemented:  Ensure that the waste is loaded securely for transport when it leaves the site; Waste transport ECO  Waste transported off site must be covered; and  Skips must be constructed of steel and possess a sealable drain outlet.

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Table 27: Hazardous substances / hazardous waste management measures Aspect Management measure Responsible party Construction, Operation and Decommissioning Phases The mine will comply with the Hazardous Substances Act, No. 15 of 1973 and Regulations and apply for the necessary permits from the Department of Legal and permitting ECO Health if required. Data The mine will keep Material Safety Data Sheets (MSDS) on site for all hazardous substances kept on site and comply with the requirements of all MSDS. ECO Include effective and relevant information regarding the handling and storage of hazardous substances / waste into environmental awareness training Awareness ECO provided to personnel and contractors during induction. Pipes are to be inspected regularly for defects and weaknesses especially at pipeline turns. Ore pumping and Pipe bursts must be addressed immediately. The portion of the failed pipe must be isolated to limit the spill and repaired immediately. ECO pipelines Any spillage of must cleaned immediately by trained competent people and any contaminated soil disposed of appropriately. Explosives must be handled at the designated explosives handling facility under the conditions stated in the MSDS. ECO Explosives Old explosives and the explosives packaging will be dealt with as legally required by industry practice, in an explosive destruction facility (this should ECO / Site manager form a condition of contract for any blasting contractors utilised). A walled concrete platform, dedicated store with adequate flooring or bermed area must be used to accommodate hazardous substances as appropriate ECO according to their specific MSDS, in well-ventilated areas. Hazardous substances Storage areas for of potentially hazardous materials must be outside of the 100-year flood line of surrounding watercourses. ECO Storage and handling Cement must be stored- and cement batching must be undertaken on an impermeable surface. ECO / Construction manager No mixed concrete may be deposited outside of the designated construction footprint. A batter / dagga board mixing trays and impermeable sumps ECO should be provided, onto which any mixed concrete can be deposited whilst awaiting placing. If any spills occur, they should be immediately cleaned up. This includes spills underground. ECO Spills Any large spills of hazardous substances will initially be controlled by on-site emergency response personnel, who will be aided by professional contractors ECO / Emergency personnel depending on the nature of the material spilled. Hydrocarbon spills must be managed as per the Hydrocarbon Management Plan. Cementitious waste Concrete spilled outside of the demarcated area must be promptly removed and taken to a suitably licensed waste disposal site. ECO Mineral waste and Characterise all waste rock and design all stockpiles to control contaminated runoff. Direct all runoff to a Pollution Control Dam ECO residues Contaminated water Surface water draining off potentially contaminated areas must be contained and directed to the Pollution Control Dam. ECO / Site manager Portable septic toilets are to be provided and maintained for construction crews until permanent facilities are available, whereby at least one portable Sewage toilet must be provided per ten personnel and maintained in a manner which prevents spills. Sewage infrastructure must be inspected and maintained to ECO / Site manager ensure no leaks. Under no circumstances may ablutions occur outside of the provided facilities and open defecation is forbidden. The bund walls for all storage facilities containing any industrial or related hazardous substances / wastes will have sufficient storage capacity of 110 % ECO / Site manager from the combined storage capacity. Waste storage capacity The volumes being temporarily stored must be monitored on a continuous basis and the relevant contractor contacted to clear the temporary facilities on a regular basis or on an ad-hoc basis if it is evident that the facilities are reaching capacity. Storage must be carried out as per the norms and standards ECO should storage thresholds (80 m3 of hazardous waste) be exceeded. In order to avoid waste or hazardous substances being exposed while stored or transported, the following must be implemented: Waste transport  Ensure that the waste is loaded securely for transport when it leaves the site; and ECO  Skips must be constructed from steel and possess a sealable drain outlet. Any hazardous waste generated on-site for disposal will be collected by a licensed hazardous waste contractor for disposal at a licensed disposal facility. Disposal ECO All waste materials cleared from the shaft should be immediately removed from site. The mine will request a safe disposal certificate for all hazardous waste streams removed by external contractors that will be kept on-file for the life of Certificates ECO the mine.

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i. Financial Provision

Determination of the amount of Financial Provision

Section 24(P)(1) of NEMA states that an Applicant for an EA relating to mining or related activities on a mining area must make the prescribed financial provision for the rehabilitation, management and closure of environmental impacts, before the Minister responsible for mineral resources issues the EA.

In order to ensure that the Applicant provides sufficient funds for the total quantum to cover the rehabilitation, management and remediation of negative residual environmental impacts, the quantum for closure-related financial provision in terms of Regulation 4 of the current NEMA Financial Provisioning Regulations (GN1147 of 2015 as amended) and Regulation 6 of the proposed NEMA Financial Provisioning Regulations (GN667 of 2019) has been determined. Refer to 5(a)(v) below.

a. Describe the closure objectives and the extent to which they have been aligned to the baseline environment described under Regulation 22 (2) (d) as described herein

Closure objectives Extent to which aligned to baseline environment  The topography will be reshaped to ensure that the area is fee draining to Developing a landform that is free draining, represent the baseline state with established, self-sustaining vegetation  Vegetation rehabilitation will be conducted and monitoring conducted to ensure that vegetation is self-sustaining  Shafts will be sealed Developing a landscape that is aesthetically  Landform will be stabilised acceptable in relation to the existing landscape  All infrastructure will be removed  All waste will be removed Ensuring that the land is acceptable for the end  Disturbed areas will be rehabilitated to suit industrial, large commercial land use in line with planning objectives and as development or wilderness per the specialist recommendations  Shafts will be sealed  Landform will be stabilised Ensuring community safety  All infrastructure will be removed  All waste will be removed

The Closure Plan has been prepared which further details the closure objectives, strategy, measures and relinquishment criteria; refer to Appendix 21.

b. Confirm specifically that the environmental objectives in relation to closure have been consulted with the landowner and interested and affected parties

The main objective will be to return the area to an acceptable end land use in line with planning objectives and specialist recommendations. The shafts will be sealed and the WRD at Windmill Shaft is to remain in situ at closure. Infrastructure determined to be required for residual pollution control will also remain post-closure. Although the shafts will be sealed during the closure phase, the land use at the Windmill Shaft (specifically around the sealed shafts and WRD) will not be appropriate for urban development due to potential safety concerns. The proposed final end land use for the disturbed areas is industrial and / or large commercial development or low intensity grazing and/or wilderness land

The above environmental objectives with regards to closure and rehabilitation have been incorporated into documentation made available, and presentations given, to the landowner and IAPs during the Scoping Phase of the project. The EIA and EMPr, and the Closure Plan are available during this EIA phase, for comment during the period (9 September – 10 October 2019).

The following issues relating to closure and rehabilitation have been raised during the PPP. These issues have been addressed in the Closure Plan (Appendix 21).

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Issues raised Response Since the NEMA Financial Provisioning Regulations came into effect the Applicant is required to put Are there are sufficient aside funds for rehabilitation before mining begins. securities, guarantees and controls in place to ensure that The required financial provision must be provided for/set aside, either through a financial guarantee or when the mine is closed there by payment into the DMR account and proof of availability for financial provisioning must be provided are sufficient funds available for on the effective date of a Mining Right and is therefore in place prior to the commencement of the rehabilitation mining.

From previous experience with Every financial year the holder must review and re-assess the closure plans and reports. The results of ERGO, the funds set aside for reviews, confirmations or adjustments of the adequacy of financial provision must be audited by an rehabilitation had not been independent auditor who must draft an audit report to be submitted to the Minister of the DMR, and available when the time came must be made available on a website, at a site office and on request. The holder must also publish the for the money to be used and outcome of the Ministers decision in a newspaper circulating in the area. asked how the community can be certain that this will not Financial Provision has been provided as a regulatory cost (under the environmental cost category) in happen again the Mining Work Programme for the proposed ERPM Ext 2 Mine. The reopening and equipping of the shafts will increase security presence in the area around the SDA Concern for safety in terms of and could have a positive impact on safety and security during operations. illegal miners, and that once a The closure plan addresses the aspects related to closure. At closure, the shafts must be sealed with mine closes, people try to approved seals designed by a professional engineer and in accordance with specifications provided by access the mines illegally. the DMR and rendered safe.

c. Provide a rehabilitation plan that describes and shows the scale and aerial extent of the main mining activities, including the anticipated mining area at the time of closure

The Closure Plan (Appendix 21) includes a rehabilitation plan for the proposed ERPM Ext 2 Mine.

d. Explain why it can be confirmed that the rehabilitation plan is compatible with the closure objectives

The rehabilitation measures in the Closure Plan (Appendix 21) were compiled to meet the specific closure objectives as described in Section 5(a)(ii) above.

e. Calculate and state the quantum of the financial provision required to manage and rehabilitate the environment in accordance with the applicable guideline

As per GN667 of 2019, the determination of the financial provision for new operations must include the costs associated with rehabilitation and management of impacts arising from:

Therefore, in order to calculate the costs to be set aside by ERPM Ext 1 for rehabilitation, decommissioning and mine closure of ERPM Ext 2, which is a new operation, the following formula was used (refer to Table 10):

Total 1 + Total 2 = sum (1 + CPI plus 2%) x VAT

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expected to manifest in the future based on an unscheduled closure on the anticipated disturbed area for the first year of operation.

The Guideline for Evaluation of the Quantum for Closure-Related Financial Provision compiled by the then Department of Minerals and Energy (DME) (now DMR) was used to inform the itemised breakdown. The guideline rates were however adjusted using market related contractor rates to provide actual costs for decommissioning and rehabilitation.

f. Confirm that the Financial Provision will be provided as determined The required financial provision will be provided for/set aside, through a financial guarantee.

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MECHANISMS FOR MONITORING COMPLIANCE WITH AND PERFORMANCE ASSESSMENT AGAINST THE ENVIRONMENTAL MANAGEMENT PROGRAMME AND REPORTING THEREON including: g. Monitoring of Impact Management Actions h. Monitoring and reporting frequency i. Responsible persons j. Time period for implementing impact management actions k. Mechanism for monitoring compliance Monitoring programmes have been developed for the management of various environmental components. These programmes define the scope, objective, time frames, roles and responsibilities as well as the reporting or recording requirements a summarised versions of the monitoring programmes are provided in Table 28.

Table 28: Summary of environmental monitoring mechanisms Functional Roles and Monitoring and Reporting Frequency and Time Periods for Implementing Impact Management Activity Impact Requiring Monitoring Requirements for Responsibilities Actions Monitoring  ECO  Internal audits shall be undertaken quarterly and finalised within two weeks of the audit taking place. Implementation Internal and external  External  External audits shall be undertaken annually and finalised within one month of the audit taking place. of Impact Inadequate environmental auditing of the EMPr auditor  Performance Assessment Report (as required by the MPRDA) and the Environmental Audit Report (as management performance and Environmental  Management required by NEMA) will be submitted as a single report, at least once every two years to the DEA and actions Management System  DEA. DMR. Vehicles  Conduct quarterly dust fallout monitoring commencing at least six months prior to construction and for travelling on the first year of construction. Dust fall out monitoring will then be reduced to annually for the remainder unpaved roads, Air Quality Monitoring  ECO of the construction phase. During the Operational phase, dust fallout monitoring shall be quarterly for wind erosion of Air quality deterioration (dust, Programme: Dust and  Air quality the first year of operations and then annually thereafter throughout the LoM. cleared areas PM10 and PM2.5) Fine Particulates specialist  One round of PM monitoring will be undertaken prior to the construction phase to provide additional and stockpiles, baseline data. Annually in winter the continuous monitoring unit will sample the air quality for fine blasting particulates at each of the SDAs for the LoM. activities. General operations including Air Quality Monitoring  ECO transport and Air quality deterioration Programme: NO2, SO2  Air quality  Passive sampling shall be undertaken annually for the LoM. operation of and BTEX specialist machines, Use of hazardous chemicals.

ERPM Ext 2 Mine, East Rand, Gauteng 190 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, September 2019

Functional Roles and Monitoring and Reporting Frequency and Time Periods for Implementing Impact Management Activity Impact Requiring Monitoring Requirements for Responsibilities Actions Monitoring  Permanent monitoring units must be active during the expected time periods of blasting including before  ECO and after blast time. They should be operated for extended periods of time on a daily basis (i.e. from  Adequately Blasting during Damage to structures and 07:00 - 22:00) to monitor possible external influences such as other mines or illegal blasting operations. Blast and Vibration trained shaft property (vibrations, air-blast Monitoring should be conducted throughout construction or until the shafts are at least 50 m deep. Monitoring Programme member of construction and fly-rock) During operation monitoring should run continuously or until it can be proven that the underground staff or blasting is not having an impact on above-ground structures. specialist  The grievance mechanism (i.e. grievance log) must be studied for any complaints relating to blasting. General operations  ECO  Noise monitoring is to be conducted on a quarterly basis for the first year of construction and then Noise monitoring as per including  Air quality reduced to annually provided that no noise complaints are received. At the start of the operational Nuisance noise the Noise Monitoring machinery and specialist phase, noise monitoring is to be conducted on a quarterly basis for the first year then reduced to programme blasting during  HSO annually provided that no noise complaints are received. construction Clearing and grubbing;  Erosion monitoring must be undertaken on a monthly basis throughout the LoM. Soil stockpiling; Soil Monitoring Soil loss  ECO  All areas susceptible to erosion must be monitored bi-annually for a period of five years post-closure Lack of storm Programme: Erosion provided that vegetation establishment of at least 70 % areal cover has been established water management. Soil Monitoring Soil contamination Programme:  ECO  Soil contamination monitoring should be undertaken during decommissioning prior to rehabilitation. Contamination Inadequate Biodiversity loss Aquatic Biomonitoring:  ECO handling of  Monitoring of the freshwater system must take place utilising industry accepted ‘best practice’ Water Management  Aquatic general waste, Habitat loss assessment methods such as the application of the SASS5 and IHAS indices bi-annually. Programme ecologist chemicals and  Boreholes will be monitored for groundwater level on a monthly basis for the LoM. water. Groundwater Monitoring  ECO  Ground water quality will be monitored monthly for the first year of construction and reduced to quarterly Groundwater contamination Programme  Geohydrologist (provided results appear stable) throughout construction, operations and for at least five years post- closure. Biodiversity Monitoring  The initial alien invasive plant species monitoring and eradication must take place at the Alien and Biodiversity loss  ECO Programme: invasive commencement of construction, and follow-up monitoring and eradication must continue in November invasive species  Botanist Habitat transformation plant species monitoring and March each year, throughout the life of mine and for five years post-closure. Biodiversity Monitoring  ECO  Recued plants will be inspected and monitored for survival and growth by a botanist weekly for the first Biodiversity loss Programme: Plant  Botanist two months, monthly for the first year and biannually thereafter for the LoM Shaft and Rescue and Relocation infrastructure  After closure, all areas susceptible to erosion must be monitored bi-annually for a period of two years Soil Monitoring construction post-closure provided that vegetation establishment of at least 70 % areal cover has been established. Soil loss and deterioration Programme: Erosion  ECO  During decommissioning the soil fertility must be assessed by taking a representative sample of the and Fertility stockpiled soils to be analysed prior to rehabilitation.

ERPM Ext 2 Mine, East Rand, Gauteng 191 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, September 2019

Functional Roles and Monitoring and Reporting Frequency and Time Periods for Implementing Impact Management Activity Impact Requiring Monitoring Requirements for Responsibilities Actions Monitoring  Daily measurement of in-situ pH and EC of water entering the treatment plant and any discharges.  Surface water monitoring will take place: o Monthly sampling and analysis of all surface water monitoring points include: pH; EC; Total Surface Water  ECO Suspended Solids; Total Hardness; Total Alkalinity; Na; K; Ca; Mg; Cl; F; SO4; NO3; NH4; Fe; Mn Alteration of hydrology and Monitoring: chemical  Aquatic and; U. Contaminant migration analysis and ecologist o On a biannual basis the following will also be analysed Al; Sb; As; Ba; B; Cd; Cr; Co; Pb; Hg; Ni; biomonitoring Cu; Se; Fe; Mn; V and; Zn  Monitoring of the freshwater system must take place utilising industry accepted ‘best practice’ assessment methods such as the application of the SASS5 and IHAS indices bi-annually. Groundwater Monitoring  Boreholes will be monitored for groundwater level on a monthly basis for the LoM. Lowering of groundwater levels Programme  Ground water quality will be monitored monthly for the first year of construction and reduced to quarterly Surface Water (provided results appear stable) throughout construction, operations and for at least five years post- Loss of surface and Monitoring: chemical closure. groundwater quality analysis and  ECO  Daily measurement of in-situ pH and EC of water entering the treatment plant and any discharges. biomonitoring  Geohydrologist  Surface water monitoring will take place:  Aquatic o Monthly sampling and analysis of all surface water monitoring points include: pH; EC; Total Storage and ecologist Suspended Solids; Total Hardness; Total Alkalinity; Na; K; Ca; Mg; Cl; F; SO4; NO3; NH4; Fe; Mn management of  Hydrologist and; U. mineral waste Deterioration of surface and Surface and Ground o On a biannual basis the following will also be analysed Al; Sb; As; Ba; B; Cd; Cr; Co; Pb; Hg; Ni; with acid groundwater quality water Monitoring Cu; Se; Fe; Mn; V and; Zn generating  Monitoring of the freshwater system must take place utilising industry accepted ‘best practice’ potential assessment methods such as the application of the SASS5 and IHAS indices bi-annually.  Boreholes will be monitored for groundwater level and water quality on a monthly basis for the LoM.  Ground water quality will be monitored monthly for the first year of construction and reduced to quarterly (provided results appear stable) throughout construction, operations and for at least five years post- closure.  Daily measurement of in-situ pH and EC of water entering the treatment plant and any discharges.  ECO  Surface water monitoring will take place: Deterioration of surface and Surface and Ground  Geohydrologist o Monthly sampling and analysis of all surface water monitoring points include: pH; EC; Total ground water water Monitoring  Aquatic Suspended Solids; Total Hardness; Total Alkalinity; Na; K; Ca; Mg; Cl; F; SO4; NO3; NH4; Fe; Mn ecologist and; U. o On a biannual basis the following will also be analysed Al; Sb; As; Ba; B; Cd; Cr; Co; Pb; Hg; Ni; Mine closure Cu; Se; Fe; Mn; V and; Zn.  Monitoring of the freshwater system must take place utilising industry accepted ‘best practice’ assessment methods such as the application of the SASS5 and IHAS indices bi-annually. Loss of habitat Biodiversity Monitoring  ECO  Rehabilitation monitoring must take place seasonally during the summer months for 5 years post- Programme: Biodiversity loss  Botanist closure Rehabilitation Soil loss  After closure, all areas susceptible to erosion must be monitored bi-annually for a period of two years Soil Monitoring post-closure provided that vegetation establishment of at least 70 % areal cover has been established. Programme: Erosion  ECO Loss of land use potential  During decommissioning the soil fertility must be assessed by taking a representative sample of the and Fertility stockpiled soils to be analysed prior to rehabilitation.

ERPM Ext 2 Mine, East Rand, Gauteng 192 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, September 2019

Functional Roles and Monitoring and Reporting Frequency and Time Periods for Implementing Impact Management Activity Impact Requiring Monitoring Requirements for Responsibilities Actions Monitoring Biodiversity Monitoring Environmental Biodiversity and habitat loss  ECO  Rehabilitation monitoring must take place biannually during the summer months for five years post- Programme: rehabilitation (aquatic and terrestrial)  Botanist closure Rehabilitation  Stakeholder Engagement Plan  Social and Labour Plan Effectiveness of proposed Mine operations  Community  Socio-economic monitoring is to occur at least every second month or as identified in the relevant socio-economic mitigation in the Engagement and  ECO specialist reports. An annual monitoring report is to be compiled, containing all of this information, and measures and ensure community Security Forum is to be made available to the CESF. stakeholder input  Community Health and Safety Policy  Grievance Mechanism. Damage of road infrastructure;  Traffic will be monitored on a monthly basis during construction phase and a quarterly basis during Transport and Traffic Monitoring Decrease in road safety;  ECO operations. The loading of trucks and road conditions will be monitored on a monthly basis during the logistics Programme Increase in nuisance traffic construction phase.

ERPM Ext 2 Mine, East Rand, Gauteng 193 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, September 2019

Table 29: Environmental monitoring programmes Scope and objective Time Frames Roles and Responsibilities Reporting Monitoring of Impact Management Actions An environmental management system will be compiled to manage and monitor  Internal audits shall be The ECO shall be responsible  Internal and external audit reports shall identify the performance of all environmental and social management actions. The system undertaken quarterly for ensuring the internal and situations that are not compliant to the EMPr, shall address all aspects regarding the biophysical and social environment and aim and finalised within two external audit and reporting legislation, or industry standard (or finding). The audit to identify and mitigate impacts resulting from those aspects. Monitoring of the weeks of the audit taking process is undertaken within the report shall identify the source of the finding and provide projects’ environmental performance shall be assessed through this system place. required time frame. recommendations on how finding shall be addressed. incorporating internal and external audits.  External audits shall be Management is responsible for  The ECO will develop an action plan to address all the undertaken annually and providing the mandate for findings raised which will include deadlines for the shall be finalised within corrective action. The ECO is actions to be completed. one month of the audit responsible for the  Audit reports and action plan shall be issued to taking place. implementation of the mandate. Management when finalised for approval of the planned actions. Where recommendations are not implemented, management shall, in writing and with the assistance of the ECO, provide alternatives or reasons for not implementing the recommended actions and how to address the resulting impact.  Performance assessment report (as required by the MPRDA) and the Environmental Audit Report (as required by NEMA) will be submitted as a single report, at least once every two years to the DEA and DMR. This report will meet the requirements of both sets of legislation. Air quality monitoring programme Air quality monitoring must be conducted to determine baseline air quality; confirm  Visual monitoring should The on-site ECO is responsible . Records on effectiveness of the dust control measures modelling predictions; assess the effectiveness of air quality management be recorded monthly or for appointing a qualified person must be documented monthly. The ECO must document measures; to qualify air quality at sensitive receptors; to evaluate compliance with when dust generating to undertake monitoring or for the findings of the site inspections and corrective actions the NAAQS at the boundary, with the National Dust Control Regulations at key activities are being undergoing the required training taken. localities; and to provide effective tools for auditing of air quality management undertaken. if monitoring will be undertaken . Dust fallout must be reported on quarterly by the ECO. performance.  Conduct quarterly dust in-house. The ECO will also Meteorological conditions from the weather station/s Targeted air quality monitoring must be undertaken wherever there is a potential fallout monitoring respond to complaints from the must be included in the report. The report must meet the for residential receptors to experience adverse air quality impacts using the commencing at least six public National Dust Control Regulations (GNR827 of 2013) prescribed monitoring and record-keeping procedures and using properly months prior to The HSO is responsible for prescribed reporting requirements for dust fallout. calibrated and maintained equipment. The sites selected for the monitoring construction. Dust fall ensuring the air quality within the . Fine particulates and the passive sampling must be programme are considered to be the most appropriate localities to provide a out monitoring will then mine is within standard. reported on annually. Meteorological conditions from the reliable and representative indication of air quality impacts associated with the be reduced to annually weather station/s should be included in the report. proposed project, as per the outcomes of the atmospheric dispersion modelling. for the remainder of the . If monitoring objectives are not met, the ECO will be Refer to Table 29. In response to any community complaints relating to air quality construction phase. responsible for reporting the findings to management impacts, which can be corroborated by monitoring results, consultation with During the Operational who must then discuss mechanisms to reduce the relevant residents must be undertaken to establish additional air quality monitoring phase, the dust impact, measure the effectiveness of management sites where necessary Prior to construction, baseline air quality monitoring should deposition monitoring measures, and where necessary, intervene further. The be initiated prior to construction to assess background levels of key pollutants. One shall be quarterly for the effectiveness of additional measures will be assessed year of baseline data would provide a comprehensive overview of the existing first year of operations through further monitoring. Any complaints received ambient conditions. However, at least six months of baseline monitoring must be and then annually regarding excessive dust generation in the community conducted. must be treated similarly.

ERPM Ext 2 Mine, East Rand, Gauteng 194 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, September 2019

Scope and objective Time Frames Roles and Responsibilities Reporting Visual monitoring thereafter throughout the . As per the National Dust Control Regulations (GNR827 Site inspections by the ECO must be conducted to provide an indication of the LoM. of 2013) any person who has exceeded the dust fallout effectiveness of the dust control measures. Visual monitoring must be conducted  One round of monitoring limit must, within three months of submission of a dust for activities which are expected to generate the most dust if not managed will be undertaken prior fallout monitoring report, develop and submit a dust effectively (i.e. cleared areas, topsoil stockpiles as well as the unpaved on-site to the construction management plan to the air quality officer for approval. roads and access roads). The visible plumes from on-site sources should not phase to provide . Progress reporting must take place at regular intervals extend past the mine boundaries. The visible plumes behind vehicles should not additional baseline data. (at least annually) during operations. Monitoring results be greater than one vehicle length. Annually in winter the and a summary of any complaints relating to air quality Dust Fallout continuous monitoring received must be combined to determine if monitoring Dust fallout monitoring must be undertaken at the ten selected sites (refer to Table unit will sample the air objectives are being met. Progress in terms of air quality 29). A dust bucket monitoring network must be installed according to the American quality for fine management should be reported to all IAPs, including Society for Testing and Materials standard test method for the collection and particulates at each of authorities and persons who may be affected by analysis of dust fallout (ASTM D1739: 1970), or an equivalent approved method. A the SDAs for the LoM. emissions from the mining activities. Corrective action dust bucket must be installed at each of the monitoring sites. The dust bucket  Passive sampling shall must be taken (i.e. the implementation of contingency network must remain in good working order. be undertaken annually measures) in the event that monitoring objectives have Continuous particulate matter monitor for the LoM. not been met. Install a continuous particulate matter monitor at the northern / north-western boundary of the each SDA (refer to Table 29). The PM unit must remain in good working order. Passive samplers Install ten passive samplers to evaluate the ambient NO2, SO2 and BTEX concentrations at the sites selected in Table 29 Biodiversity Monitoring Programme Alien Invasive Plant Species Monitoring and Eradication . The initial alien invasive The ECO is responsible for: . A report must be prepared by the qualified botanist after Alien invasive plant species monitoring shall be undertaken to ensure that alien plant species monitoring . Ensuring an adequately each Alien and Invasive Plant monitoring survey, and invasive plants are adequately managed, and to promote and increase the and eradication must trained botanist is appointed indicating the status of the alien invasive species spread habitat integrity and species diversity of the area and immediate surroundings. take place at the for the invasive species and recommended further control measures (if Monitoring shall be undertaken within the areas adjacent to the SDAs, access commencement of monitoring, an adequately required). roads, culverts and the topsoil stockpiles and 50 m surrounding the SDAs must be construction, and follow- trained botanist / . Annual monitoring of Alien and Invasive Plant Control conducted by a qualified botanist. up monitoring and horticulturalist is appointed Plan must be performed to determine the extent of Biodiversity Maintenance and Management eradication must for the rescue and relocation infestation and to monitor if the Alien and Invasive Plant Continual environmental monitoring will enable all parties involved to manage continue in November monitoring and an Control Plan is efficient. aspects with the aim of mitigating biodiversity related impacts will include ECO site and March each year, experienced ecologist is . The botanist will prepare a report following each walk-through surveys with specific focus on: throughout construction, appointed to undertake the inspection of the recued / relocated plants providing . Erosion monitoring; operation, rehabilitation monitoring. recommendations and a summary of the past actions . Spill events; and decommissioning, and . An adequately skilled taken to ensure the survival and establishment of the . Waste and litter problems. for five years post- environmental practitioner species of concern. Rescue and relocation monitoring closure. will undertake the . The ECO should complete a daily checklist during the All individuals of species rescued or relocated are to be monitored according to the . Recued plants will be walkthrough surveys and site walk-through surveys including identified issues and rescue and relocation plan that will be drafted before construction. At a minimum, inspected and monitored compile the relevant reports. the proposed management measures which must be recued plants will be inspected and monitored for survival and growth by a botanist for survival and growth implemented. so that actions can be implemented to ensure that relocated individuals have the by a botanist weekly for . A report, including photographs of the rehabilitated greatest chance of establishment. the first two months, areas, must be prepared and signed off by the qualified Vegetation Rehabilitation Monitoring monthly for the first year ecologist / botanist.

ERPM Ext 2 Mine, East Rand, Gauteng 195 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, September 2019

Scope and objective Time Frames Roles and Responsibilities Reporting A qualified ecologist / botanist will monitor vegetation rehabilitation / establishment and biannually thereafter seasonally for at least two growing seasons (2 years) or until > 70 % areal cover is for the LoM. achieved and to provide recommendations which will promote species diversity . Site walk-through and self-sustaining rehabilitated areas. surveys shall be undertaken at least three times a week throughout construction, operation, decommissioning phases. . Rehabilitation monitoring must take place biannually during the summer months for five years post-closure. Blast / Vibration Monitoring Programme Monitoring of the blasting will assist in identifying the source of vibration in the . Permanent monitoring . The ECO is responsible for . A report must be prepared monthly by the person area, whether the associated impacts can be assigned to the project activities and units must be active appointing a suitably undertaking the monitoring. This report must be based ensure that ground vibration from blasting are within the acceptable standards. during times of blasting qualified independent on the recordings at the proposed monitoring points. Monitoring of the blasting the data collected will include: (i.e. must span the specialist or adequately The report must be submitted to the ECO to ascertain . Background ground vibration levels (prior to construction) as a result of other expected time periods of training a staff member to be compliance with the required objectives. mines or illegal blasting operations in the area; blasting including before competent to carry out the . All blast monitoring reports shall be made available to . Ground vibration and air blast results; and after blast time) as monitoring and reporting. IAPs upon request. . Blast Information summary; well as for extended Using an independent . Meteorological information at time of the blast; periods of time on a daily specialist will facilitate . Video Recording of the blast; and basis (i.e. from 07:00 - unbiased evaluations of . Fly rock observations. 22:00) to monitor ground vibration levels; The location of monitoring points is are provided in Table 31. possible external . If monitoring objectives are Monitoring results will allow the project to corroborate any community complaints influences such as other not met, the ECO must relating to blasting impacts, consultation with relevant residents must be mines or illegal blasting report the findings to undertaken to establish additional monitoring points where necessary. operations. management. Changes will Monitoring must be done using appropriate seismographs installed in permanent . Monitoring should be be implemented to reduce positions (Table 31). These seismographs measure the ground vibration intensity conducted throughout the impact using the “plan, as velocity in mm/s. The required seismographs must be set to trigger from construction or until the do, check, act’ model i.e. ground vibration levels above a specific threshold. Generally, such threshold will shafts are at least 50 m further monitoring will be such that it will register generated ground vibration from blasting operations but deep to determine the measure the effectiveness of also high enough not to trigger from any movement or vehicle travel close to the baseline levels from the management measures seismograph. Threshold levels are to be set in the order of 1.5 mm/s. This is external influences and which are in place, and greater than false triggering and significantly lower than the monitoring objectives. continuously throughout where necessary, further Photographic inspections should be undertaken of all structures within 1000 m of the operation phase or intervention implemented; the proposed shafts prior to construction. Installations within the regulatory 500 m until it can be proven that . The grievance mechanism which require specific attention are provided in Table 32. the underground blasting (i.e. grievance log) must be External consultation and monitoring should be considered for all ground vibration is not having an impact studied for any complaints and air blast monitoring work. Audit functions may also be conducted to assist the on the above-ground relating to blasting. Any mine in maintaining a high level of performance with regards to blast results and structures. complaints received must be monitoring the effects related to blasting operations. investigated by the ECO

ERPM Ext 2 Mine, East Rand, Gauteng 196 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, September 2019

Scope and objective Time Frames Roles and Responsibilities Reporting Compliance levels for ground vibration are provided in Table 32. These levels are (informed by monitoring sufficient to ensure that damages to surface structures do not occur. Blasting is to findings) and the monitoring be managed to ensure that vibration and air blast are below theses limits. programme updated where necessary; and . Compensation for damage would then need to be considered where necessary. Noise Monitoring Programme Noise monitoring is to be undertaken to ensure that noise produced by the project . Noise monitoring is to be . The ECO must appoint a A report must be prepared by the specialist after each is sufficiently managed and within acceptable standards. Monitoring results will conducted on a quarterly suitably qualified specialist to monitoring survey. This report must be based on the also be useful when responding to noise related community complaints, which can basis for the first year of carry out the monitoring and recordings at the proposed monitoring points and be be corroborated by monitoring results. Environmental noise monitoring must be the construction phase reporting; submitted to the ECO to ascertain compliance with the conducted at the recommended monitoring points (Table 33 and Figure 35) to and then reduced to . If monitoring objectives are required standards at sensitive receptors. determine the noise levels being generated by activities related to the operational annually provided that no not met the ECO must report activities, to detect deviations from predicted noise levels to be generated from noise complaints are the findings to management, activities and to enable corrective measures to be taken where warranted. received. who can then discuss Consultation with relevant community residents must be undertaken to establish . At the start of the mechanisms to reduce the additional monitoring points where necessary. operational phase, noise impact, measure the Noise monitoring must be carried out according to the SANS 10103:2008 (or an monitoring is to be effectiveness of the equivalent approved method) by a specialist with calibrated recording equipment. conducted on a quarterly management measures Readings must be taken hourly for a 24 hour period to determine daytime and basis for the first year which are in place, and night time noise levels. Noise measurements should be taken for a period of not then reduced to annually where necessary, intervene less than 10 minutes at each location. Noise levels at the monitoring points should provided that no noise further. The effectiveness of not exceed the acceptable rating levels (Table 34) by more than 5 dB as a result of complaints are received. additional measures will be mining activities during the LoM. assessed through further monitoring; and . The grievance mechanism (i.e. grievance log) must be studied for any complaints relating to noise. Any complaints received must be investigated by the ECO (informed by monitoring findings) and the monitoring programme updated where necessary. Socio-economic Monitoring Programme This programme will monitor the progress and effectiveness of proposed socio- Socio-economic monitoring . The ECO must appoint a An annual monitoring report is to be compiled, containing all economic mitigation measures and ensure stakeholder input is considered as part is to occur at least every suitably qualified specialist to of this information, and is to be made available to the CESF. of the ongoing implementation process. Ongoing stakeholder engagement will play second month or as carry out the monitoring and a key role in monitoring impacts and the effectiveness of mitigation and identified in the relevant reporting management strategies. monitoring programme.

ERPM Ext 2 Mine, East Rand, Gauteng 197 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, September 2019

Scope and objective Time Frames Roles and Responsibilities Reporting The following residential areas will need to be monitored in order to ensure that potential socio-economic impacts are recorded and documented, which will facilitate effective mitigation and management: . The two farmhouses near the Windmill Shaft SDA . Withok Estates; . Eggbert Eggs; . Areas directly bordering the Witpoortje Shaft SDA. The following aspects need to be monitored: Establishment of informal settlements Should any new informal settlements emerge in the vicinity of the mine, the size and location must be monitored and mapped on a 6 monthly basis to determine if there is any growth. Establishment of tuck shops in the vicinity of the mine should be monitored to ensure that any informal retail activities are controlled and are not permitted to become nuisance / safety factors. Community perception and experience of crime in their area Crimes must be reported to the mine so that a record can be kept of criminal activity within and around the mine. This will assist ERPM in monitoring and managing the potential increase in crime as a result of in-migration and community expansion. All grievances must be recorded and dealt with as per the established grievance mechanism / procedure. Air Quality Air quality and dust within and around the mine site must be monitored in accordance with the AQIA. The AQIA details seven monitoring points located within the MRA and in locations where there are sensitive receptors outside the MRA. If complaints are experienced about any aspect of air quality, then more frequent or investigative sampling must be undertaken. The mine must ensure that dust deposition rates in the sensitive receptor communities remain compliant at all times with the Residential Guideline and adopt the Industrial Guideline for the on-site target, and also ensure that air quality at the boundary of the mine remains compliant with the National Ambient Air Quality Standards for PM10, PM2.5, NO2 and SO2. If they exceed acceptable limits, corrective measures must be implemented to ensure that standards are met. Noise The Noise Impact Management Plan (NIMP) laid out in the Noise Impact Assessment must be updated to include any requirements or conditions laid out by the authorities. All contractors must be bound by the NIMP (including construction and mining contractors). The NIMP details monitoring points that should be monitored every 3 months during the first year, and then annually thereafter. The aim of the monitoring programme is to detect deviations from predicted noise levels and enable corrective measures to be taken where warranted. Baseline noise monitoring should be undertaken at all the proposed monitoring sites prior to the commencement of construction to determine the ambient sound level baseline for comparison when the facility is operational. A community relations committee should be established to act as a formal vehicle of communication of issues and

ERPM Ext 2 Mine, East Rand, Gauteng 198 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, September 2019

Scope and objective Time Frames Roles and Responsibilities Reporting concerns. All noise related complaints must be recorded and addressed as per the grievance mechanism. Blasting The blast monitoring elements as described in the blasting impact assessment should be monitored. These include: . Ground vibration and air blast results; . Blast information summary; . Meteorological information at time of the blast; . Video recording of the blast; . Fly rock observations. Ground vibration and air blast monitoring requires identified locations for monitoring. Proposed positions were selected to indicate the nearest POIs at which levels of ground vibration and air blast should be within the accepted norms and standards. The monitoring of ground vibration will also qualify the expected ground vibration and air blast levels and assist in mitigating these aspects properly. Ground vibration and air blast level limits, and times and conditions for blasting have been recommended in the Blasting Impact Assessment. These limits should be strictly adhered to. The results of blasting monitoring are to be made available through the CESF. Groundwater The groundwater monitoring programme detailed in the Groundwater Impact Assessment and EMPr must be adhered to. The monitoring programme for groundwater quality should be done monthly at first, and then quarterly. Groundwater quality monitoring should comply with the relevant legislation, and also correspond to the parameters suitable to monitor gold mining activities. Soil Monitoring Programme Erosion . Erosion monitoring must The ECO must appoint a . Annual erosion monitoring reports must be prepared by During construction and operation erosion monitoring must be undertaken on a be undertaken on a suitably qualified service the ECO and mine surveyor (including checklists and monthly basis, including visual assessments and topographic surveys in areas monthly basis throughout provider to conduct the required photographs). If erosion is noted, repair, maintenance susceptible to erosion (such as roads, culverts and bare areas), to determine the LoM; and sampling. The ECO/ Site and prevention measures must be implemented. erosion rates, identify areas of concern and soil management measures to be . After closure, all areas manager must conduct the . A report containing the results of the contamination taken. This is to ensure that there is no undue soil erosion that is allowed to susceptible to erosion required erosion monitoring. monitoring and the fertility monitoring must be prepared develop before effecting repairs must be monitored bi- to inform the remediation and amelioration efforts All areas susceptible to erosion must be monitored annually and repair, annually for a period of required during rehabilitation to ensure that closure maintenance and prevention measures implemented (if erosion is noted) for a five years post-closure objectives are met. period of 2 years post-closure provided that vegetation establishment of at least 70 provided that vegetation % areal cover has been established. establishment of at least Soil contamination 70 % areal cover has Soil contamination monitoring will ensure timely actions are taken to eliminate or been established. control the sources of soil contamination and prevent or reduce the risk of . Soil contamination contaminant transfer from impacted soils to other environmental media (air or monitoring should be water) or potential receptors. The assessment must be carried out after stockpiling undertaken during and during decommissioning prior to rehabilitation. Soil analyses should include decommissioning prior to pH, EC and the metals, metalloids, hydrocarbons and anions as listed in terms of rehabilitation.

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Scope and objective Time Frames Roles and Responsibilities Reporting the “SSV from GNR 331 of 2014 National Norms and Standards for the . During decommissioning Remediation of Contaminated Land and Soil Quality” to determine if there are any a representative sample exceedances relative to the SSV 2 – Commercial and Industrial guidelines. If of the stockpiled soils exceedances are found, appropriate remediation measures must be implemented must be analysed prior to such that the soil quality is in line with the planned land use for the area. rehabilitation. Soil fertility A representative sample of the stockpiled soils must be analysed prior to rehabilitation to determine the nutrient status and chemistry of the utilisable materials. As a minimum the following elements must be tested for: EC, CEC, pH, Ca, Mg, K, Na, P, Zn, Clay % and Organic Carbon. Traffic Monitoring Programme Traffic shall be monitored to ensure that roads are not damaged by the project Traffic will be monitored on a The ECO will be responsible for The ECO will be responsible for compiling traffic and road related traffic and assess if road upgrades that are made are effective in reducing monthly basis during traffic monitoring as well as condition reports following each monitoring event. Reports queuing traffic as a result of the project. Dust generated from traffic will be construction phase and a collecting the data relevant to shall include, at minimum, interpreted data and monitored according to the Air Quality Monitoring Programme. quarterly basis during road conditions. recommendations Traffic operations. The loading of Traffic monitoring will be undertaken at the access intersection where queue trucks and road conditions lengths will be monitored. The complaints register will be reviewed for any traffic will be monitored on a related grievances logged. monthly basis during the Road conditions construction phase. The loading of trucks will be monitored to ensure they are not overloaded and the pavement condition of a 2 km length of Barry Marais Road which provides access to the Windmill Shaft will be inspected for deterioration and photographs will be taken for records. Surface Water Monitoring Programme Surface water quality monitoring is undertaken to indicate if water resources are . The volume of water The ECO must appoint service A report must be prepared by the specialist after each being influenced by the project. Therefore, it is important to ensure that the water pumped from the mine provider or suitably train a monitoring survey. If monitoring objectives are not met, the is adequately characterised prior to the project being implemented so the water shall be recoded daily. member of staff to conduct the ECO will be responsible for reporting the findings to quality data collected in the future will have a baseline that it can be compared to. . Daily measurement of in- required sampling monitoring management who must then discuss mechanisms to reduce If considerable deterioration of the water resources is noted, investigations can situ pH and EC of water and reporting. At least one round the impact, measure the effectiveness of management identify the cause and actions can be implemented to manage the impact. Water entering the treatment of sampling per year will be measures, and where necessary, intervene further. The quality will be assessed using laboratory analysis (SANAS accredited) and aquatic plant and discharges. undertaken by an external party. effectiveness of additional measures will be assessed biomonitoring. Although it is not expected that discharge will be undertaken, the . Monthly sampling and through further monitoring quantities of groundwater that may be intercepted are unknown at this stage. To analysis of all surface address this gap monitoring measures to mitigate potential impacts resulting from water monitoring points the discharge of groundwater have been included. include: pH; EC; Total A hydrologist shall identify monitoring points including at minimum: Suspended Solids; Total . An up-stream and downstream of each of the SDAs within the quaternary Hardness; Total catchment C22C Alkalinity; Na; K; Ca; Mg; . A monitoring point downstream of the confluence of catchments C22C and Cl; F; SO4; NO3; NH4; C22B Fe; Mn and; U. . Any surface water resources likely to receive runoff from the SDAs . On a biannual basis the . Any discharge water from the proposed mine (during construction, operation following will also be and post-closure phases) analysed Al; Sb; As; Ba; . Any point likely to receive decant water from the proposed mine. B; Cd; Cr; Co; Pb; Hg;

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Scope and objective Time Frames Roles and Responsibilities Reporting Monitoring points will be used for both laboratory and aquatic monitoring. During Ni; Cu; Se; Fe; Mn; V chemical analysis at least one blank (distilled water) and one duplicate shall be and; Zn. analysed for quality control purposes. . Biomonitoring for SASS5 The quantity of water pumped from the mine shall also be gauged and recorded. and IHAS indices will be Chemical analysis undertaken on a bi- Monitoring of physical and chemical parameters will be undertaken and analysed annual basis and by a SANAS accredited laboratory. The daily monitoring may be undertake using a diatoms will be analysed calibrated handheld probe. every two years Biomonitoring throughout the LoM and Monitoring of the freshwater system must take place utilising industry accepted for five years post- ‘best practice’ assessment methods such as the application of the SASS5 and closure. IHAS indices. Watercourse rehabilitation and management The Watercourse Rehabilitation and Management Plan aims to provide mitigation measures to manage and rehabilitate potential impacts that could affect the Hillslope Seep (HSS) wetland and the Channelled Valley Bottom (CVB) wetland during the proposed mining activities. This WRMP identifies the responsible parties and relevant timeframes (where applicable). The key aims of the WRMP include: . Maintenance of the Present Ecological State (PES) of the CVB wetland and HSS wetland associated with the development of the Witpoortje Vent Shaft and Windmill Shaft, and where possible improve the ecological conditions of the system through rehabilitation of historic anthropogenic activities that have altered the ecological functioning of these systems . Minimisation of impacts on surface water and groundwater quality; . Reinstatement of ecological services and topographical sequences; . Alien invasive plant species control, protection and the reinstatement of indigenous vegetation; . Erosion control and siltation management, including topsoil management and bank stabilisation; and . Prudent monitoring to ensure timeous detection of, and response to damage caused by mining activities and the development of infrastructure. This WRMP advocates the use of several environmental management tools and mitigatory measures appropriate to the overall planning process of the construction, operational and is provided in Appendix 17.1. Groundwater Monitoring Programme Designated monitoring boreholes must be drilled between underground mining . Boreholes will be The ECO must appoint a A report must be prepared by the ECO after each operations and the external users’ boreholes prior to construction. Dedicated monitored for suitably qualified service monitoring survey. If monitoring objectives are not met, the groundwater monitoring boreholes to be installed include: groundwater level and provider to conduct the required ECO will be responsible for reporting the findings to . Down gradient of the topsoil stockpile and WRD areas water quality on a sampling, monitoring and management who must then discuss mechanisms to reduce . In the vicinity of the Windmill Shaft A and Shaft B monthly basis for the interpretation of groundwater the impact, measure the effectiveness of management . In the vicinity of the Witpoortje vent shaft. LoM. monitoring data. measures, and where necessary, intervene further. The The hydrocensus points close to the zones of impact and the return water should . Ground water quality will effectiveness of additional measures will be assessed form part of the monitoring network (i.e. HBH1, HBH4 and HBH9). be monitored monthly for through further monitoring. Water quality monitoring parameters will include: the first year of . General chemistry such as pH, TDS and EC construction and reduced

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Scope and objective Time Frames Roles and Responsibilities Reporting . Major elements such as calcium, magnesium, sodium, potassium, sulphate, to quarterly (provided At least ten years prior to planned closure monitoring nitrate, fluoride, chloride, phosphate results appear stable) period, the surface and groundwater data shall be reviewed . Minor elements including aluminium, arsenic, barium, boron, bismuth, throughout construction, by a hydrogeologist in order to: cadmium, copper, chrome (total), cyanide, iron, manganese, mercury, operations and for at . Develop a local ground water model prior to construction molybdenum, nickel, lead, antimony, selenium, vanadium and zinc. least five years post- . A regional ground water model within five years of The objectives of the groundwater monitoring programme is to: closure. operation which will help predict the of influences the . Groundwater levels must not decrease to an extent that it impacts surrounding decant potential, locality of expected decant points, external users decant volumes and decant qualities . Groundwater quality must not deteriorate as a result of the mining activities . Quantify the contaminant migration . Establishment of groundwater remediation plans. . Establish the scope of the groundwater remediation requirements that are to be implemented.

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Monitoring Programmes – detail for air quality, blasting and noise (sample sites and objectives)

Table 30: Air quality monitoring points DFO Sampler Co-ordinates Location Site Windmill SDA 26°18'17.58"S WM-AQ1 Located on the northern boundary of the Windmill SDA 28°16'53.09"E 26°19'09.65"S Commercial chicken farm property (Eggbert Eggs – Maye Serobe Laying Site) directly south-east WM-AQ2 28°17'22.37"E of the Windmill SDA 26°20'23.79"S Commercial chicken farm property (Eggbert Eggs – Rebafenyi Rearing Site) located immediately WM-AQ3 28°17'38.96"E north-east of the Argo slimes dam and south-east of the Windmill SDA 26°18'31.75"S WM-AQ4 Residential small-holding farm property immediately east of and adjacent to the Windmill SDA 28°17'16.76"E 26°17'37.27"S Rural area nearby to residential community to west of Windmill SDA and nearby to the access WM-AQ5 28°16'45.99"E route (gravel road) Central MRA 26°17'55.49"S CM-AQ6 Open grassland located between the Windmill SDA and Witpoortje SDA 28°18'58.37"E Witpoortje SDA 26°17'39.03"S WP-AQ7 Residential property immediately west of and adjacent to the Witpoortje SDA 28°20'44.35"E 26°17'57.38"S WP-AQ8 Residential/commercial property directly south of the Witpoortje SDA 28°20'50.47"E 26°17'28.31"S WP-AQ9 Rural area directly north of the Witpoortje SDA 28°20'51.15"E 26°16'59.70"S WP-AQ10 Residential community directly north-east of the Witpoortje SDA 28°21'05.49"E

Table 31: Blast monitoring points Co-ordinates Monitoring site Longitude Latitude Chicken Broilers 70818.80 2912266.54 Gravel Road 71482.41 2910757.03 Pipeline 71393.15 2911007.79

Table 32: List of possible installations within the regulatory 500 m for Shaft A and Shaft B Description Y X Farm Buildings/Structures 71062.43 2911211.51 Power lines/Pylons 71893.43 2910853.89 Power lines/Pylons 71729.83 2910645.31 Gravel Road 71482.41 2910757.03 Cultivated Fields 71095.10 2910796.32 Gravel Road 71303.91 2911326.47 Pipeline 71393.15 2911007.79 Pipeline 71259.27 2911442.78

Table 33: Blasting monitoring objectives Structure Description Ground Vibration Limit (mm/s) Air Blast Limit (dBL) National Roads/Tar Roads: 150 N/A Electrical Lines: 75 N/A Railway: 150 N/A Transformers 25 N/A Water Wells 50 N/A Telecoms Tower 50 134 General Houses of proper construction USBM Criteria or 25 mm/s Shall not exceed 134dB at point of concern Houses of lesser proper construction 12.5 but 120 dB preferred Rural building – Mud houses 6

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Table 34: Noise monitoring points Monitoring site Location Current SANS Land-use Classification / District type WM-SL1 26°18’28.34” S 28°17’01.19” E Rural district WM-SL2 26°19’06.32” S 28°17’24.44” E Rural district WM-SL3 26°20’14.77” S 28°17’33.59” E Rural district WM-SL4 26°18’31.28” S 28°17’17.27” E Rural district WM-SL5 26°17’56.25” S 28°16’36.40” E Rural district WM-SL6 26°17’20.54” S 28°17’16.83” E Rural district WP-SL1 26°17’56.96” S 28°20’50.56” E Rural district WP-SL2 26°17’38.57” S 28°20’43.59” E Rural district WP-SL3 26°16’58.66” S 28°21’05.80” E Suburban districts with little road traffic WP-SL4 26°17’36.59” S 28°21’15.88” E Rural district WP-SL5 26°17’36.01” S 28°20’53.63” E Rural district B-SL1 26°17’55.09” S 28°18’58.77” E Rural district B-SL2 26°17’36.62” S 28°18’40.79” E Rural district B-SL3 26°17’42.85” S 28°19’08.77” E Rural district

Table 35: Acceptable rating levels for noise in districts (SANS 10103: 2008) District type Day-time db(A) Night-time db(A) Rural districts 45 35 Suburban districts with little road traffic 50 40 Urban districts 55 45 Urban districts with main roads 60 50 Central business districts 65 55 Industrial districts 70 60

l. Indicate the frequency of the submission of the performance assessment report

MPRDA Regulation 55(1) (of the MPRDA Regulations GNR527 of 2004) stipulates the requirements for performance assessments of the EMPr (in sub-regulation [3]) to be undertaken every two years, to ensure compliance with the EMPr and to determine the continued appropriateness and adequacy of the EMPr.

NEMA also makes provision for environmental audits of the EMPr, as per Regulation 34 of the NEMA EIA Regulations, GNR982 of 2014 (as amended by GNR326 of 2017), which must be conducted to determine whether the programme sufficiently provides for the avoidance, management and mitigation of environmental impacts. Regulation 35 of the NEMA EIA Regulations requires an Environmental Audit Report to be submitted to the CA at the frequency specified within the EA. Within 7 days of the date of submission of an Environmental Audit Report to the CA, the Applicant must notify all potential and registered IAPs of the submission of that report, and make the report immediately available to anyone on request and on a publicly accessible website. The EA will also specify the frequency of updating the EMPr and Closure Plan.

It is anticipated that the performance assessment report (as required by the MPRDA) and the Environmental Audit Report (as required by NEMA) will be submitted as a single report, at least once every two years. This report will meet the requirements of both sets of legislation.

m. Environmental Awareness Plan a) Manner in which the applicant intends to inform his or her employees of any environmental risk which may result from their work

Employees will undergo environmental awareness training as per the Environmental Awareness Plan. Contractors will undergo environmental awareness training as part of induction prior to the commencement of construction and decommissioning activities, and relevant aspects of the EMPr will be extracted for use by contractors. The Environmental Awareness Plan provides for periodic awareness training throughout the LoM. Adherence to the Environmental Awareness Plan as well as provision of periodic environmental awareness training will be monitored and enforced by the ECO throughout the LoM. The contents of the Environmental Awareness Plan are detailed below:

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Objectives

 All personnel must be made aware of the environmental management requirements;  All personnel, as a minimum, will undergo general environmental awareness training, which will highlight the environmental responsibility of all employees (mine employees and contractors); and  Those personnel whose functions may have a significant impact on the environment will receive the appropriate specialised training, so that they may perform their designated tasks adequately.

Types of Training

There are two types of training that will be undertaken - awareness training and competency training. Awareness training refers to acquiring knowledge of the Environmental Policy, EMPr requirements, legal requirements and key environmental issues. Awareness training is general in nature, similar in content irrespective of job description, delivered from an environmental perspective, and conducted in a classroom or boardroom setting or during site visits.

Competency training is job-orientated. It refers to training that ensures that any task that may have a significant impact on the environment is performed properly. Competency training is specific in nature, dependent on individual job descriptions, aimed at ensuring that key tasks are performed correctly, and involves classroom or boardroom instruction and on-the-job training.

Training Requirements

Personnel may require either awareness or competency training, or both, depending on their job description. The agenda for the environmental awareness course must consist of the following:

 A definition of what the environment is;  Environmental rights;  Constitutional rights;  NEMA, and the rights of a whistle blower;  Why we must look after the environment;  How we should look after the environment;  Details of working areas;  The possible presence of subterranean archaeological and/or paleontological sites, features or artefacts, the penalties associated with the unlawful removal of these artefacts, as set out in the NHRA as well as of the chance finds procedure;  Management of streams, rivers and wetlands;  Management of biodiversity including:

o The importance of biodiversity; o The different habitats in the area; o The habitats that the teams must avoid; o Reasoning why species should not be harvested or used as firewood; o Speeding and the impacts on biodiversity; o Alien invasive species; o Incentives for reporting any instances of speeding or harvesting etc.; o Avoidance (and not destruction) of feared species such as snakes; and o Contacts for snake removals.  Details regarding smoking and fires;  Management of petrol, oil and diesel (and other chemicals);  Dust management;  Ablution facilities;  Waste management;  Traffic and road safety;

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 Emergency procedures and numbers; and  Appropriate manner of interacting with neighbouring communities.

Frequency of Training

All new employees, as well as contractors, will be expected to undergo environmental awareness training as part of their induction. This induction will occur within the first two weeks of employment.

New employees who undertake activities that have or may have a significant environmental impact will, upon employment, have a personalised training programme developed as part of his/her job description. This programme will include any required competencies associated with that employee’s environmental management role, and the means and timeframe by which this competency is meant to be achieved. Adherence to this programme will be monitored. The employee will be required to successfully complete the programme.

Contractor employees who undertake activities that have or may have a significant environmental impact will undergo awareness training prior to the commencement of any such activities. b) Manner in which risks will be dealt with in order to avoid pollution or the degradation of the environment

The EMPr details commitments in order to avoid pollution or the degradation of the environment. Compliance with the EMPr commitments will form part of the contractors’ contract, and relevant aspects of the EMPr should be extracted for use by contractors. Employees will also be briefed regarding the EMPr commitments prior to the commencement of operations. The ECO will monitor that the commitments are being adhered to by the contractors during the construction and decommissioning phases as well as by employees during the operational phase.

The Emergency Preparedness and Response Plan (EPRP) must be consulted in the event an emergency condition occurs which may result in the pollution or the degradation of the environment.

Contractors will be provided with a copy of the EPRP and will be briefed on the contents of the plan during induction prior to the commencement of construction activities. Employees will be briefed regarding the EPRP as part of their in induction. The ECO will monitor that the EPRP is being adhered to by the contractors as well as by employees during the LoM.

Components of the EPRP are detailed below:

General Communication Procedures

Communication procedures include:

 Communication of hazards to local communities and local authorities; and  Co-ordination of emergency response (both internal and with local emergency services) that will deal effectively with accidents and prevent major disasters.

Emergency and Hazard Identification

The EPRP identifies all environmental emergencies or hazards that may arise on the site, for which emergency procedures must be developed.

The following emergencies / hazards may occur at the ERPM Ext 2 site:

 Hazardous chemical spill;  Oil spill;  Bulk fuel spillage;  Large-scale erosion;  Uncontrolled fires;  Traffic accident; and  Natural disaster (i.e. earth tremor).

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Emergency Procedures

The following are the standard emergency procedures for each of the emergencies / hazards which may occur:

Hazardous Chemical Spill

 Detoxification, clean-up and rehabilitation of spillages;  All personnel who form part of emergency reaction teams for hazardous chemical spillages will be trained and able to apply detoxification procedures;  Spillages will be cleaned up as soon as possible to minimise the exposure to members of the public, production personnel and the environment;  Notification of mine personnel, emergency services and relevant government departments;  Procedures to be followed by mine and plant personnel;  Protection of sensitive habitats, fauna and flora, and livestock; and  Evacuation of local communities.

As far as possible, assistance will be obtained from Hazchem emergency response units for dealing with major spills. Where this is not possible, production personnel required to enter the area will be trained and fully equipped with MSDS and approved Personal Protective Equipment (PPE).

The following actions must be taken when a hazardous chemical spill occurs:

 Establish what has happened, the nature and extent of the spill, and the chemical involved. Obtain MSDS. If staff are unsure of what has occurred and what chemicals have been spilled, the area must be isolated;  Casualties must be identified and treated;  The responsible area manager, Health and Safety representative, ECO, and emergency response team must be informed. These contact numbers must be on the list of emergency contact details; and  To contain and clean a chemical spill, the instructions on the MSDS must be followed. The area must be cordoned off and kept clear until the spill has been cleaned.

Oil Spill

Oil spills can occur over most of the site and the major sources will be leaks from mobile plant, machinery, winding and compressor rooms, hydrocarbon stores and recycling area. These spills may be minor (i.e. a few spots) or major (i.e. a 220 ℓ drum falling over onto the soil). Negligence is also a source of oil spills where contractors or site staff are servicing machinery and plant, and allow used oil to spill onto the ground. There is also the potential for equipment and machinery breakdowns on the site. MSDS will be kept at the stores for each type of hydrocarbon on the site. These will contain information on decontamination procedures and the correct procedure to follow in the event of a spill. The mine manager will also place emergency spill kits (i.e. plastic tarpaulin, a 220 ℓ drum, a broom and an absorbent to soak up the material) at strategic locations around the site and these will be audited annually.

The following actions must be taken in the event of an oil spill:

 Establish what has happened, and the nature and extent of the spill and obtain the relevant MSDS;  The responsible area manager and ECO must be informed. These contact numbers must be on the list of emergency contact details; and  To contain and clean a spill, the instructions on the MSDS must be followed. The area must be cordoned off and kept clear, and the spill contained and cleaned up immediately. Any contaminated soil, vegetation or rock must be removed and disposed of at a licensed landfill facility.

Bulk Fuel Spillage

The following actions must be taken in the event of a bulk fuel spill:

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 Establish what has happened, and the nature and extent of the spill, damage to bund walls, when last the tanks were pressure tested and whether this is within the supplier specifications. Obtain MSDS;  The responsible area manager, health and safety representative, ECO, and emergency response team must be informed. These contact numbers must be on the list of emergency contact details;  The spill must be prevented from entering into any watercourses;  If it is unclear whether the fuel has spilled from, the area must be isolated; and  To contain and clean a spill, the instructions on the MSDS must be followed. The area must be cordoned off and kept clear. Any contaminated soil, vegetation or rock must be removed and disposed of at a licensed landfill facility, or be treated at a bioremediation facility.

Large-scale Erosion

The area is relatively flat and the area around the TSF and a portion of the WRD, where the heavy darker clay soils occur, has a high erosion potential. Activities related to the mine such as discharging excess treated water to the Rietspruit, stockpiling soil and stormwater runoff across unpaved roads and cleared areas may result in erosion. Therefore, the potential for large-scale erosion to occur does exist should prevention and management measures not be implemented.

The following actions must be taken in the event large-scale erosion:

 The ECO must be informed. The contact number must be on the list of emergency contact details;  Establish whether erosion is being prevented or controlled, especially alongside unpaved roads and at the discharge point, and whether erosion is occurring on any slopes, what has caused the erosion to occur, and the nature and extent of the erosion;  The area must be stabilised and where possible, soil exposed to rain and wind should be vegetated; and  Where sediment is eroding towards a watercourse, this must be prevented and any sediment must be contained.

Uncontrolled Fire

The responsible area manager in conjunction with the ECO on site must take measures to prevent fires on the site. These parties will ensure that there is adequate fire-fighting equipment, which is regularly maintained and that specified workers will receive formal fire-fighting training. Finally, it is the responsibility of mine management to ensure that there is an adequate system of firebreaks in place and that all fire hazard ‘hotspots’ have been identified.

The fire emergency procedure is as follows:

 Raise the alarm by sounding the fire alarm system, informing responsible area manager, Health and Safety representative, ECO, and the mine fire-fighting representative;  Determine the location and severity of the fire;  The Municipal fire department must be notified if the fire cannot be extinguished by the fire-fighting representative. The emergency number for the closest fire station must be located on the list of emergency contact details;  Apply basic fire-fighting procedures if possible and apply evacuation procedures if necessary; and  If evacuation is deemed necessary, assemble at the emergency control point and obey all instructions from the fire- fighting representative.

Traffic Accidents

This procedure addresses accidents that occur within the site boundary. All bulk chemical transporters will be the responsibility of the supplier and accident management will be according to their procedures.

The following actions must be taken in the event of a traffic accident:

 Establish what has happened, including the location, nature, and status of the accident; the nature and extent of injuries or damage; and the nature and extent of any spills or leaks (where chemicals may be involved – refer to earlier relevant procedures);

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 The responsible area manager, Health and Safety representative, ECO, and emergency response team must be informed. These contact numbers must be on the list of emergency contact details;  Isolate the accident scene and treat any casualties; and  Depending on the seriousness of the accident, notify the closest emergency services. The emergency number for the closest emergency services must be on the list of emergency contact details.

Natural Disaster

The manager in conjunction with the group environmental manager and the ECO on site will co-ordinate their response with that of the Municipal Disaster Management team. All parties and section managers will ensure that there is adequate equipment (fire-fighting, medical, rescue, etc.), which is regularly maintained. This team will ensure that all workers will receive training on how to respond in the event of a natural disaster (i.e. earth tremor or in the unlikely event of subsidence occurring).

The disaster management emergency procedure is as follows:

 Raise the alarm by breaking the nearest break-glass unit on the fire alarm system;  Inform site management, fire station, closest Joint Operations Centre (JOC), and the Municipal Disaster Management Centre. These contact numbers must be on the list of emergency contact details;  Determine the location and severity of the disaster;  Apply basic disaster management procedures and ensure that dangerous areas are cordoned off, and apply evacuation procedures if necessary;  Ensure the evacuation of local communities if necessary; and  Assemble at the emergency control point and obey all instructions from the emergency representative.

n. Specific information required by the Competent Authority (among others, confirm that the financial provision will be reviewed annually)

The Applicant commits to reviewing the Financial Provision on an annual basis as per the requirements of Section 24(P)(3) of NEMA, which states that every holder must annually assess his or her environmental liability and, if circumstances so require, must adjust his or her financial provision to the satisfaction of the Minister responsible for mineral resources.

The Applicant commits to conduct EMPr performance assessments as required in terms of Regulation 55 of the MPRDA on a biennial basis and external environmental audits of the EMPr and EA as per the NEMA EIA Regulations, GNR982 of 2014 (as amended by GNR326 of 2017) according to the frequency indicated in the EA.

The CA requested the following information on 2 July 2019 in the Scoping Report acceptance letter:

Where addressed Information requested Response in the EIA EMPr Please ensure that comments from all relevant stakeholders All relevant stakeholders including GDARD, are incorporated into the EIAR to be submitted to this DAFF and DWS were provided an opportunity to Department. This includes (but is not limited to) GDARD, comment on the Scoping Report and will be Refer to Appendix Department of Agriculture, Forestry and Fisheries (DAFF), provided an opportunity to comment on this 4.6 for proof of DWS and the local municipality within which the application EIAR /EMPr. Proof of distribution of the Scoping distribution of the area falls. Proof of correspondence with the various Report is included in this EIAR / EMPr. Proof of Scoping Report. stakeholders must be included in the EIAR. Should you be distribution of the EIAR / EMPr for comment will

unable to obtain comments, proof of the attempts that were be included in the final EIAR / EMPr submitted to Refer to the made to obtain comments should be incorporated into the the DMR for consideration. comments and EIAR to be submitted to this Department. Comments received from all relevant responses table stakeholders have been incorporated into this (Section 3.g.iii) of EIAR. All comments received to date are the EIAR - Part A of included in the comments and responses table. this document. This table was updated to include all comments received during the PPP and included in the final EIAR submitted to the DMR for consideration. The EIAR must be submitted in accordance with Regulation 23 The IAPS were informed of the Department's of the NEMA EI Regulations 2014. The IAPs, during the PPP Refer to the EIA BID decision to accept the Scoping Report during the of the EIAR, must be informed of the Department's decision to (Appendix 4.10). EIA PPP. accept the Scoping Report.

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Where addressed Information requested Response in the EIA EMPr You are hereby reminded to comply with the requirements of This is the final EIAR /EMPr (which has been regulation 3 of the NEMA EIA Regulations, 2014 with regards subjected to a public participation period of 30 to the time period allowed for complying with the requirements calendar days) and is been submitted to the

of the Regulations. DMR for consideration within legislated time period (i.e. within 106 days of acceptance of the Scoping Report – 18 October 2019) Please ensure that the EIAR includes the A3 size locality maps of the area and illustrates the exact location of the proposed development. The maps must be of acceptable quality and as a minimum, have the following attributes: A3 size locality maps and vegetation maps of the Refer to Appendix • Maps relatable to one another; area have been included in the EIAR. 22 • Co-ordinates; • Legible legends; • Scale of not smaller than 1:50 000; and • Vegetation types of the study area. Further, it must be reiterated that, should an application for EA A WULA is required and a pre-application be subjected to any permits or authorisations in terms of the enquiry has been submitted to the DWS. Proof Refer to Appendix 3. provisions of any Specific Environmental Management Acts, of submission is included in the EIAR. proof of such application will be required. You are hereby requested to submit 2 copies and one electronic copy through SAMRAD, of an EIR, inclusive of any specialist reports and an EMPr, which has been subjected to This is the final EIAR /EMPr (which has been the PPP of at least 30 days incorporating comments received, subjected to a public participation period of 30

including all comments from the CA. Kindly refer to section calendar days) and which is been submitted to 24N(2) of the NEMA and Appendix 2, 4 and 6 of the NEMA the DMR. EIA Regulation, 2014 for the minimum requirements set out for the aforementioned reports. The PPP should be conducted as stipulated in chapter 6 of the Refer to Section EIA Regulations, 2014 and taking into consideration any Public participation was conducted in terms 3.g.ii – 3.g.iii of the guideline applicable for public participation. Chapter 6 of the NEMA EIA Regulations, 2014. EIAR - Part A of this document.

ERPM Ext 2 Mine, East Rand, Gauteng 210 Environmental Impact Assessment Report and Environmental Management Programme For ERPM Extension Area 1 (Pty) Ltd, October 2019

2) UNDERTAKING

The EAP herewith confirms a) the correctness of the information provided in the reports X b) the inclusion of comments and inputs from stakeholders and I&APs ; X c) the inclusion of inputs and recommendations from the specialist reports where relevant; X and d) the acceptability of the project in relation to the finding of the assessment and level of mitigation proposed; X

Signature of the environmental assessment practitioner

18/10/2019 Date

3) UNDERTAKING UNDER OATH/ AFFIRMATION

I, Gené Main, swear under oath / affirm that all the information submitted or to be submitted for the purposes of this EIAR and EMPr is true and correct.

Signature of the environmental assessment practitioner

Prime Resources (Pty) Ltd Name of company

18/10/2019 Date

-END-

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