Railway line relocation at Pit 37E, Anglo American ...

Railway line relocation at Pit 37E, Anglo American Platinum Amandelbult Complex, Limpopo Province

Final Basic Assessment Report

Anglo American Platinum (Pty) Ltd

16 February 2017

Revision: 4

Reference: 112544

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Document control

Report title Final Basic Assessment Report

Document ID Project number 112544

File path P:\Projects\112544 EIA for Amandelbult Mine Opencast\03 PRJ Del\6 REP\10. BA for Open Pit 37E\2. BAR & EMPr\109888 FBAR & EMPr 17.02.13_rev 4.docx

Client Anglo American Platinum (Pty) Ltd

Client contact Dustin van Helsdingen Client reference Pit 37E BAR

Rev Date Revision details/status Author Reviewer Verifier (if required)

Approver

3 9 December 2016 Draft BAR for public review LH RH RH

4 13 February 2017 Final BAR LH RH RH

5 16 February 2017 Final Bar for submission to DMR LH RH RH

Current revision 5

Approval

Author signature

Approver signature

Name Lynette Herbst Name Reuben Heydenrych

Title Environmental Consultant Title EAP

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BASIC ASSESSMENT REPORT

AND

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

SUBMITTED FOR ENVIRONMENTAL AUTHORISATIONS IN TERMS OF 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 MINERAL AND

PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).

NAME OF APPLICANT: Anglo American Platinum (Pty) Ltd

TEL NO: 014 784 1001

CELL NO: 083 295 6524

POSTAL ADDRESS: PO Box 02, Chromite, 0362

PHYSICAL ADDRESS: Rustenburg Platinum Mines Limited, Amandelbult Section, Tumela Mine,

Thabazimbi

FILE REFERENCE NUMBER SAMRAD: LPNEMA0048MR

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TABLE OF CONTENTS

SECTION CONTENT

1 IMPORTANT NOTICE

2 OBJECTIVES OF THE BASIC ASSESSMENT PROCESS

PART A

3 SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT

3.1 Contact Person and correspondence address

3.2 Location of the overall activity

3.3 Locality map

3.4 Description of the Scope of the proposed overall activity

3.5 Policy and Legislative Context

3.6 Need and desirability of the proposed activities

3.7 Motivation of the overall preferred site, activities and technology alternative

3.8 Full description of the process followed to reach the proposed referred alternatives within the site

3.9 Details of the Public Participation Process followed

3.10 The Environmental Attributes associated with the alternatives

3.11 Impacts and risk identified including the nature, significance consequence, extent, duration and probability of the impacts, including degree to which these impacts

3.12 Methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks

3.13 Assessment of each identified potentially significant impact and risk

3.14 Summary of specialist reports

3.15 Environmental impact statement

3.16 Proposed management impact objectives and the impact management outcomes for inclusion in the EMPr

3.17 Aspects for inclusion as conditions of authorisation

3.18 Description of any assumptions, uncertainties and gaps in knowledge

3.19 Reasoned option as to whether the proposed activity should or should not be authorized

3.20 Period for which the Environmental authorization is required

3.21 Undertaking

3.22 Financial Provision

3.23 Specific information may be required by the competent authority

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3.24 Other matters required in terms of section 24(4) (a) and (b) of the Act.

PART B

4 ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

4.1 Draft Environmental Management Programme

4.2 Impact management outcomes

4.3 Impact management actions

4.4 Financial Provision

4.5 Indicate the frequency of the submission of the performance assessment or environmental audit report.

4.6 Environmental awareness plan

4.7 Specific information required by the Competent Authority

5 UNDERTAKING

LIST OF APPENDICES

Appendix 1 EAP Qualifications and Curriculum Vitae Appendix 2 Locality and Sensitivity Maps Appendix 3 Site Plan Appendix 4 Record of PPP Appendix 5 Impact Assessments Appendix 6 Correspondence with DMR Appendix 7 Specialist Reports

LIST OF FIGURES

Figure 1 | Locality of the project site relative to the closest town (Thabazimbi), the extent of the mining right, and the affected farms, Elandskuil and

Middellaagte. .................................................................................................................................................................................................................. 10 Figure 2 | Location of the proposed railway line relocation ............................................................................................................................................. 11 Figure 3 | Location of proposed railway and pipeline diversion, relative to Pit 37E. ....................................................................................................... 12 Figure 4 | Critical Biodiversity and Ecological Support Areas in the vicinity of Pit 37E and the railway to the north thereof .......................................... 19 Figure 5 | Waterberg District Environmental Management Framework: Environmental Management Zones, showing the general project location

(Waterberg District Municipality 2010) ............................................................................................................................................................................ 21 Figure 6 | Thabazimbi Environmental Management Zones, showing the general project location (Waterberg District Municipality 2010) .................... 21 Figure 7 | Project location according to the Mining and Biodiversity Guidelines (Department of Environmental Affairs, et al. 2013). ........................... 22 Figure 8 | Topographic map 2427 CD of the 1980s. ....................................................................................................................................................... 25 Figure 9 | Land cover and land use of the Thabazimbi Local Municipality ..................................................................................................................... 29 Figure 10 | Mining within the Waterberg Spatial Development Framework, indicating the general project location within an active mining area (WSDF,

2009)............................................................................................................................................................................................................................... 30 Figure 11 | View of the water and compressed air lines in the site at a road crossing, looking east .............................................................................. 30 Figure 12 | View of the water and compressed air lines in the site at a road crossing, looking west ............................................................................. 31 Figure 13 | Panoramic view of the site, looking south, from near the entrance to the site ............................................................................................. 32 Figure 14 | Panoramic view of the site, looking south, from its north-eastern corner ..................................................................................................... 32 Figure 15 | Panoramic view of the site along the railway line in the north-western portion of the site, looking north-west ............................................ 33 Figure 16 | Panoramic view of the site along the railway line in the north-western portion of the site, looking north-east ............................................. 33

LIST OF TABLES Table 1 | Summary of the PPP undertaken to date ........................................................................................................................................................ 15

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Table 2 | Waterberg District EMF requirements and project applicability ....................................................................................................................... 20 Table 3 | Gender and age distribution for Thabazimbi Local Municipality (StatsSA, 2011) ............................................................................................ 26 Table 4 | Languages spoken by the population in Thabazimbi Local Municipality (StatsSA, 2011) ............................................................................... 26 Table 5 | Education level of the population in Thabazimbi Local Municipality (StatsSA, 2011) ...................................................................................... 27 Table 6 | Employment status of the working age population in the Thabazimbi Local Municipality (StatsSA, 2011) ..................................................... 27 Table 7 | Annual income distribution of households within the Thabazimbi Local Municipality (StatsSA, 2011) ............................................................ 27 Table 8 | Living conditions details for the Thabazimbi Local Municipality (StatsSA, 2011) ............................................................................................ 28 Table 9 | Construction phase impacts before mitigation ................................................................................................................................................. 34 Table 10 | Construction phase impacts after mitigation .................................................................................................................................................. 35 Table 11 | Operational phase impacts before mitigation ................................................................................................................................................ 36 Table 12 | Operational phase impacts after mitigation ................................................................................................................................................... 36 Table 13 | Decommissioning phase impacts before mitigation ....................................................................................................................................... 37 Table 14 | Decommissioning phase impacts after mitigation .......................................................................................................................................... 37 Table 15 | Positive and negative impacts that the proposed railway line relocation and extension may have on the environment and communities

potentially affected .......................................................................................................................................................................................................... 40

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1) IMPORTANT NOTICE

In terms of the Mineral Petroleum Resources Development (Act 28 of 2002 as amended), the minister must grant a

prospecting or mining right if among others the mining “will not result in unacceptable pollution, ecological degradation or

damage to the environment.”

Unless an Environmental Authorisation can be granted following the evaluation of an Environmental Impact Assessment

and an Environmental Management Programme report in terms of the National Environmental Management Act (Act 107

of 1998) (NEMA), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological

degradation or damage to the environment.

In terms of section 16(3) (b) of the EIA Regulations, 2014, any report submitted as part of an application must be prepared

in a format that may be determined by the Competent Authority and in terms of section 17 (1) (c) the competent Authority

must check whether the application has taken into account any minimum requirements applicable or instructions or guidance

provided by the competent Authority to the submission of applications.

It is therefore an instruction that the prescribed reports required in respect of applications for an environmental

authorisation for listed activities triggered by an application for a right or 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 Environmental Authorisation being refused.

It is furthermore an instruction that the Environmental Assessment Practitioner must process and interpret his/her

research and analysis and use the findings thereof to compile the information required herein. (Unprocessed supporting

information may be attached as appendices). The EAP must ensure that the information required is placed correctly in the

relevant sections of the Report, in the order, and under the provided headings as set out below, and ensure that the report

is not cluttered with un-interpreted information and that it unambiguously represents the interpretation of the applicant.

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2) OBJECTIVES OF THE BASIC ASSESSMENT PROCESS

The objectives of the assessment process is to, through a consultative process –

(a) determine the policy and legislative context within which the proposed activity is located and how the activity complies

with and response to the policy and legislative context;

(b) identify the alternatives considered, including the activity, location, and technology alternatives;

(c) describe the need and desirability of the proposed alternatives,

(d) through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which focused on

determining the geographical, physical, biological, social, economic, heritage, and cultural sensitivity of the sites and

locations within sites and the risk of impact of the proposed activity and technology alternatives on the these aspects to

determine:

(i) the nature, significance, consequence, extent, duration, and probability of the impacts occurring to; and

(ii) the degree to which these impacts –

(aa) can be reversed;

(bb) may cause irreplaceable loss of resources; and

(cc) can be managed, avoided or mitigated;

(e) through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will impose on

the sites and location identified through the life of the activity to –

(i) identify and motivate a preferred site, activity and technology alternative;

(ii) identify suitable measures to manage, avoid or mitigate identified impacts; and

(iii) identify residual risks that need to be managed and monitored.

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PART A

SCOPE OF ASSESSMENT AND BASIC ASSESSMENT REPORT

3 Contact Person and correspondence address

a) Details of the EAP

i) Details of the EAP

Name of the Practitioner: Reuben Heydenrych

Tel No.: 012 427 2134

Fax No. : 086 556 0521

E-mail address: [email protected]

ii) Expertise of the EAP

(1) The qualifications of the EAP

(with evidence)

Please Refer to Appendix 1.

(2) Summary of EAP’s past experience

(In carrying out the Environmental Impact Assessment Procedure)

Please Refer to Appendix 1.

b) Location of the overall Activity

Farm Name Portion 0 of the farm Middellaagte 382 KQ Portion 1 of the farm Elandskuil 378 KQ

Application area (Ha) Approximately 0.7 hectares

Magisterial District Thabazimbi Local Municipality and Waterberg District Municipality

Distance and Direction from nearest Town The proposed project site is located approximately 17.5 km south-southwest of

Thabazimbi.

21 Digit Surveyor General code for each farm

Portion

T0KQ00000000038200000 T0KQ00000000037800001

c) Locality Map

(Show nearest town, scale not smaller than 1:250000)

Please refer to Figure 1 and Appendix 2 for a locality map. The proposed project site is located approximately 17.5 km south-southwest of Thabazimbi, and 23.5 km northeast of Northam. The R510 is located approximately 3.6 km west, and the R511 approximately 7 km east of the project site. The proposed activity will take place on the Amandelbult Mining Right area. The area around the proposed site is dominated by mining activities. The coordinates of where the proposed activity will take place:

Number of corner Latitude Longitude

Starting point 24° 45' 2.49" 27° 21' 58.65"

Turning point 24° 45' 23.9" 27° 21' 35.67"

End point 24° 45’ 33.3” 27° 21’ 35.45”

mailto:[email protected]

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Figure 1 | Locality of the project site relative to the closest town (Thabazimbi), the extent of the mining right, and the affected farms, Elandskuil and Middellaagte.

d) Description of the scope of the proposed overall activity

Provide a plan drawn to scale acceptable to the competent Authority but not less than 1: 10 000 that shows the location, area

(hectares) of all the aforesaid main and listed activities, and infrastructure to be placed on site.

Please refer to Appendix 2 and Figure 2.

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Figure 2 | Location of the proposed railway line relocation

(i) Listed and specified activities

NAME OF ACTIVITY

(E.g. For prospecting - drill site, site camp, ablution facility,

accommodation, equipment storage, sample storage, site

office, access route etc…etc…etc

E.g. for mining,- excavations, blasting, stockpiles, discard

dumps or dams, Loading, hauling and transport, Water

supply dams and boreholes, accommodation, offices,

ablution, stores, workshops, processing plant, storm water

control, berms, roads, pipelines, power lines, conveyors,

etc…etc…etc.)

AERIAL EXTENT OF THE ACTIVITY

Ha or m2

LISTED ACTIVITY

Mark with an X where applicable or affected

APPICABLE LISTING NOTICE

(GNR 983, 984 or

985)

The proposed railway line will be relocated approximately 100 m to

the north of its current location, and will be lengthened by 52 m. The

footprint expansion, considering the railway line width of 5.5 m,

would be 286 m2.

286 m2 X Activity 64 of GN R

983 of 2014

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(ii) Description of the activities to be undertaken

(Describe Methodology or technology to be employed, including the type of commodity to be prospected/mined and for a linear activity, a description of the route activity)

The Anglo American Platinum (Pty) Ltd Amandelbult Complex (henceforth referred to as Anglo) has existing Mining Rights, initially granted in 1997

under the then Minerals Act, 1991 (Act No. 50 of 1991). This Act was replaced by the Minerals and Petroleum Resources Development Act, 2002

(Act No. 28 of 2002) [MPRDA]. The Environmental Management Programmes (EMPrs) that were approved in 1997 remained valid under the

MPRDA, and now continue to remain valid under the “One Environmental Management System” 1 in terms of the National Environmental

Management Act (Act No. 107 of 1998).

Anglo intends to start mining its so-called Pit 37E in 2017. This pit forms a portion of the authorised mining complex, in an area straddling portions

of both the Elandskuil and Middellaagte farms. The entire extent of both these farms have been authorised for mining under the approved EMPrs.

In order to mine Pit 37E, existing mining infrastructure (an Anglo railway line, a compressed air pipeline, and a water pipeline) needs to be relocated.

Anglo’s railway line, which serves mining areas east of the site, bisects the area near its northern boundary, and curves to the south near the area’s

western boundary. The area is also traversed by a water and compressed air line, of 200mm and 600mm diameter respectively, which run adjacent

to each other in a WSW to ENE direction through the site.

The north-western corner of the proposed open pit mining area is affected by the alignment of the water and compressed air pipelines and the

railway line. Therefore, it is proposed to move all these lines to the north, to the boundary of the proposed pit (close to the existing road) to enable

optimal extraction of the available ore body. The resulting relocation of the railway line will move it a maximum of approximately 100m to the north,

add an extra 52m to its length and increase its footprint by 286m2.

No increases in capacity of the existing pipelines or railway line are proposed. It is only their routes that are proposed to be changed, as indicated

in Figure 3.

Figure 3 | Location of proposed railway and pipeline diversion, relative to Pit 37E.

The increase in the footprint the railway line requires environmental authorisation.

1 Put in place through the Environmental Impact Assessment Regulations, 2014 (Government Notices No. 982 – 985 of 2014)

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e) Policy and Legislative Context

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT

(a description of the policy and legislative context within which the development is proposed including an identification of all legislation, policies, plan, guidelines, spatial tools, Municipal development planning frameworks instruments that are applicable to this activity and are to be considered in the assessment process)

REFERENCE WHERE APPLIED HOW DOES THIS DEVELOPMENT COMPLY WITH AND RESPOND TO LEGISLATION AND POLICY CONTEXT

(E.g. In terms of the National Water Act a Water use license has/has not been applied for)

NEMA EIA Regulations 2014 BAR and EMPR This BAR and EMPr were compiled in terms of the

NEMA EIA Regulations 2014. The applicable

requirements of the EIA Regulations 2014 were

adhered to during the compilation of this report.

Guideline on Public Participation

(March 2013)

BAR The public participation guideline was consulted to

ensure that an adequate public participation process is

undertaken.

Guideline on Alternatives (March

2013)

BAR and EMPR This guideline was consulted to inform the consideration

of alternatives.

Guideline on Need and Desirability

(March 2013)

BAR and EMPR This guideline was consulted to inform need and

desirability aspects of the proposed project.

National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA)

Heritage Impact Assessment as an appendix to the BAR

As required by Sections 39(1) and 38(8) of the NHRA, a Heritage Impact Assessment has been undertaken for the proposed increased length of the railway line, which is classified as a linear development under Section 38(1) of the NHRA.

Limpopo Conservation Plan (CPlan) V2 of 2013

Baseline Environment section, describing the type of environment affected by the proposed activity

The development area does not fall within any environmentally sensitive areas (e.g. Critical Biodiversity Areas or Ecological Support Areas) according to the Limpopo CPlan.

Environmental Management Framework for the Waterberg District


The proposed project falls within Zone 4 of the Waterberg District EMF, a Mining Focus Area.

Mining and Biodiversity Guidelines (MBG)


The proposed project falls within an area of Highest Biodiversity Importance according to the MBG. An ecological specialist study was conducted as a groundtruthing exercise. It had confirmed that the project area holds little biodiversity value.

Thabazimbi Spatial Development Framework

Baseline Environment section, providing a description of the current land uses

The project will be located within an area that is established as a mining area, posing no threat to urbanisation or other economically valuable spatial developments, such as farming.

Waterberg Spatial Development Framework

Baseline Environment section, providing a description of the current land uses

The project will be located within an area that is established as a mining area.

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(i) 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)

Opencast mining opportunities for potential short-term mining of shallow Platinum Group Elements (PGE) exist at Anglo’s Amandelbult Complex. In light of this, PGE-containing UG2 and MR reef remnants will be economically extracted through the so-called Pit 37E.

The proposed mining activities will provide economically extracted PGEs while commodity prices are low. Relocating the railway line, which runs through the proposed pit area, will enable Anglo to take advantage of the opportunity to extract reef remnants in Pit 37E.

The mining sector is a major contributor to the South African economy. The expansion of opencast operations to extract resources at a relatively low cost would contribute to the security of employment for Anglo Platinum mine workers. The subcontractor undertaking proposed mining activities will be determined upon project finalisation, which will unlock local procurement and employment opportunities.

The relocation and expansion of the railway line a few metres to the north of Pit 37 will ensure that it can continue to serve areas to the east of the

site, as it currently does.

(ii) Motivation of the overall preferred site, activities and technology alternative

The site is an isolated greenfields site within the existing Amandelbult mining complex (see Figure 1). The pit’s location has been determined based on the extensive geological testing of where the reef can be mined. The pit location, and therefore the railway location, is restricted to the ore body location.

The existing Anglo American Platinum Amandelbult railway line bisects the area near the northern boundary of the pit area, and curves to the south near the area’s western boundary. It is proposed to move the railway line to the north of its current location, so as to have the smallest possible impact on the surrounding area.

The resulting relocation of the railway line will move it a maximum of approximately 100m to the north, add an extra 52m to its length and 286m2 to its footprint. The other alternatives considered, such as rerouting the railway line to the south of the pit, will result in a far larger addition to its length and associated construction footprints.

(iii) Full description of the process followed to reach the proposed preferred alternatives within the 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 issue raised by interested and affected parties, and the consideration of alternatives to the initially proposed site layout.

(i) Details of the development footprints alternatives considered

With reference to the site plan provided as Appendix 2 and the location of the individual activities on site, provide details of

alternatives considered with respect to:

(a) the property on which or location where it is proposed to undertake the activity;

(b) the type of activity to be undertaken;

(c) the design or layout of the activity;

(d) the technology to be used in the activity;

(e) the operational expects of the activity; and

(f) the option of not implementing the activity.

Alternatives

Three project layout alternatives were considered:

1) The relocation of the railway to approximately 100 m north of the pit, resulting in an extension of the current line by approximately 52 m.

2) Substantially reducing the size of Pit 37E to allow the railway to remain in its current location.

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3) The relocation of the railway line to the south of the pit.

4) The option of not implementing the activity (“No-go alternative”). This alternative will entail leaving the rail in its current location and abandoning

the Pit 37E project altogether.

Alternative 1 is preferred.

Motivation

In the case of Alternative 2, the reduction of Pit 37E will result in a very small amount of ore material that could be extracted from the smaller pit.

The amount of PGE-ounces that could then be extracted would not outweigh the cost of extracting and processing the minerals, as it would in the

case of Alternative 1. This could contribute to the contraction of mining operations at the Amandelbult Complex, with various negative indirect

socio-economic impacts, such as job losses.

Alternative 3 is not a feasible option, since the wide horizontal curves requires for a railway line would not make it possible to keep the railway line

outside the proposed open pit area. In other words, the railway line would continue to bisect the open pit area. This would result in a larger footprint,

potentially causing greater environmental impacts as a larger area would be occupied, driven over, and cleared of vegetation during construction.

This would have the same effect as the Alternative 2 – to reduce the size of Pit 37E.

In the case of Alternative 4, the “No-Go alternative”, neither infrastructure relocation, nor mining of Pit 37E would take place. The impacts of this

alternative are similar to the reduction in size of Pit 37E.

(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.

Consultation with the public forms an integral component of the environmental authorisation process. This process enables I&APs (e.g. directly

affected landowners, national-, provincial- and local authorities, and local communities), to raise issues and concerns regarding the proposed

activities, which they feel should be addressed in the EIA process. The Public Participation Process (PPP) has thus been structured to provide

I&APs with an opportunity to gain more knowledge about the proposed project, to provide input through the review of documents/reports, and to

voice any issues or concerns at various stages throughout the BA process.

The objectives of public participation are to provide information to the public, identify key issues and concerns at an early stage, respond to the

issues and concerns raised, provide a review opportunity, and to document the process properly. The PPP has been managed to meet these

objectives throughout the BA. The approach followed for the PPP is according to Chapter 6 of the EIA Regulations, 2014 published in Government

Notice No. 982 of 4 December 2014. The PPP conducted to date is summarised in Table 1:

Table 1 | Summary of the PPP undertaken to date

Task Details Date

I&AP notification (relevant authorities and I&APs)

I&AP identification An I&AP database was developed for the project by establishing the jurisdiction of organisations,

individuals and businesses in proximity to the project site or with an interest in the proposed

development. The database of I&APs includes the landowner, the adjacent landowners, relevant district

and local municipal officials, relevant national and provincial government officials, and organisations.

This database was updated as new I&APs were identified throughout the BA lifecycle. The list of I&APs

is attached in Appendix 4.

November

2016 –

January 2017

Written notification All identified I&APs were notified of the proposed railway relocation via emails and registered mail.

Copies of these notification letters and transmittal proofs are attached in Appendix 4.

November

2016

16

Site notices Site notices of 600 mm x 420 mm in size were put up to inform the general public of the proposed project

and the PPP. Photos of the site notices are included in Appendix 4. Site notices were placed at:

Northam Shoprite Centre;

Tumela training Centre;

On site; and

Setaria Spar.

January

2017

Consultation (Draft)

Basic Assessment

Report

Copies of the CBAR were made available at:

Northam Post Office;

Tumela Main Office; and

Setaria Spar.

January

2017

Media adverts The proposed project was advertised in a local newspaper, the Platinum Bushvelder (in English and

Setswana), to indicate the availability of the CBAR for public perusal and comment.

January

2017

Comments received Comments received from I&APs were included and responded to in the table included in Section (iii) on

page 17. Concerns from I&APs were given due consideration during the finalisation of the Basic

Assessment Report. A Comments and Response Report is included in Appendix 4.

January –

February

2017

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(iii) Summary of issues raised by I &APs

(Complete the table summarising comments and issues raised, and reaction to those responses)

Interested and Affected Parties List the names of persons consulted in this column, and mark with an X where those who must be consulted were in fact consulted

Date Comments Received

Issues Raised EAP’s Response to issues as mandated by the applicant

Section and paragraph reference in this report where the issues and or response were incorporated

AFFECTED PARTIES

Landowner/s X

Lawful occupier/s of the land Not applicable.

Landowners or Lawful occupiers on adjacent properties

X

Municipal Councillor X

Municipality X

Organs of state (responsible for infrastructure that may be affected Roads Department, Eskom, Telkom, DWA)

X 1 February 2017

This office acknowledges the receipt of your application documents regards to the above-mentioned on 30 January 2017 (T35/2017). The office responsible for this area is: Ms Lethabo Ramashala and can be contacted at (012) 253-1026.

Comments would be forwarded in due time.

Noted. No further comments were received from the DWS.

Communities Not applicable, as the project is located within the Amandelbult Mining Complex.

Dept. Land Affairs Not applicable.

Traditional Leaders X

Limpopo Department of Economic Development, Environment and Tourism (LEDET)

X 27 January 2017

The Department has reviewed the content of the Basic Assessment Report in respect of the subject matter, received by the Department on 13 January 2017 and submits the following; The following tools must be considered during the processing of this application:

The Limpopo Conservation Plan of 2013;

The Environmental Management Framework for the Waterberg District;

The Mining and Biodiversity Guidelines;

The Thabazimbi Spatial Development Framework; and

The Waterberg Spatial Development Framework. Please note that in terms of section 24F (1) of the NEMA and notwithstanding the provisions of any other Act; "no person may commence an activity listed in terms of section 24(2) (a) or (b) unless the competent authority has granted an environmental authorization for the activity, and no person may continue an existing activity listed in terms of section 24(2) (d) if an application for an environmental authorisation is refused".

The issues raised by the LEDET are addressed in the final BAR through the discussion of the project impact in the context of the tools required to be considered. Note that the Limpopo Conservation Plan had been considered in the draft BAR.

Baseline Environment Section, describing the Type of environment affected by the proposed activity and providing a Description of the current land uses, Section (1)(a) and (b), page 18 and 29.

Other Competent Authorities affected

Not applicable.

OTHER AFFECTED PARTIES Not applicable.

INTERESTED PARTIES Not applicable.

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(iv) The Environmental Attributes associated with the 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 heritage character).

Please note that the majority of the following descriptions of the environment affected by the proposed activity was extracted from the consolidated

EMPr, which covers the entire Amandelbult Mining Complex in November 2013 (Prime Resources 2013). The biodiversity and heritage components

were extracted from dedicated specialist studies, which focus on this project site.

Climate

The climate is semi-arid and hot in the Limpopo- and Olifants River basins, but cooler with a higher humidity on the Waterberg plateau and

Soutpansberg. Temperatures in the Thabazimbi region are generally warm to hot in the summer months. The highest temperatures occur in

December and January, while winter months are characterised by lower temperatures. The lowest minimum temperature recorded was -0.1°C in

July 1993. The highest rainfall occurs from November to March. Rainfall is generally low between May and September. The majority of the rainfall

occurs as thunderstorms and heavy showers, sometimes accompanied by hail. The mean annual evaporation at Thabazimbi is 2017 mm, which

exceeds the mean annual rainfall of 600mm. The area is prone to extreme weather events, such as droughts and floods. Winds are light to

moderate and are predominantly in a north-westerly direction during the summer months, with westerly winds occurring frequently in the winter.

Topography

The overall elevation decreases in an easterly direction from 980 m above mean sea level (mamsl) in the south-western boundary of the site to 920

mamsl in the north-east. The area is relatively flat, dipping gently to the east.

Geology

The project area is primarily underlain by the Bushveld Igneous Complex (BIC), one of the largest layered mafic intrusions in the world. The BIC is

a world-class repository for a number of ore bodies, yielding a range of mineral commodities including chrome, vanadium, titaniferous magnetite

and PGEs. The complex extends approximately 350 km east to the west and 250 km north to the south. The complex is saucer-shaped, with the

edges dipping inwards towards the centre. At the rim of the ‘saucer’, pyroxenites, norites, gabbros and Chromitites are found interlayered in a

variety of combinations. Unique to the BIC is the presence of two stratiform deposits, known as the Merensky Reef and the UG2 Reef, containing

economically exploitable PGE-quantities. These reefs serve as the primary source of PGE reserves exploited by Anglo. Apart from the platinum-

bearing Merensky and UG2 Reefs, the area’s geology consists of gabbro, norite and pyroxenite rocks of the BIC.

The majority of the surface exposures are covered by either weathered norites, or black turf. The ore bodies dip towards the southeast. The dip

of the ore bodies varies between 18º towards the south west of the property to 22º towards the northeast. The Merensky Reef comprises feldspathic

pegmatoidal pyroxenite, bounded by thin Chromitite bands. The reef thickness varies from 10 cm to 300 cm. The UG2 Chromitite, which underlies

the Merensky Reef by 35 m to 50 m, is 150 cm wide. Faults of various sizes occur throughout the mining right area, and include major north-west

trending faults with associated throws of up to 500 m.

Biodiversity

Tembele Ecological Services (undated) compiled an ecological assessment of the proposed Pit 37E area, attached as Appendix 7, to confirm

whether there could be any faunal or floral species of conservation concern (SCC) in the affected area (Tembele Ecological Services 2016). The

study was based on published data and a field survey.

The key findings of this assessment are as follows:

The proposed site fall within the Dwaalboom Thornveld, which has a Least Threatened status. It is described as semi-arid plains with a layer of

scattered, low to medium-sized deciduous microphyllous trees and shrubs, with a few broad-leaved tree species and an almost continuous

herbaceous layer dominated by grass species. The substrate is dominated by heavy, vertic, black clay soils developed from norite and gabbro.

The site is reasonably homogenous, with thorn tree species, including Umbrella–thorn Vachellia tortilis, Scented-thorn Vachellia nilotica and

Black-thorn Senegalia mellifera dominating the tree and shrub layer. Buffalo Thorn Ziziphus mucronata and Velvet Raisin Grewia flava were

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also recorded throughout the site, in small numbers. ‘Turf-loving’ grasses such as Setaria incrassata and Bothriochloa radicans were commonly

found on the site. In low-lying areas and depressions dense stands of Sorghum halepense occur.

Two protected tree species, namely Camel Thorn Vachellia erioloba and Leadwood Combretum imberbe may occur in the region of the proposed

site. However, neither of these species were found to occur on the site.

No provincially protected or red-data listed plant species were recorded or are expected to occur within or adjacent to the proposed site.

During the field survey 56 bird species were identified within the study site and its immediate surrounds. Two Yellow-throated Sandgrouse

Pterocles gutturalis were seen flying over the site in an easterly direction. This species is listed as ‘Near-threatened’ in the Red Data book of

birds of South Africa (Taylor, et al., 2015). Yellow-throated Sandgrouse forage in open patches in turf soil areas and drink daily from water bodies

with open shorelines. Within the study area very little suitable foraging or breeding habitat exists and no appropriate ‘drinking waterholes’ are

present. The birds observed during the survey were in all probability en route to a dam some 5km south-east of the site.

A significant portion of the site forms part of a game camp, thus several large mammal species occur on the site. No small mammals were

recorded on the site. It is unlikely that any protected or red-data mammal species would occur on the site.

Due to the dry conditions and the lack of any surface water, no frog species were recorded during the field survey. The site does not hold any

permanent surface water, nor does it possess any significant depressions where water can collect during the wet season.

The conclusion of the ecological study is that the site has a low conservation index, as the natural aspect has been severely altered due to the

presence of mining-related infrastructure and mining activities in the past. No plant or vertebrate species of conservation importance, with the

exception of the ‘near-threatened’ Yellow-throated Sandgrouse (seen flying over the site), were found on the site. This species is not expected to

utilise the site for foraging or breeding.

Furthermore, as shown in Figure 4, the proposed project site does not fall within Critical Biodiversity Areas or Ecological Support Areas as defined

in the Limpopo Conservation Plan (Limpopo CPlan 2013).

Figure 4 | Critical Biodiversity and Ecological Support Areas in the vicinity of Pit 37E and the railway to the north thereof

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Environmental Management Framework for the Waterberg District

According to the Waterberg District Environmental Management Framework of 2010, the proposed project area falls within Zone 4: Mining Focus

Areas (Waterberg District Municipality 2010). The desired state, preferred, compatible and undesired developments in Zone 4, together with its

applicability to the proposed project, are discussed in Table 2. The Environmental Management Zones of the Waterberg District are shown in Figure

5 and in Figure 6 for the Thabazimbi region, where the project is proposed.

Table 2 | Waterberg District EMF requirements and project applicability

Waterberg District EMF requirement or recommendation Applicability to proposed project

Desired state

The correct permits are to be in place for water utilisation. No water will be utilised during the rail relocation.

Water quality should not deteriorate as a result of large scale water utilisation for industrial purposes.

No waterbodies are located in the vicinity of the project. Minimal effluent from, for instance, chemical toilets used during the construction phase, will be processed in the existing mining effluent treatment facilities.

Threatened species occurring in the area should be protected. No threatened species were found to occur in the project area.

No agriculture or business and retail activities should take place in this area.

No agriculture or commercial activities will take place as part of this project.

Game farming take place where mining in this zone is not actively carried out.

Game farms in the greater area will not affect this project.

Service infrastructure, in particular, transport infrastructure should be able to support mining activities.

The railway line that is to be located will continue to support current mining activities at the Amandelbult Mining Complex.

Waste should be disposed of legally and recycling encouraged in this area.

Waste will be disposed of as part of existing, authorised waste management and recycling processes at the mine.

Sewage treatment and disposal should not deteriorate the quality of waterbodies in the area.

Minimal effluent from, for instance, chemical toilets used during the construction phase, will be processed in the existing mining effluent treatment facilities.

Employment of local unemployed people is encouraged. During the construction phase, where possible, local unemployed job seekers may be employed. It must be noted that the rail relocation itself will be of short duration, and that the mining off Pit 37E should rather be considered as a potential source of short-term employment.

Housing in the area should be concentrated in urban areas where various basic service provision is established.

No housing will be established in the project area.

Preferred, compatible and undesired activities

The mining of minerals, industrial activities associated with mining, and roads and railway infrastructure for mineral transportation are preferred activities in this area.

The relocation of the railway line will enable the mining of PGE-minerals in Pit 37E.

Existing farming activities, commercial game and/or cattle-keeping, and tourism facilities are compatible with desired mining in this zone where mining is not possible.

Game farms and/or cattle keeping in the greater area will not affect this project.

Any activities inhibiting mining activities in this area is undesired. The no-go alternative, i.e. no relocation of the railway line, will result in an activity inhibiting mining activities in this area.

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Figure 5 | Waterberg District Environmental Management Framework: Environmental Management Zones, showing the general project location (Waterberg District Municipality 2010)

Figure 6 | Thabazimbi Environmental Management Zones, showing the general project location (Waterberg District Municipality 2010)

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Mining and Biodiversity Guidelines

The majority of the project area is located within an area of Highest Biodiversity Importance according to the Mining and Biodiversity Guidelines

(MBG) ( (Department of Environmental Affairs, et al. 2013)). See Figure 7 below.

Figure 7 | Project location according to the Mining and Biodiversity Guidelines (Department of Environmental Affairs, et al. 2013).

Wetlands

No natural wetlands have been identified on the site according to the DWAF Wetland Delineation Guidelines (2005).

Soil

The dominant soil form across the mine right area is the Arcadia Form, representative of the typical catena for the greater Rustenburg area. The

Arcadia Form occurs up to depths ranging from 0.8 to 1.5 m below ground level (BGL). The underlying geology undoubtedly controls the thickness

of the cover material. The Arcadia soil form is characterised by a deep (<1 m) Vertic A Horizon with a calcareous B Horizon lens, characteristic of

the Rustenburg region. The presence of hydrophilic, expansive 2:1 montmorillonite clay results in seasonal soil heave, hence the classification as

Vertic. The clayey soil is dark in colour and black when slightly moist to saturated, with a granular surface structure when dry. Desiccated material

forms deep, hexagonal desiccation cracks at the surface during the dry season which indicates the presence of these swelling clays. At depth, the

soil is increasingly firm and, when excessively dry or excessively moist, is impenetrable with a hand auger. Such soils usually develop slicken-

slides (movement planes) caused by regular seasonal heave. Soils are mostly clayey with limited silt and sand contents.

Chemical characteristics

The soil is characteristically high in macro-element nutrients (P, K, Ca and Mg). Macro elements are essential for plants to grow, and an abundance

of these nutrients may result in moderate to high fertility. The low exchangeable sodium potential (less than 2%) of the mine area indicates that the

soil is non-sodic implying high soil fertility and good soil structure. The soil is characterised by a high Cation Exchange Capacity (CEC) which (Na+,

23

K+, Mg2+, Ca2+ and Al3+). However, Al3+ is an aggressive, acid-forming cation common to the chemical composition of montmorillonitic clays. The

presence of Al3+ in the soil therefore results in a low reserve acidity. The pH of the soil is 6.8 to 6.9 which is within the necessary range for most

crops, including wheat, maize and vegetables.

Land capability (agricultural potential)

Despite the high fertility of the soil caused by high macro-nutrient concentrations, the Vertic A horizon has a high clay content (>40%). The extremely

hydrophilic nature of the clayey soil, increasing with depth, will likely compete with and overwhelm root absorption of soil moisture. Root penetration

into the soil is very low, and it is likely that moisture uptake is retarded by the stronger adsorption of moisture onto clay particle surfaces than root

absorption. The soil is non-saline and non-sodic, with low exchangeable sodium resulting in low erodibility. Erodibility is further reduced by

hydrophilic montmorillonite clay particles binding to one another. Despite low salinity, sodicity and erodibility, high soil moisture retention (poor

drainage) impacts negatively on overall agricultural potential.

The soil across the mining right area is considered to have a relatively high buffer capacity to industrial activities. Adverse chemical influences

imposed on the soils, such as irrigation with acidic or saline effluent, will thus be buffered to a certain degree and the soil would be considered

suitable for rehabilitation purposes.

Groundwater

Information on groundwater is obtained from the WSP groundwater report (2006) for the Amandelbult Complex. Note that no monitoring boreholes

are located around the proposed site, as no faults that could aid underground water flow are located in the area.

The geohydrological study conducted in 2006 by WSP, showed that during dry seasons, deep desiccation cracks in the montmorillonitic “black turf”

cover extend down to 1.5m below ground level. This may allow surface contamination to reach shallow, perched water tables during heavy rains

following a dry season and before the desiccated clays become hydrated. The hydrophilic nature of the clays may reduce surface infiltration during

wet months, possibly forming temporary, seasonally perched aquifers within the black turf horizon.

Under normal conditions, slow downward infiltration through the thick clayey cover should result in contaminant attenuation due to clay chemistry

(high buffer capacity). Therefore, groundwater moves slowly and receives limited recharge through the black clays associated with norite

weathering. The groundwater flow direction is predominantly from south to north across the mine right area, with an average seepage velocity

estimated between 0.1 and 20 m/annum. This implies that shallow groundwater may not migrate as far as deeper subsurface fissure flow. Recharge

to the groundwater regime is estimated at 3% of Mean Annual Precipitation (MAP) across the area and between 5 and 7 percent of MAP within the

drainage lines.

Due to the layered nature of the geology, less resistant rock units may undergo preferential weathering, resulting in increased vertical heterogeneity

and distinct and separate hydraulic zones. Although these structures may increase groundwater movement along their flanks, they generally do

not allow the lateral flow of groundwater. Thus, the groundwater regime of the mining right area is divided into four distinct sub-compartments.

However, where faults or shear zones cut across diabase intrusions, aquicludes can be locally connected.

Groundwater levels and quality

The groundwater levels within the Amandelbult Concentrator Plant Section at the Tailings Storage Facility (TSF) vary between 2 m and 45 meters

below ground level (mbgl). The depth to groundwater level in this area, is determined primarily by the type of aquifer and the hydraulic characteristics

of the water-bearing formations, and reflects piezometric levels in shallow and deep weathered and fractured hard bedrock aquifers. These aquifers

are comprised of weathered and fractured, layered pyroxenite, norite-anorthosite and gabbro-norite rocks (Tailings Dam Extension EMPR

Amendment, 2002).

Groundwater levels resemble the local topography, i.e. regional groundwater drainage takes place in a north-westerly, northerly and north-easterly

direction, although locally, drainage may take place towards surface drainage features. At least three different intrusions by dolerite dykes sub-

compartmentalise the study area, but they appear not to influence groundwater levels significantly i.e. the depth to groundwater level seems to be

almost the same from west to east. There appeared to be a significant groundwater mound beneath the TSF. Groundwater levels in proximity to

the TSF rise slowly due to continuous, albeit slow, seepage from the TSF (Tailings Dam Extension EMPR Amendment, 2002).

According to the approved 16W UG2 EMPR Amendment, 2004, background groundwater quality for the mining right area is generally poor. The

electrical conductivity (EC) of the groundwater varies between 127 mS/m and 264 mS/m and averages around 210 mS/m. The groundwater

contains excessive concentrations of calcium (156 mg/l), magnesium (152 mg/l), sodium (between 139 mg/l and 158 mg/l), chloride (351 mg/l to

456 mg/l), nitrate (between 34 mg/l and 42 mg/l) and sulphate (between 146 mg/l and 178 mg/l).

Surface water

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The proposed project area falls within the A24F catchment area, in which the Bierspruit River flows in a northerly direction to eventually meet the

Crocodile River far north of the mine right area.

According to 2016 annual surface water quality monitoring results, the average water quality profile is neutral to alkaline (Aquatico 2016). The average total dissolved solids (TDS) was very saline and the total hardness varied between very hard and extremely hard.

The average physical and chemical composition of several process water monitoring localities exceeded the target values specified in the Water Use Licence (WUL) Waste Water Discharge in terms of EC, Na, Cl and NO3 concentrations. The General Limit was exceeded by the average EC levels, NO3 and suspended solids (SS) Concentrations.

While qualities for process water may exceed, risk is low as water in maintained in a closed system and no individuals are expected to consume water directly.

The water quality of the receiving environment at Dishaba shaft was in general neutral, saline and hard.

The average physical and chemical composition of the receiving environment water quality exceeded the WUL Surface Water Resource limits in

terms of EC, Total Alkalinity, sodium adsorption ration (SAR), SS turbidity and Dissolved Oxygen (DO). Low impact on the Bierspruit was recorded.

Heritage

Information on heritage is obtained from the Heritage Impact Assessment (G&A Heritage 2016) undertaken for the project. The cultural landscape

in the study area is mostly associated with agricultural and mining activities. The project site is severely altered, making it impossible to comment

on the possible existence of sub-surface sites.

No sites of heritage significance were identified during the fieldwork investigation. Some stone heaps around the eastern end of the study area were initially thought to be possible graves. However, after further investigation, they were found to be material dumps associated with the railway line construction, since the materials are the same as those used on the railway and these do not occur naturally in the area.

Nevertheless, it is possible that burial grounds and grave sites exists, including:

Pre-colonial burials (marked or unmarked, known or unknown)

Historical graves (marked or unmarked, known or unknown)

Graves of victims of conflict

Human remains (older than 100 years)

Associated burial goods (older than 100 years)

Burial architecture (older than 60 years)

A 1980s Surveyor General 1:50 000 topographic map set was found during the archival study. The map shows that the railway line in question was being constructed at the time. This means that the railway line itself is not old enough to be protected under the NHRA and, therefore, can be altered at will.

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Figure 8 | Topographic map 2427 CD of the 1980s.

Air quality

The mining right area is inherently dry and has high evaporation rates. Therefore, environmental dust is an inherent property of the natural

environment, even without anthropogenic influences such as mining and transport activities. There are currently 11 dust fallout monitoring sites

across the Tumela and Dishaba Mines, the Amandelbult Concentrator Plant and the services supporting each of the aforementioned sections. Nine

of the sites are classified as industrial and two of the sites are classified as residential. All monitoring sites recorded dust fallout rates within the

recognised limits (SANS 1929: 2005) for the residential and industrial sites. The results indicate that dust emissions from the current mining

activities do not significantly increase ambient dust levels.

Noise

Ambient noise levels at the Tumela Mine and the Amandelbult Concentrator Plant Section are characterised by noise emissions from the existing

mining operations, as well as community noise.

Traffic

The R510 road traverses the mining right area and provides access to Northam in the south and Thabazimbi in the north. The northern intersection

of the R510 provides access to the Dishaba Mine and the Amandelbult Concentrator Plant Section. The connecting roads intersecting with the

R510 are controlled with stop signs. Intersections are mostly used by mine employees.

Socio-economy

Demographics

The proposed project site is located approximately 16.7 km northeast of Northam, and 24 km south of Thabazimbi within the Thabazimbi Local

Municipality (TLM) and the Waterberg District Municipality’s jurisdiction in the Limpopo Province. The population of TLM consists of 85 234 people,

with an annual population growth rate of approximately 2.63% (StatsSA, 2011).

The age profile of a population provides valuable insight into the composition of the market population and will help establish the Potential

Economically Active (PEA) population. The PEA refers to the population that falls within the working age group (aged between 15 and 64). It does

26

not mean that this entire portion of the population is prepared, willing or able to be employed, i.e. some prefer to stay at home as housekeepers,

others are disabled and some are fulltime students, or have stopped looking for work. They do, however, form part of the potential labour pool. In

TLM, 76.4% of the population is classified as PEA.

Approximately 2.4% of the population is over the age of 65 and approximately 21.1% is under the age of 14. The dependency ratio indicates the

number of individuals that is younger than 15 and older than 64, who are dependent on the PEA population. In TLM, 30.8% of the population is

dependent on the PEA population (StatsSA, 2011).

The TLM is dominated by a black African population (84.3%), with a smaller representation of white people (14.4%) and other population groups

(1.2%). Gender and age are important variables in terms of the labour-sending capacity of an area. As shown in Table 3, the male population per

age category within the TLM exceeds that of the female population for the same age category. The predominance of males can partially be

attributed to the historical in-migration of males as result of the local platinum mining industry and farm employment.

The language predominantly spoken in the TLM is Setswana (38%), followed by Afrikaans (14.5%) and IsiXhosa (11.4%). The remaining languages

spoken in TLM and their distributions are provided in Table 4.

Table 3 | Gender and age distribution for Thabazimbi Local Municipality (StatsSA, 2011)

Table 4 | Languages spoken by the population in Thabazimbi Local Municipality (StatsSA, 2011)

Age distribution Gender

Males Females

0-4 4,7% 4,8%

5-9 3,2% 3,1%

10-14 2,7% 2,7%

15-19 3% 2,9%

20-24 6,4% 4,5%

25-29 8,6% 5,2%

30-34 7,4% 4,2%

35-39 5,9% 3,5%

40-44 4,3% 3%

45-49 4,3% 4,3%

50-54 3,6% 1,9%

55-59 2,3% 1,2%

60-64 1% 0,7%

65-69 0,5% 0,5%

70-74 0,3% 0,3%

75-79 0,2% 0,2%

80-84 0,1% 0,1%

85+ 0,1% 0,1%

Total 41.5% 58.5%

Language Percentage of population

Afrikaans 14,5%

English 3,3%

IsiNdebele 0,9%

IsiXhosa 11,4%

IsiZulu 2%

Sepedi 7,3%

Sesotho 3,6%

Setswana 38%

Sign Language 0,3%

SiSwati 0,7%

Tshivenda 1,2%

Xitsonga 6,8%

Other 2.1%

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Education

A critical factor affecting quality of life is the standard of education within a community. The level of education of a population is used as an indicator

of human capital. It is measured by the percentage distribution of the population older than 20 years and the highest level of schooling attained.

The 2011 Census data provided by StatsSA (2011) indicates that only approximately 14.2% of the population attained a matric level of education,

with only 1.6% of the population having completed a higher education. Table 5 contains a summary of the education level of the all ages of the

population within the TLM.

Table 5 | Education level of the population in Thabazimbi Local Municipality (StatsSA, 2011)

Employment and earnings

Of the total working age population of approximately 76.4% in the TLM, 20.6% are unemployed. The unemployment and youth unemployment

rates (26.9%) are the lowest in the district. Table 6 provides an overall summary of the employment status within the TLM for those aged 15 to 64.

Table 6 | Employment status of the working age population in the Thabazimbi Local Municipality (StatsSA, 2011)

The ability of people to afford basic services (such as water, sanitation and health care), is often indicated through income levels. As shown in

Table 7, households with an income of between R 38 201 and R 76 400 form the largest single group (20%) in the municipality. The majority of the

population (69.5%) earns an annual income of less than R 76 400. Note that the average household size is 2.8 people.

Table 7 | Annual income distribution of households within the Thabazimbi Local Municipality (StatsSA, 2011)

Living conditions

Of the 25 080 households in the TLM, 47.3% have piped water inside their dwelling, 23.9% have piped water inside the yard, and 12.7% have

access to piped water less than 200 m from their dwellings. Only 6.2% of households have no access to piped water. The various water sources

Not Applicable 7,8%

Level of Education Percentage of population in TLM (all ages)

No Schooling 5,6%

Some Primary 36,3%

Completed Primary 6,4%

Some Secondary 33,4%

Completed Secondary 14,2%

Higher Education 1,6%

Not Applicable 2,5%

Employment status Number

Employed 32,918

Unemployed 8,562

Discouraged Work Seeker 1,236

Not Economically Active 22,438

Average household income Percentage

No income 14%

R1 - R4,800 2,7%

R4,801 - R9,600 4,1%

R9,601 - R19,600 12,6%

R19,601 - R38,200 16,1%

R38,201 - R76,400 20%

R76,401 - R153,800 14%

R153,801 - R307,600 9,9%

R307,601 - R614,400 4,6%

R614,001 - R1,228,800 1,2%

R1,228,801 - R2,457,600 0,4%

R2,457,601+ 0,2%

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in TLM are listed in Table 8. Most of the TLM population live in urban settings, and the remainder on farms, with 70.7% of the population residing

in formal dwellings. Only 63.1% of households have access to toilets connected to a sewerage system, but 76.8% of households have access to

electricity for lighting. Refuse is removed by a local authority or private company for 62.2% of households, while 31% of households dispose of

refuse in dumps themselves. Additional details on housing, water and sanitation facilities, energy sources, and refuse disposal are provided in

Table 8.

Table 8 | Living conditions details for the Thabazimbi Local Municipality (StatsSA, 2011)

Facility Percentage of households

Housing

Urban 82,2%

Tribal/Traditional 0%

Farm 17,8%

Source of water

Regional/Local water scheme (operated by municipality or other water services provider)

63,9%

Borehole 17,4%

Spring 0,2%

Rain water tank 0,3%

Dam / Pool / Stagnant water 0,3%

River/Stream 0,2%

Water vendor 1,2%

Water tanker 14,8%

Other 1,7%

Toilet facility

None 6,3%

Flush toilet (connected to sewerage system) 63,1%

Flush toilet (with septic tank) 4,9%

Chemical toilet 0,7%

Pit toilet with ventilation 2,6%

Pit toilet without ventilation 18,4%

Bucket toilet 0,8%

Other 3,3%

Energy source Cooking Heating Lighting

Electricity 73,1% 68% 76,8%

Gas 1,7% 1,2% 0,2%

Paraffin 16,1% 8% 4,4%

Solar 0,1% 0,2% 0,3%

Candles 0% 0% 17,9%

Wood 8,7% 14% 0%

Coal 0,1% 0,1% 0%

Animal Dung 0% 0,1% 0%

Other 0% 0% 0%

None 0,2% 8,2% 0,4%

Refuse Disposal

Removed by local authority / private company at least once a week 60,4%

Removed by local authority / private company less often 1,8%

Communal refuse dump 2,2%

Own refuse dump 28,8%

No rubbish disposal 5,5%

Other 1,3%

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(b) Description of the current land uses

Land uses in the Thabazimbi Local Municipality

The TLM is dominated by open bush vegetation, a few scattered patches of low shrubland vegetation, and large portions of degraded vegetation.

Cultivated commercial croplands are also common, especially along the Crocodile River. Various mines are located in the vicinity of the proposed

project, together with associated communities, such as the Chromite mine settlement to the west of the Amandelbult mine complex (see Figure 9).

Figure 9 | Land cover and land use of the Thabazimbi Local Municipality

Thabazimbi Spatial Development Framework (TSDF)

The proposed project will occur within an area regarded as having a mining land use. Therefore, it will not negatively influence the spatial

development of future developments such as game farming, irrigation agriculture, dry-land farming, cattle farming or urban development in the

Thabazimbi Municipal Area (Thabazimbi Municipality 2007). Mining is one of the primary economic activities in the Thabazimbi Local Municipality.

The proposed project does not take place within any of the areas identified as Environmentally Sensitive Areas (mountainous areas, area between

Thabazimbi and the Marakele National Park, the riparian zone of the Crocodile River, and various other nature reserves) identified in the Integrated

Environmental Programme (IEP) complied together with the Thabazimbi Spatial Development Framework (TSDF, 2007).

Waterberg Spatial Development Framework (WSDF)

Mining is not considered to be in conflict with urban development in the Waterberg District Municipality (Waterberg Municipality 2009). The relocated

railway will be placed in an area that is considered a currently active mine with existing mining activity and platinum potential. The relocation of the

railway will not lead to any significant environmental scarring, a concern raised in the WSDF (Waterberg Municipality 2009), and will be rehabilitated

at the end of the life of mine of the Amandelbult Complex.

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Figure 10 | Mining within the Waterberg Spatial Development Framework, indicating the general project location within an active mining area (WSDF, 2009)

Land uses in the study area

Land uses in and around the proposed site consist of mining, agriculture (crop and cattle farming) and game farming. Infrastructure on site includes

gravel service roads, service tracks, the operational railway line, game fencing and the surface compressed air and water pipelines. The pipelines

are shown in Figure 11 and Figure 12. The railway line to be relocated is shown in Figure 13, Figure 14, Figure 15, and Figure 16.

Figure 11 | View of the water and compressed air lines in the site at a road crossing, looking east

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Figure 12 | View of the water and compressed air lines in the site at a road crossing, looking west

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Figure 13 | Panoramic view of the site, looking south, from near the entrance to the site

Figure 14 | Panoramic view of the site, looking south, from its north-eastern corner

33

Figure 15 | Panoramic view of the site along the railway line in the north-western portion of the site, looking north-west

Figure 16 | Panoramic view of the site along the railway line in the north-western portion of the site, looking north-east

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(c) Description of specific Environmental features and infrastructure on the site

Specific environmental features are described in sections (a) and (b), page 18 and 29. There are no original farmstead buildings, graves, or

archaeological artefacts on the project area.

(d) Environmental and current land use map

(Show all environmental and current land use features)

Please refer to Figure 9.

e) Impacts and risks identified including the nature, significance consequence, extent, duration and probability

of the impacts, including degree to which these impacts

(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 anticipated impacts of the proposed facility during construction (Table 9 and Table 10), operation (Table 11 and Table 12), and decommissioning

(Table 13 and Table 14 ) phases are shown in the tables below, before and after mitigation. The decommissioning phase includes both the removal

of the current railway line, as well as the decommissioning of the expanded railway portion at mine closure.

The impacts listed here are based on typical known impacts of the proposed activity, and will be amended according to issues and concerns

received from affected parties, in the Final BAR.

Impacts and risks identified are provided in terms of the extent to which they can be reversed, may cause irreplaceable loss of resources, can be

avoided, managed or mitigated by showing their significance levels in two tables per phase as anticipated pre-mitigation and post-mitigation.

Construction phase

Pre-mitigation

Table 9 | Construction phase impacts before mitigation

Code Impact

Pre-mitigation:

Duration Extent Intensity Consequence Probability Significance

1 Soil pollution from cement or concrete Short-term Site-

specific

Moderate -

negative

Slightly

detrimental Fairly likely

Low -

negative

2 Soil pollution from chemicals used at any time during construction

(e.g. hydrocarbons) Short-term

Site-

specific

Moderate -

negative

Slightly


Low -

negative

3 Soil pollution from contaminated washwater or wastewater

(including ballast washwater) Short-term

Site-

specific

Moderate -

negative

Slightly

detrimental Unlikely Very low

4 Soil pollution from ablution facilities Short-term Site-

specific

Low -

negative Negligible Unlikely Very low

5 Loss of topsoil from ineffective topsoil removal or storage Long-term Site-

specific

Low -

negative

Slightly


Low -

negative

6 Air pollution and nuisance caused by dust generation by speeding

(construction) vehicles Short-term

Site-

specific

Low -

negative Negligible Very likely Very low

7 Air pollution caused by emissions released by (construction)

vehicles Short-term Local

Low -

negative

Slightly

detrimental Very likely

Low -

negative

8 Surface and/or groundwater pollution from incorrect management,

storage and disposal of cement and concrete Short-term Local

Moderate -

negative

Slightly


Low -

negative

35

9

Surface and/or groundwater pollution from incorrect disposal or

spillage of chemicals used at any time during construction (e.g.

hydrocarbons)

Short-term Local Moderate -

negative

Slightly


Low -

negative

10 Surface and/or groundwater pollution from ablution facilities Short-term Local Low -

negative

Slightly


11 Surface and/or groundwater pollution from incorrect management

and disposal of contaminated wash water or wastewater Short-term Local

Moderate -

negative

Slightly


Low -

negative

12 Surface and/or groundwater pollution from spillages or incorrect

cleaning of equipment used during construction Short-term Local

Moderate -

negative

Slightly


Low -

negative

13 Soil erosion caused by vegetation clearing / bare soil Medium-

term Local

Low -

negative

Slightly


Low -

negative

14 Establishment / proliferation of alien invasive species in areas

disturbed during construction Long-term

Site-

specific

Moderate -

negative

Moderately


Low -

negative

15 Visual impact from inappropriate disposal of construction waste Long-term Site-

specific

Low -

negative

Slightly


Low -

negative

16 Noise caused by vehicle movement to and from the railway line

sites Short-term

Site-

specific

Low -

negative Negligible Very likely Very low

17 Loss of faunal and floral habitat due to construction activities Long-term Site-

specific

Low -

negative

Slightly


Low -

negative

18 Soil compaction Long-term Site-

specific

Low -

negative

Slightly


Low -

negative

19 Potential heritage or palaeontological finds Medium-

term

Site-

specific Negligible Negligible Unlikely Very low

Post-mitigation

Table 10 | Construction phase impacts after mitigation

Code Impact

Post-mitigation:


1 Soil pollution from cement or concrete Short-term Site-specific

Moderate - negative

Slightly detrimental

Unlikely Very low

2 Soil pollution from chemicals used at any time during construction (e.g. hydrocarbons)

Short-term Site-specific

Moderate - negative


Unlikely Very low

3 Soil pollution from contaminated washwater or wastewater (including ballast washwater)


Moderate - negative


Very unlikely

Very low

4 Soil pollution from ablution facilities Short-term Site-specific

Low - negative

Negligible Very unlikely

Very low

5 Loss of topsoil from ineffective topsoil removal or storage Short-term Site-specific

Low - negative

Negligible Fairly likely Very low

6 Air pollution and nuisance caused by dust generation by speeding (construction) vehicles


Low - negative


7 Air pollution caused by emissions released by (construction) vehicles Short-term Local Negligible Negligible Very likely Very low

8 Surface and/or groundwater pollution from incorrect management, storage and disposal of cement and concrete


Moderate - negative


Unlikely Very low

9 Surface and/or groundwater pollution from incorrect disposal or spillage of chemicals used at any time during construction (e.g. hydrocarbons)


Moderate - negative


Unlikely Very low

10 Surface and/or groundwater pollution from ablution facilities Short-term Site-specific

Low - negative

Negligible Unlikely Very low

11 Surface and/or groundwater pollution from incorrect management and disposal of contaminated wash water or wastewater


Negligible Negligible Unlikely Very low

36

12 Surface and/or groundwater pollution from spillages or incorrect cleaning of equipment used during construction


Moderate - negative


Unlikely Very low

13 Soil erosion caused by vegetation clearing / bare soil Short-term Site-specific

Low - negative


14 Establishment / proliferation of alien invasive species in areas disturbed during construction

Long-term Site-specific

Low - negative


Unlikely Very low

15 Visual impact from inappropriate disposal of construction waste Short-term Site-specific

Low - negative

Negligible Unlikely Very low

16 Noise caused by vehicle movement to and from the railway line sites Short-term Site-specific

Low - negative


17 Loss of faunal and floral habitat due to construction activities Long-term Site-specific

Negligible Negligible Very likely Very low

18 Soil compaction Short-term Site-specific

Low - negative

Negligible Very likely Very low

19 Potential heritage or palaeontological finds Medium-term

Site-specific


Operational phase

Pre-mitigation

Table 11 | Operational phase impacts before mitigation

Code Impact

Pre-mitigation:


1 Soil erosion from soil left bare after construction Long-

term

Site-

specific Low - negative Slightly detrimental Fairly likely Low - negative

2 Establishment / proliferation of alien invasive species Long-

term

Site-


3 Loss of faunal and floral habitat Long-

term

Site-


4 Soil erosion from incorrectly managed stormwater

runoff

Long-

term

Site-

specific Low - negative Slightly detrimental Unlikely Very low

5 Employment through continuation of mining

operations

Long-

term Local

Moderate -

positive

Moderately

beneficial Very likely

Moderate -

positive

Post-mitigation

Table 12 | Operational phase impacts after mitigation

Code Impact

Post-mitigation:


1 Soil erosion from soil left bare after construction

Long-term Site-specific Low - negative Slightly detrimental Unlikely Very low

2 Establishment / proliferation of alien invasive species

Long-term Site-specific Low - negative Slightly detrimental Unlikely Very low

3 Loss of faunal and floral habitat Long-term Site-specific Negligible Negligible Fairly likely Very low

4 Soil erosion from incorrectly managed stormwater runoff

Long-term Site-specific Negligible Negligible Unlikely Very low

5 Employment through continuation of mining operations

Long-term Local Moderate - positive

Moderately beneficial Very likely Moderate - positive

Decommissioning phase

Pre-mitigation

37

Table 13 | Decommissioning phase impacts before mitigation

Code Impact

Pre-mitigation:


1 Soil pollution from chemicals used at any time during

decommissioning (e.g. hydrocarbons) Short-term

Site-

specific

Low -

negative Negligible Fairly likely Very low

2 Soil pollution from contaminated washwater or wastewater Short-term Site-

specific

Low -

negative Negligible Unlikely Very low

3 Visual impact from inappropriate disposal of demolished structures Medium-

term

Site-

specific

Low -

negative

Slightly


Low -

negative

4 Establishment / proliferation of alien invasive species Long-term Site-

specific

Low -

negative

Slightly


Low -

negative

5 Surface and/or groundwater pollution from incorrect management,

storage and disposal of construction waste Short-term Local

Slightly


Low -

negative


and disposal of contaminated wash water or wastewater Short-term Local

Moderate -

negative

Slightly



and disposal of domestic or hazardous waste Short-term Local

Moderate -

negative

Slightly


8 Surface and/or groundwater pollution from incorrect disposal /

leakage / spillage of chemicals (e.g. hydrocarbons) Short-term Local

Moderate -

negative

Slightly


Low -

negative

9 Reestablishment of floral and faunal habitat at decommissioning of

railway Long-term

Site-

specific Low - positive

Slightly

beneficial Very likely Low - positive

10 Increased floral and faunal diversity at decommissioning of railway Long-term Site-

specific Low - positive

Slightly

beneficial Very likely Low - positive

Post-mitigation

Table 14 | Decommissioning phase impacts after mitigation

Code Impact

Post-mitigation:


1 Soil pollution from chemicals used at any time during decommissioning (e.g. hydrocarbons)

Short-term

Site-specific

Low - negative Negligible Unlikely Very low

2 Soil pollution from contaminated washwater or wastewater Short-term

Site-specific


3 Visual impact from inappropriate disposal of demolished structures

Short-term

Site-specific

Low - negative Negligible Unlikely Very low

4 Establishment / proliferation of alien invasive species Short-term

Site-specific

Low - negative Negligible Fairly likely Very low

5 Surface and/or groundwater pollution from incorrect management, storage and disposal of construction waste

Short-term

Site-specific

Moderate - negative


Unlikely Very low

6 Surface and/or groundwater pollution from incorrect management and disposal of contaminated wash water or wastewater

Short-term

Site-specific

Moderate - negative


Unlikely Very low

7 Surface and/or groundwater pollution from incorrect management and disposal of domestic or hazardous waste

Short-term

Site-specific

Moderate - negative


Unlikely Very low

8 Surface and/or groundwater pollution from incorrect disposal / leakage / spillage of chemicals (e.g. hydrocarbons)

Short-term

Site-specific

Moderate - positive

Slightly beneficial Unlikely Very low

9 Reestablishment of floral and faunal habitat at decommissioning of railway

Long-term

Local Low - positive Moderately beneficial

Very likely Moderate - positive

10 Increased floral and faunal diversity at decommissioning of railway Long-term

Local Low - positive Moderately beneficial

Very likely Moderate - positive

38

f) 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).

Methodology used in determining the significance of environmental impacts

For each predicted impact, criteria are applied to establish the significance of the impact based on likelihood (probability) and consequence, firstly

in the case of no mitigation and then with the most effective mitigation measure(s) in place.

The criteria that contribute to the consequence of the impact are INTENSITY (the degree to which pre-development conditions are changed); the

DURATION (length of time that the impact will continue); and the EXTENT (spatial scale) of the impact. The sensitivity of the receiving environment

and/or sensitive receptors is incorporated into the consideration of consequence by appropriately adjusting the thresholds or scales of the intensity,

duration and extent criteria, based on expert knowledge. For each impact, the specialist applies professional judgement to ascribe a numerical

rating for each criterion according to the ratings provided.

The consequence is then established using the formula:

Consequence = intensity (duration + extent)

Duration

Rating Criteria

2 Long-term: The impact will continue for 6-15 years.

1 Medium-term: The impact will continue for 2-5 years.

0 Short-term: The impact will continue for between 1 month and 2 years.

Extent

Rating Criteria

2 Regional: The impact will affect the entire region

1 Local: The impact will extend across the site and to nearby properties.

0 Site specific: The impact will be limited to the site or immediate area.

Intensity

Rating

Criteria

Negative impacts

(Type of impact = -1)

Positive impacts

(Type of impact = +1)

Very high (-/+ 4)

Very high degree of damage to natural or social systems or

resources. These processes or resources may restore to their pre-

project condition over very long periods of time (more than a typical

human life time).

Great improvement to ecosystem or social processes and services or

resources.

High (-/+ 3)

High degree damage to natural or social system components,

species or resources. Intense positive benefits for natural or social systems or resources.

Moderate (-/+ 2)

Moderate damage to natural or social system components, species

or resources.

Average, on-going positive benefits for natural or social systems or

resources.

Low (-/+ 1)

Minor damage to natural or social system components, species or

resources. Likely to recover over time. Ecosystems and valuable

social processes not affected.

Low positive impacts on natural or social systems or resources.

Negligible (0)

Negligible damage to individual components of natural or social

systems or resources, such that it is hardly noticeable. Limited low-level benefits to natural or social systems or resources.

Depending on the numerical result of this calculation, the impact’s consequence would be classified as one of the following:

Range Consequence rating

-8 Extremely detrimental

-7 to -6 Highly detrimental

39

-5 to -4 Moderately detrimental

-3 to -2 Slightly detrimental

-1 to 1 Negligible

2 to 3 Slightly beneficial

4 to 5 Moderately beneficial

6 to 7 Highly beneficial

8 Extremely beneficial

To determine the significance of an impact, the probability (or likelihood) of that impact occurring is also taken into account. In assigning probability,

the specialist must take into account the likelihood of occurrence and the degree of uncertainty and detectability of the impact.

Significance is calculated according to the following formula:

Significance = consequence x probability

Probability

Rating Criteria

4 Certain/ Definite: There are sound scientific reasons to expect that the impact will definitely occur.

3 Very likely: It is most likely that the impact will occur.

2 Fairly likely: This impact has occurred numerous times here or elsewhere in a similar environment and with a similar

type of development and could very conceivably occur.

1 Unlikely: This impact has not happened yet but could happen.

0 Very unlikely: The impact is expected never to happen or has a very low chance of occurring.

Depending on the numerical result of this calculation, the impact would fall into a significance category of one of the following:

Rating Significance rating Colour code

-4 Very high - negative

-3 High - negative

-2 Moderate - negative

-1 Low - negative

0 Very low

1 Low - positive

2 Moderate - positive

3 High - positive

4 Very high - positive

Methodology for identification of mitigation measures

The mitigation hierarchy below illustrates the actions which can be undertaken to respond to negative impacts and the preference give to mitigation

measures. The topmost measures are preferred, and the preference for mitigation measures decreases the further one moves down the hierarchy.

40

For each impact assessed, mitigation measures have been proposed to reduce and/ or avoid negative impacts and enhance positive impacts. The

mitigation measures identified by the specialists have been reviewed for feasibility and incorporated into the EMPr to ensure that they are

implemented throughout the lifecycle of the proposed project. The EMPr would become a legally binding document should this project receive an

EA.

The potential impacts identified, as well as the methodology employed in determining their nature, significance, consequences, extent, duration and

probability, is provided in this report as well as in Appendix 5. Affected parties are encouraged to peruse these sheets and raise comments, issues

and concerns therewith. These comments will be taken into account upon finalisation of the railway line layout.

e) The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternatives

will have on the environment and the communities that may be affected.

(Provide a discussion in terms of advantages and disadvantages of the initial site layout compared to alternative layout options to accommodate concerns raised by affected parties)

Options to meeting the project’s objectives were considered during site visits and communications with the Applicant, which led to the investigation

of alternatives as part of the BA process.

The preferred alternative is taken forward in the impact prediction, where the potential positive and adverse effects to the environmental features

and attributes are examined further. A detailed comparative analysis of the project’s feasible alternatives is included in the CBAR, considering

environmental evaluations and concerns of affected parties (if any are raised during consultation, these will be incorporated into the assessment of

positive and negative impacts of the proposed activity).

It is important to note that the proposed activity will take place on existing an existing mining area. No communities will be affected as none are

located in the area, apart from a few farm residents on neighbouring properties. Nevertheless, any issues with the current preferred railway line

layout, as raised by I&APs, will be addressed in the FBAR.

According to the requirements of the NEMA, the EAP and applicant has reviewed project alternatives and contemplated various potential

environmental impacts associated with the project resulting, in the selection of the Best Practicable Environmental Option.

Table 15 | Positive and negative impacts that the proposed railway line relocation and extension may have on the environment and communities potentially affected

Positive Impacts Negative Impacts

Impact avoidance: This step is most effective when applied at an early stage of project

planning. It can be achieved by:

Not undertaking certain projects or elements that could result in adverse impacts;

Avoiding areas that are environmentally sensitive; and

Putting in place preventative measures to stop adverse impacts from occurring.

Impact minimisation: This step is usually taken during impact identification and prediction

to limit or reduce the degree, extent, magnitude, or duration of adverse impacts. It can be

achieved by:

Scaling down or relocating the proposal;

Redesigning elements of the project; and

Taking supplementary measures to manage the impacts.

Impact compensation: This step is usually applied to remedy unavoidable residual

adverse impacts. It can be achieved by:

Example, by habitat enhancement;

Restoration of the affected site or environment to its previous state or better; and

Replacement of the same resource values at another location (off-set), for example, by

wetland engineering to provide

The mitigation described in the above diagram represents the full range of plausible and

pragmatic measures that can be implemented to mitigate identified impacts.

41

Alternative 1

Relocating railway line approximately 100m north of current railway line location

Railway operations at the mine will be enabled to continue, in

particular, the operations to the east of the site, which is served by

the rail to be relocated and extended.

Increased disturbance (including vegetation clearing, vehicle activity,

material stockpiling etc.) will likely take place in an area which, although

mostly disturbed, is bordered by partially natural surroundings.

The extraction of PGEs from Pit 37E, would be made possible. The

Pit is located on a portion of the existing railway line. The positive

knock-on impacts of increased resource extraction at the

Amandelbult mine are described in more detail in Section 3(i), page

14, and includes, inter alia, continued contribution of the mine to

Platinum resources extracted, as well as continuation of job provision

to mine employees.

Two protected tree species, namely Camel Thorn (Acacia erioloba) and

Leadwood (Combretum imberbe) may occur in the region of the

proposed site. However, neither of the two species was seen on or in

the vicinity of the study site during the specialist’s site visit.

A new fence may have to be erected to keep game out. Game will have

to be removed from the site prior to any activities taking place on site.

The project site may be used by two common toad species namely

Guttural Toad and Red Toad en route between breeding sites (these

species are not of conservation concern).

Alternative 2

Leaving the current railway line in its current position and reducing the size of Pit 37E

Disturbance may still be caused by the mining of Pit 37E. However,

mining of this pit may prove financially unfeasible if its size is reduced to

accommodate leaving the existing railway line in its current position.

Alternative 3

The relocation of the railway line to the south of the pit

The size of Pit 37E would have to be reduced, resulting in potential

financial infeasibility of mining in this area.

A larger footprint would result from constructing the railway south of the

pit, potentially causing greater environmental impacts as a larger area

would be occupied, driven over, and cleared of vegetation during

construction.

Alternative 4

No-go alternative – the existing railway line remains in its current position (along with the compressed air and water pipeline) and no mining

through Pit 37E take place.

No additional disturbance (from vegetation clearing, vehicle activity,

material stockpiling etc.) will take place in an area which, although

mostly disturbed, is bordered by partially natural surroundings.

The mine will not be able to contribute further Platinum-resources, nor

sustain the same number of jobs as present.

42

f) The possible mitigation measures that could be applied and the level of risk

(With regard to the issues and concerns raised by affected parties provide a list of the issues raised and an assessment/ discussion of the mitigations or site layout alternatives available to accommodate or address their concerns, together with an assessment of the impacts or risk associated with the mitigation or alternatives considered).

No issues were raised as yet. See Part B, section (1) (e) for a discussion on mitigation measures of each impact.

Although unlikely, sub-surface remains of heritage sites could still be encountered during the project’s construction. Such sites would offer no surface indication of their presence due to the high state of alterations in some areas, as well as heavy plant cover in other areas. The following indicators of unmarked sub-surface sites could be encountered:

Ash deposits (unnaturally grey appearance of soil compared to the surrounding substrate);

Bone concentrations, either animal or human;

Ceramic fragments such as pottery shards either historic or pre-contact;

Stone concentrations of any formal nature.

The following recommendations are given, should any sub-surface remains of heritage sites be identified:

All operators of excavation equipment should be made aware of the possibility of the occurrence of sub-surface heritage features and the following procedures should they be encountered;

All construction in the immediate vicinity (50m radius of the site) should cease;

The heritage practitioner should be informed as soon as possible;

In the event of obvious human remains, the South African Police Services (SAPS) should be notified;

Mitigation measures (such as refilling etc.) should not be attempted;

The area in a 50m radius of the find should be cordoned off with hazard tape;

Public access should be limited;

The area should be placed under guard; and

No media statements should be released until such time as the heritage practitioner has had sufficient time to analyse the finds.

g) Motivation where no alternative sites were considered

Additional railway line location alternatives were not considered.

Consideration of site alternatives is not feasible in this instance, due to the existence of the current railway line, of which only a small section is to

be relocated.

h) Statement motivating the alternative development location within the overall site

(Provide a statement motivating the final site layout that is proposed)

Alternative 1 is the preferred alternative. As shown in Table 15, the preferred alternative will have very few additional negative impacts on the

environment, as the area is already fairly degraded. Furthermore, the extension of the current railway line is proposed to be extended by merely

52 m. Alternative 1 is further motivated by a potential increase in economically extracted Platinum-resources provision from the Amandelbult

Complex, along with positive indirect social impacts.

In the case of Alternative 2, the reduction of Open Pit 37 will result in a very small amount of ore material that could be extracted from the smaller

pit. The amount of PGE-ounces that could then be extracted would not outweigh the cost of extracting and processing the minerals, as it would in

the case of Alternative 1. This could lead to contraction of mining operations at the Amandelbult Complex, with various indirect socio-economic

impacts, such as job losses.

Alternative 3 is not a feasible option, since the wide horizontal curves requires for a railway line would not make it possible to keep the railway line

outside the proposed open pit area. In other words, the railway line would continue to bisect the open pit area. This would result in a larger footprint,

potentially causing greater environmental impacts as a larger area would be occupied, driven over, and cleared of vegetation during construction.

This would have the same effect as the Alternative (2) – to reduce the size of Open Pit 37.

In the case of Alternative 4, the “No-Go alternative”, neither infrastructure relocation, nor mining of Open Pit 37 would take place. The impacts of

this alternative are the same as for the reduction in size of Open Pit 37.

43

i) 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 activity

(Including (i) a description of all environmental issues and risks that are identified during environmental impacts 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.)

The EAP, a heritage specialist, and an ecological specialist conducted field assessments (with mine personnel) to identify and determine the

environmental attributes and associated impacts during the proposed activity. By understanding the necessity of the proposed railway line

relocation, and the context of the project in the greater socio-economic and environmental context of the mining operations, the EAP was able to

rank or rate the impacts potentially caused by the project.

Complete lists of the impacts anticipated during all phases of the project are provided in Table 9, Table 10, Table 11, Table 12, Table 13, and Table

14. Impacts are ranked according to their ratings obtained in these tables (the methodology for rating project activity impacts are discussed on page

38), and are further discussed below.

Construction Phase

Low – negative impacts

1) “Loss of faunal and floral habitat due to construction activities”: Could be mitigated by clearing vegetation only on the proposed 5.5m width of the proposed railway line, as well as replacing vegetation and removing waste materials from the remainder of the site overall, where it has been affected by construction activities.

2) “Establishment / proliferation of alien invasive species in areas disturbed during construction”: Regular removal and disposal of alien or invasive species could ensure that these species affect the natural ecological structure negligibly.

3) “Soil pollution from cement or concrete”: Soil pollution can be avoided effectively by storing cement in sealed containers, mixing concrete in dedicated bunded areas or ensuring that liners are placed underneath concrete truck outlets.

4) “Soil pollution from chemicals used at any time during construction (e.g. hydrocarbons)”: As with soil pollution from cement or concrete, placing drip trays underneath vehicles or stationary equipment, as well as placing containers in bunded areas can effectively prevent soil pollution. Furthermore, cleaning accidental spills with spill kits and disposing the waste properly could reduce the impacts on soil on site.

5) “Loss of topsoil from ineffective topsoil removal or storage”: Stripping topsoil from the railway line area according to the specifications (Anglo methodology) and minimising handling could reduce the loss thereof.

6) “Soil erosion caused by vegetation clearing / bare soil”: Could be mitigated by clearing vegetation only on the proposed 5.5m width of the proposed railway line, as well as replacing vegetation on the remainder of the site overall where it has been unnecessarily removed during construction.

7) “Soil compaction”: The soils underneath the railway line will become compacted, as will any area on which materials are stockpiles. By ripping and reshaping stockpiling when construction is finalised, the impact can be minimised. The ripping of the railway width can only take place once if line is removed upon mine closure.

8) “Air pollution caused by emissions released by (construction) vehicles”: Emissions could be reduced by switching vehicles or equipment off when not in use.

9) “Surface and/or groundwater pollution from incorrect management, storage and disposal of cement and concrete”: Water pollution can be avoided effectively by storing cement in sealed containers, mixing concrete in dedicated bunded areas or ensuring that liners are placed underneath concrete truck outlets.

10) “Surface and/or groundwater pollution from incorrect disposal or spillage of chemicals used at any time during construction (e.g. hydrocarbons)”: Placing drip trays underneath vehicles or stationary equipment, as well as placing containers in bunded areas can effectively prevent water from carrying contaminants into the ground. Furthermore, cleaning accidental spills with spill kits and disposing the waste properly could reduce the impacts of contaminants to groundwater.

11) “Surface and/or groundwater pollution from incorrect management and disposal of contaminated wash water or wastewater”: Water containing any hazardous constituents, such as hydrocarbons, should be disposed of as hazardous waste.

12) “Surface and/or groundwater pollution from spillages or incorrect cleaning of equipment used during construction”: Water containing any hazardous constituents, such as hydrocarbons, should be disposed of as hazardous waste.

13) “Visual impact from inappropriate disposal of construction waste”: Removing all waste generated during construction from site could sufficiently ensure that the visual impact is mitigated. Rubble not contaminated with hazardous substances can be used as backfill material.

The impacts listed here are typically associated with the construction of railway lines. The Low (-) ratings result mostly from the fact that the proposed railway relocation will have a relatively small footprint and construction activities will be of short duration (six months). However, the impacts are not negligible, as they are mostly fairly likely to affect the site. If mitigation measures are employed, however, all of these impacts can be mitigated to a Very Low (-) level.

Very Low – negative impacts

44

14) “Soil pollution from contaminated washwater or wastewater (including ballast washwater)”: If any washwater containing hazardous substances is generated, it should be contained while on site and disposed of as hazardous waste, which could completely mitigate its impacts on soils on site.

15) “Soil pollution from ablution facilities”: Ablutions’ (likely chemical portable toilets) impacts on soils could be negated by simply ensuring that facilities are regularly cleaned out, secured to the ground, and not leaking.

16) “Air pollution and nuisance caused by dust generation by speeding (construction) vehicles”: This impact could be mitigated effectively if all drivers on site adhere to speed limits and if dust suppression is carried out on windy, dry days or when material prone to generate dust is handled or moved.

17) “Surface and/or groundwater pollution from ablution facilities”: Ablutions’ (likely chemical portable toilets) impacts on water could be negated by simply ensuring that facilities are regularly cleaned out, secured to the ground, and not leaking.

18) “Noise caused by vehicle movement to and from the railway line sites”: This impact could be mitigated effectively if all drivers on site adhere to speed limits.

19) “Potential heritage or palaeontological finds”. Potential impacts on heritage finds could be mitigated by following the protocol recommended by the Heritage specialist.

The impacts listed above are rated Very Low [-] mostly because they are unlikely to occur. If they are likely to occur (such as noise and dust generated by vehicles on site) their low impacts ratings result from their site-specific nature and the fact that they would have a low intensity, due to the small project size.

Operational Phase


1) “Soil erosion from soil left bare after construction”: By revegetating soils that were cleared during construction (on areas excluding the 5.5 m-wide railway line), the impact of soil erosion around the site could be reduced substantially.

2) “Establishment / proliferation of alien invasive species”: The impact of alien and invasive species on the current ecological structure could be mitigated by removing such species and disposing thereof in a manner that would prevent its survival through reseeding.

3) “Loss of faunal and floral habitat”: The location of the railway line would remove a portion of habitat that may be required for the movement of certain faunal species. This impact could be mitigated only by restricting vegetation clearance only to areas where it is essential.

The impacts listed here are typically associated with the operation of railway lines, but are rated as Low (-) due to the railway’s usage: the railway has been in use for years, and only serves mining operations, so the current and planned operation is relatively small. If mitigation measures are employed, however, all of these impacts can be mitigated to a Very Low (-) level.

Very Low – negative impact

1) “Soil erosion from incorrectly managed stormwater runoff”: if all soil dumps are removed from site, no channelling of stormwater that could contribute to erosion would occur, thus completely mitigating this impact.

The impacts listed above are rated as Very Low (-) based on their negligible intensity in the context of the environment they would occur. Noise and air pollution impacts occur currently as part of the existing railway line, and are very low as is. Stormwater runoff would not change significantly, due to the project’s linear nature – no significant topographical changes are required around the railway expansion area.

Moderate – positive impact

2) “Employment through continuation of mining operations”: no mitigation measures are required for this positive impact, except, perhaps, to ensure that all recommendations for the mitigation of environmental impacts resulting from the operation of Pit 37 are fulfilled as set out in the EMPr and the Environmental Authorisation for this project, as well as that of the entire Amandelbult Complex.

Relocating the railway would ensure that operations to the east of the current line can continue to be served. More importantly, the removal of the existing railway line would render the space required for the extraction of resources from Pit 37 available. This impact on the mine and its employees as a whole would be Moderate (+).

Decommissioning Phase


1) “Visual impact from inappropriate disposal of demolished structures”: the removal of all waste materials or demolished structures that could be reused or recycled could ensure that no visual impact results from the proposed railway extension.

2) “Establishment / proliferation of alien invasive species”: The reestablishment of indigenous plant species should be monitored after closure and rehabilitation of the mine to ensure that alien and invasive species have not established and spread. This mitigation measure can only be implemented after mine closure, as the area on which the railway line that is to be relocated will not be rehabilitated. Rather, it will be mined out through Pit 37.

3) “Surface and/or groundwater pollution from incorrect management, storage and disposal of construction waste”: All waste generated during the project lifetime and after demolition of the railway line should be removed from the site to ensure that this impact is mitigated completely. This impact should also be mitigated

45

4) “Surface and/or groundwater pollution from incorrect disposal / leakage / spillage of chemicals (e.g. hydrocarbons)”: All waste generated during the project lifetime and after demolition of the railway line should be removed from the site to ensure that this impact is mitigated completely. Similarly, all spills should be cleaned and contaminated materials disposed of appropriately.

The decommissioning phase includes both the removal of the current railway line, as well as the decommissioning of the expanded railway portion at mine closure. These impacts are rated as Low (-) due to the relatively small component that the railway line makes up of the Amandelbult Complex. However, the complete removal of all structures and rehabilitation of the area to a state similar to or better than its pre-construction state is essential at mine closure. If all recommendations are taken into account upon decommissioning of the existing railway portion and the expanded portion, impacts during this phase could be mitigated to a Very Low (-) level. waste is removed, all spills or contaminants are cleaned, and if

Very Low – negative impacts

5) “Surface and/or groundwater pollution from incorrect management and disposal of contaminated wash water or wastewater”: All residual waste water generated during the project lifetime and after demolition of the railway line should be removed from the site to ensure that this impact is mitigated completely.

6) “Surface and/or groundwater pollution from incorrect management and disposal of domestic or hazardous waste”: All waste generated during the project lifetime and after demolition of the railway line should be removed from the site to ensure that this impact is mitigated completely.

7) “Soil pollution from chemicals used at any time during decommissioning (e.g. hydrocarbons)”: This impact can be mitigated completely by ensuring that all spillages / leakages are cleaned immediately after occurring and disposing of contaminated materials at a registered landfill, authorised to deal with hazardous waste.

8) “Soil pollution from contaminated washwater or wastewater (including ballast washwater)”: This impact can also be mitigated completely be ensuring that all contaminated water is removed from the site and disposed of as hazardous waste.

The Very Low (-) impacts anticipated are so rated due to the low likelihood of it occurring in the decommissioning phase. If they do occur, they should be mitigated in any event.

Low – positive impacts

9) “Reestablishment of floral and faunal habitat at decommissioning of railway”: This impact can be enhanced by the implementation of rehabilitation as per Anglo guidelines (through soil ripping, revegetation, etc.), the involvement of a rehabilitation specialist post-closure, and monitoring floral and faunal reestablishment at a frequency and for a period as proposed by an ecological specialist.

10) “Increased floral and faunal diversity at decommissioning of railway”: The enhancement of this impact can be achieved in the same way as the impacts of habitat reestablishment.

The impacts discussed here are rated as Low (+) as the rehabilitation of the project site will allow the ecological structure to be restored such that the floral and faunal habitat and diversity of the pre-mining scenario will prevail. The efficacy of rehabilitation of disturbances (caused throughout the lifetime of this project and other mining related operations) can be enhanced through monitoring rehabilitation success as per specialist recommendations. The impact could thus be enhanced to a Moderate (+) level.

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j) 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).

NAME OF ACTIVITY

e.g. for prospecting- drill site, site camp, ablution facility accommodation, equipment storage, sample storage, site office, access route etc.…etc.…etc.

e.g. for mining- excavation, blasting, stockpiles, discard dumps or dams, loading hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control berm, roads, pipelines, powerlines, conveyors, etc.

POTENTIAL IMPACT

(including the potential impacts for cumulative impacts)

(e.g. dust noise, drainage surface disturbance, fly rock surface water contamination, ground water contamination, air

pollution etc…etc..etc...)

ASPECTS AFFECTED

PHASE

In which impact is anticipated

(e.g. construction, commissioning, operational Decommissioning closure, post-closure)

SIGNIFICANCE

If not mitigated

MITIGATION TYPE

(Modify, remedy, control, or stop) through (e.g. noise control measures, storm water control, dust control, rehabilitation, design measures blasting controls, avoidance, relocation, alternative activity etc…etc)

e.g. modify through alternative method control through noise control through management and monitoring through rehabilitation.

SIGNIFICANCE

If mitigated

Construction of railway line Soil pollution Soils Construction Please refer to Table 9

Please refer to the EMPr (Part B of this report)

Please refer to Table 10

Topsoil loss Soils

Ecological structure

Air pollution Ambient air

Surface- and groundwater pollution

Surface- and groundwater

Soil erosion Soils

Soil compaction Soils

Alien invasive species establishment / spread


Visual impact Aesthetics

Noise pollution Ambient noise

Loss of faunal and floral habitat


Operation of railway line Soil erosion Soil Operation

47

NAME OF ACTIVITY

e.g. for prospecting- drill site, site camp, ablution facility accommodation, equipment storage, sample storage, site office, access route etc.…etc.…etc.

e.g. for mining- excavation, blasting, stockpiles, discard dumps or dams, loading hauling and transport, water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control berm, roads, pipelines, powerlines, conveyors, etc.

POTENTIAL IMPACT

(including the potential impacts for cumulative impacts)

(e.g. dust noise, drainage surface disturbance, fly rock surface water contamination, ground water contamination, air

pollution etc…etc..etc...)

ASPECTS AFFECTED

PHASE

In which impact is anticipated

(e.g. construction, commissioning, operational Decommissioning closure, post-closure)

SIGNIFICANCE

If not mitigated

MITIGATION TYPE

(Modify, remedy, control, or stop) through (e.g. noise control measures, storm water control, dust control, rehabilitation, design measures blasting controls, avoidance, relocation, alternative activity etc…etc)

e.g. modify through alternative method control through noise control through management and monitoring through rehabilitation.

SIGNIFICANCE

If mitigated

Loss of fauna and flora Ecological structure




Mining continuation Socio-economic aspects

Mining operations

Railway line demolition and rehabilitation Soil pollution Soils Decommissioning, closure and post-closure




Visual impact Aesthetics





Reestablishment of floral and faunal habitat


Increased faunal and floral diversity


The supporting impacts assessment conducted by the EAP must be attached as an appendix, marked Appendix 5

48

k) 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):-

LIST OF STUDIES UNDERTAKEN

RECOMMENDATIONS OF SPECIALIST REPORTS SPECIALISTS RECOMMENDATIONS THAT HAVE BEEN INCLUDED IN THE EIA REPORT (Mark with an X where applicable)

REFERENCE TO APPLICABLE SECTION OF REPORT WHERE SPECIALIST RECOMMENDATIONS HAVE BEEN INCLUDED

Phase I Heritage Impact Assessment

The following recommendations are given, should any sub-surface remains of heritage sites be identified:

• All operators of excavation equipment should be made aware of the possibility of the occurrence of sub-surface heritage features and the following procedures should they be encountered;

• All construction in the immediate vicinity (50m radius of the site) should cease;

• The heritage practitioner should be informed as soon as possible;

• In the event of obvious human remains, the South African Police Services (SAPS) should be notified;

• Mitigation measures (such as refilling etc.) should not be attempted;

• The area in a 50m radius of the find should be cordoned off with hazard tape;

• Public access should be limited;

• The area should be placed under guard; and

• No media statements should be released until such time as the heritage practitioner has had sufficient time to analyse the finds.

X Please refer to Section 0, page 42.

Baseline Vegetation and Vertebrate Survey

It is suggested that a new game fence be erected which will exclude the proposed mining area. This should be done once all the game has been moved out of the proposed site and before the existing fence is removed.

X Please refer to Section 4e), page 56.

Attach copies of specialist reports as appendices.

The specialist assessments are attached as Appendix 7.

49

l) Environmental impact statement

(i) Summary of the key findings of the environmental impact assessment

The proposed railway extension will be located on a partially disturbed area, influenced by surface tilling, soil compaction, vehicle tracks and gravel

roads and shallow excavations and dumping.

With regards to the biophysical environment, all potential negative impacts related to the proposed project have been assessed to be of acceptably

low significance after the implementation of mitigation measures. Conversely, the positive socio-economic impacts (employment opportunities and

local economic empowerment) will be of moderate, positive significance. With the implementation of the recommended mitigation measures, no

long-term cumulative negative impacts are expected. All recommended mitigation measures are deemed feasible for implementation.

(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.

Please refer to Appendix 2.

(iii) Summary of positive and negative impacts and risks of the proposed activity and identified alternatives

Please refer to Section e), page 40.

m) 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.

The objective of impact management will be to manage all the significant environmental aspects associated with the project with a view to address, manage and control the environmental impacts of the project, to ensure continuous monitoring of environmental performance, and continual improvement in environmental performance throughout the duration of the project through:

Implementing the EMPr with its requirements to manage significant aspects;

Measuring, controlling and monitoring relevant construction activities, significant aspects and mitigation measures;

Prevention, minimisation and control of pollution and environmental degradation, and

Regular compliance and efficiency auditing and management review for continual improvement.

Impact management outcomes

The key impact management outcomes would be the efficient and environmentally responsible railway expansion construction activities, and

efficient resource utilisation. With the successful implementation of the recommended mitigation measures, the railway line could produce an

overall positive impact on the socio-economy of the Amandelbult Complex, by allowing Pit 37 mining project to proceed.

Existing operating procedures of the Complex

In addition to the site-specific EMPr of the railway line extension (Part B of this report), the construction of the railway line will have to adhere to the relevant infrastructure policies and operating procedures on the Complex.

n) Aspects for inclusion as conditions of Authorisation

Any aspects which must be made conditions of the Environmental Authorisation

Any changes to, or deviations from the project description set out in this application must be approved, in writing, by the competent

authority before such deviations may be effected.

A suitably qualified Environmental Officer (EO) must monitor compliance with specifications of the EMPr for the duration of construction

activities. An internal EO could play this role, due to the small project size and limited environmental impacts.

50

o) Description of any assumptions, uncertainties and gaps in knowledge

(Which relate to the assessment and mitigation measures proposed)

This BA is based on the following assumption(s):

The information provided by the applicant is accurate, sufficient and unbiased, and no information that could change the outcome of the

authorisation process has been withheld.

The information obtained from the specialist baseline studies undertaken for the approved mine EMPr, as well as the Phase I Heritage

Impact Assessment conducted for this project, is accurate and unbiased.

The proposed railway line extension will not deviate significantly from the preferred alignment that has been assessed by the EAP.

Anglo will follow the conditions of the EA and applicable legislation for the duration of the project.

p) Reasoned opinion as to whether the proposed activity should or should not be authorised

(i) Reasons why the activity should be authorised or not

The proposed expansion and relocation of the internal Amandelbult Complex railway line will enable the continued service of mining operations to the east of the site. It will also allow Pit 37E operations to continue and consequently provide economically extracted PGEs, while commodity prices are low. This will help ensure the economic survival of the mine complex.

The mining sector is a major contributor to the growth of the South African economy. The expansion of opencast operations to extract resources at a relatively low cost would contribute to the security of employment for mine workers. The subcontractor undertaking proposed mining activities will be determined upon project finalisation, which will unlock local procurement opportunities. The proposed activities’ products will be processed at the existing concentrator at Amandelbult, meaning that the project scope / battery limits will be comparatively small.

Mining affects the smallest portion of land (0.4%) in the TLM, while being one of the major economic contributors in the Thabazimbi Local Municipality (Integrated Development Plan, 2014). The TLM economy is dependent on the mining, agriculture and tourism sectors. Fortunately, the proposed project in no way threatens the latter two sectors.

In addition to the quantifiable economic benefits that will result from this development, there are also a number of qualitative benefits that should be considered. These benefits could include:

Technology: Technology used on the mine will work towards improving knowledge on available technologies and skills in using such technology.

Local procurement and SMME opportunities: Local communities will be provided with opportunities and capacity to participate in contracts that would become available during construction and operation.

(ii) Conditions that must be included in the authorisation

Any changes to, or deviations from the project description set out in this application must be approved, in writing, by the competent authority

before such deviations may be effected.

A suitably qualified Environmental Officer (EO) must be appointed to monitor compliance with specifications of the EMP for the duration of the

construction activities.

q) Period for which the Environmental authorization is required

It is estimated that relocation of the railway line will take place within 3 years from date of issue of the environmental authorisation.

r) 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 basic assessment report and the Environmental Management Programme report.

Yes, the abovementioned aspects are provided at the end of this report and apply to the full content of both the BA and EMPr report.

s) Financial Provision

State the amount that is required to both manage and rehabilitate the environment in respect to rehabilitation.

51

A total of R21,070,068.51 was calculated as the Life of Mine (LoM) liability for the entire 37 East opencast project.

(i) Explain how the aforesaid amount was derived

The approach to calculating the closure quantum as specified in the DMR Guideline which was utilised in this assessment is as summarised as follows:

Step1: Determine the Mineral Mined o In the first step the mineral mined has been identified in the tables provided in the DMR Guideline (Table B.12) as “Platinum”.

Step 2A: Determine Primary Risk Class o The class has been determined from Table B.12 as “B (Medium Risk)”.

Step 2B: Revision of Primary Risk Class o The class can be revised on the basis of sellable by-products of required. However, this is not applicable for this project.

Step 3: Determine Environmental Sensitivity o The sensitivity has been determined by reference to Table B.4 of the DMR Guideline as “High”.

Step 4: Determination of weighting factors o Weighting Factor 1: The nature of the terrain where the operation is located is flat. o Weighting Factor 2: The proximity of the operation to an urban centre is considered peri-urban.

The liability was calculated from the generic closure activities considered in the DMR Guideline.

(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).

The financial provision for closure of the 37 East opencast project will be made available to the DMR in the form of a financial guarantee.

t) Specific information required by the competent Authority

(i) Compliance with the provisions of section 24(4) (a) and (b) read with section 24(3) (a) and (7) of the National

Environmental Management (Act 107of 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).

The affected land is owned by Rustenburg Platinum Mines, which also holds the Mining Right for the area on which the relocation of the railway

line is proposed. Please refer to Section (ii), page 15 for details on the Public Participation Process followed to date to investigate, assess, and

evaluate the impact of the proposed relocation on any directly affected persons.

Potential negative socio-economic impacts that will influence directly affected persons include the following:

Visual impacts: potentially arising as the aesthetic environment may be altered through the temporary visual intrusion of the small construction

site.

Increase of noise on the site during relocation and expansion of the railway line.

Dust nuisance caused by general construction activities during the relocation of the railway line.

It is not expected that these impacts would have a major influence on nearby stakeholders or I&APs, as the proposed project is located on an area that is already affected and surrounded by mine-related infrastructure. There are no non-mining land uses within a 500m radius of the site. Even the land north of the proposed site, which is not owned by Anglo, is used for mining purposes by Cronimet.

Potential positive socio-economic impacts include the following:

Local employment opportunities: the indirect impact of continuation of mining through Pit 37E may allow current employees to retain their

employment.

52

Local economy opportunities and economic empowerment: the indirect impact of continuation of mining through Pit 37 will have positive

impacts on the local economy.

(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 mining bulk sample or alluvial diamond

prospecting on any national 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 that investigation

report as Appendix 2.19.2 and confirm that the applicable mitigation is reflected in 2.5.3, 2.11.6 and 2.12 herein).

Not applicable.

u) Other matters required in terms of section 24(4) (a) and (b) of the Act

(the EAP managing the application must provide the competent authority with detailed, written proof of an investigation as

required by section 24(4) (b)(i) of the Act and motivation if no reasonable or feasible alternatives as contemplated in sub

regulation 22(2)(h), exist. The EAP must attach such motivation as Appendix).

Not applicable.

53

PART B

ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

1) Draft environmental management programme

a. Details of the EMP

(Confirm that the requirement for the provision of the details and expertise of the EAP are already included in PART A, section

1 (a) herein as required).

Yes, Details of EAP have been provided in PART A, section 1(a) of this document.

b. Description of the Aspect of the Activity

(Confirm that the requirement to describe the aspects of the activity that are covered the draft environmental management

programme is already included in PART A, section (1) (h) herein as required).

Yes, description of the activities to be undertaken as part of the proposed railway line extension and relocation has been provided in PART A of this

document.

c. Composite Map

(Provide a map (attached as an Appendix) at an appropriate scale, which superimposes the proposed activity, its associated

structures, and infrastructure on the environmental sensitivity of the preferred site, indicating any areas that should be avoided,

including buffers)

Please refer to Appendix 2.

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)

The rehabilitation of the proposed facility will be subject to conditions in the existing closure plan of the Amandelbult Complex, in which provision is

made for the decommissioning of facilities such as the proposed one. The current closure liability assessment for the Amandelbult Complex has

the following closure objectives:

The rehabilitation of land to the satisfaction of the Regional Director and to leave the area in the best possible state for continuous use of land by future generations

Revegetated areas will be monitored and maintained until such time as a vegetation cover has been established and can be shown to be self-sustaining.

Measures to control erosion of soil, such as contour drains and other erosion control structures, will be installed and maintained during the decommissioning phase and up to closure.

Grass will be monitored and maintained until such time as a suitable cover has been achieved and a closure certificate can be issued.

The following environmental management measures are proposed for Mine Infrastructure in the Closure Liability Assessment (SRK, 2012):

Mine surface infrastructure will either be demolished or an alternative use will be decided on.

Foundations will either be removed to a depth of at least 500mm below surface or be suitably covered.

Building rubble will be disposed of at a nearby suitable site;

All areas cleared of surface infrastructure will be rehabilitated by placement of topsoil and then revegetated.

All roads that will not be utilised by the local population in the post mining scenario will be ripped and vegetated.

ii. Volumes and rate of water use required for the operation.

No water will be required for this project.

iii. Has a water use licence has been applied for?

No.

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iv. Impacts to be mitigated in their respective phases

Measures to rehabilitate the environment affected by the undertaking of any listed activity

ACTIVITIES

(E.g. For prospecting - drill site, site

camp, ablution facility, accommodation, equipment storage, sample storage, site office, access route etc…etc…etc

E.g. For mining,- excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storm water control, berms, roads, pipelines, power lines, conveyors, etc…etc…etc.)

PHASE

(of operation in which activity will take place.

State; Planning and design, Pre- Construction’ Construction, Operational, Rehabilitation, Closure, Post closure).

SIZE AND SCALE of disturbance

(volumes, tonnages and hectares or m²)

MITIGATION MEASURES

(describe how each of the recommendations in herein will remedy the cause of pollution or degradation and migration of pollutants)

COMPLIANCE WITH STANDARDS

(A description of how each of the recommendations herein will comply with any prescribed environmental management standards or practices that have been identified by Competent Authorities)

TIME PERIOD FOR IMPLEMENTATION

Describe the time period when the measures in the environmental management programme must be implemented Measures must be implemented when required.

With regard to Rehabilitation specifically this must take place at the earliest opportunity. .With regard to Rehabilitation, therefore state either:- Upon cessation of the individual activity or.

Upon the cessation of mining, bulk sampling or alluvial diamond prospecting as the case may be.

Vegetation clearing Pre-construction 7012.5 m2 Vegetation shall only be cleared in areas where the railway shall be relocated to and extended.

EMPr Prior to relocation and extension of the railway line (i.e. construction).

Excavations of railway line area Construction 7012.5 m2 Topsoil removal and storage shall be conducted as per Anglo guidelines.

Materials excavated should be placed on disturbed areas as far as possible.

EMPr

Anglo American Rehabilitation Guideline

Throughout construction phase.

Infilling of excavated areas with appropriate materials

Construction 7012.5 m2 Materials used for infilling shall be safe and non-hazardous.

EMPr Throughout construction phase.

Topsoil removal, temporary handling, and storage

Construction, Decommissioning

7012.5 m2 The handling shall be limited as far as possible.

Topsoil should not be driven over, and spillages and leakages from vehicles or equipment onto topsoil should be avoided.

Topsoil stripping and storage shall be carried out according to Anglo guidelines.

EMPr

Anglo American Topsoil Guideline

Throughout construction phase. As and when topsoil is reused within the Complex.

General site management Construction 7012.5 m2 Alien invasive species shall be regularly removed to prevent its spread.

Adequate portable ablution facilities must be provided, maintained, and regularly emptied.


55

Windblown litter shall be regularly cleared from the site.

Adequate storm water and erosion control measures on bare soil shall be implemented and maintained.

Access to the site shall be controlled.

Application of dust suppressants in areas prone to dust generation if required.

Ensure that the use of machines do not disrupt any services (e.g. electricity, water supply, and telephone lines).

All machinery and equipment must be maintained in good working order, and fitted with approved and specified muffler systems.

Compliance with local by-laws and regulations regarding noise, hours of operation, and speed limits shall be adhered to.

If necessary, a fence shall be constructed to keep game out of the construction site.

Use and storage of hazardous materials, cement, hydrocarbons and other chemicals on site

Construction 100 m2 The storage and handling of any hazardous substances, cement, or concrete shall occur in bunded or on lined areas to prevent soil, surface, and groundwater contamination.


Generation and storage of domestic waste Construction 500 m2 Domestic waste should be disposed of in dedicated bins or skips, emptied on a regular basis by a registered/ authorised waste facility.

EMPr

NEM: WA


Generation and storage of hazardous waste

Construction 500 m2 Contaminated materials (wash water, rags, soil etc.) shall be disposed of as such.

The storage and handling of any hazardous substances shall occur in bunded or on lined areas to prevent soil, surface, and groundwater contamination.

EMPr

NEM: WA

Hazardous Substances Act of 1973 (Act No. 15 of 1973)


Generation and storage of construction waste

Construction 500 m2 Construction material (e.g. steel, wood, rubble) shall be removed from site regularly to an authorised waste handling facility or re-used, recycled where possible.

EMPr

NEM: WA


56

e) Impact Management Outcomes

(A description of impact management outcomes, identifying the standard of impact management required for the aspects contemplated in paragraph;

Transportation of construction (e.g. infilling) materials to and from site

Construction - Dust-prone materials should be covered during transportation thereof.

Dangers associated with the movement of large vehicles shall be clearly sign-posted and vehicles shall comply with speed limits.

Vehicle movement shall be limited to pre-existing roads and the area adjacent to existing and new railway line during installation.

Speed limits shall be adhered to at all times.


Removal of existing railway line Construction 6726 m2 All components and materials of the existing railway line to be relocated shall be removed to prevent damage to equipment upon commencement of mining activities within Pit 37.

All waste materials shall be removed and re-used, recycled or disposed of appropriately.


Removal and rehabilitation of relocated railway and extension

Decommissioning 7012.5 m2 All waste materials shall be removed and re-used, recycled or disposed of appropriately.

The site soils should be ripped to alleviate soil compaction, topsoil spread, revegetated, and regrowth monitored.

EMPr

Mineral and Petroleum Resources Development Act (Act. No. 28 of 2002)

During closure and decommissioning phase of Amandelbult Complex.

57

ACTIVITY

(whether listed on not)

(E.g. Excavations, blasting, stockpiles, discard dumps or dams, Loading, hauling and transport, Water supply dams and boreholes, accommodation, offices, ablution, stores, workshops, processing plant, storms water control, berms, roads, pipelines, power lines, conveyors, etc…etc…etc)

POTENTIAL

IMPACT

(e.g. dust, noise, drainage surface disturbance, fly rock, surface water contamination, groundwater contamination, air pollution etc…etc…)

ASPECTS

AFFECTED

PHASE

In which impact is anticipate (e.g. construction, commissioning, operational Decommissioning, closure, post-closure)

MITIGATION TYPE

(modify, remedy, control, or stop through (e.g. noise measures, storm-water control, dust control, rehabilitation, design measures, blasting controls, avoidance, relocation, alternative activity etc. etc.)

E.g.

Modify through alternative method.

Control through noise control

Control through management and monitoring

Remedy through rehabilitation.

STANDARD TO BE

ACHIEVED

(Impact avoided, noise levels, dust levels, rehabilitation standards, end use objectives etc.)

Vegetation clearing Loss of floral and faunal

habitat

Ecological structure Pre-construction;

Construction; Operation

Please refer to Section iv, from page 54. Vegetative cover is similar

to pre-project condition

after construction is

completed.

Soil erosion Soils No excessive soil erosion

during construction.

Dust generation Ambient air quality No excessive dust

nuisance or complaints.

Establishment /

proliferation of alien

invasive species in

areas disturbed during

construction

Ecological structure No alien and invasive

species established.

Excavations of railway line area Loss of topsoil Soils


Construction Please refer to Section iv, from page 54. No loss of topsoil or

seedbank.



Soil contamination Soils No soil contamination

through accidents, spillage

or leakage.

Soil compaction Soils Soil compaction limited only

to railway area.

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Surface- and

groundwater

contamination

Surface- and

groundwater

No surface- and

groundwater contamination


Soil contamination Soils Construction Please refer to Section iv, from page 54. No soil contamination through accidents, spillage or leakage.

Soil compaction Soils Soil rehabilitated to Anglo standards or as prescribed by specialist at decommissioning phase.

Topsoil removal, temporary handling, and storage

Loss of topsoil Soils


Construction, Decommissioning

Please refer to Section iv, from page 54. No loss of topsoil or seedbank.

General site management Soil contamination Soils Construction, operation,

decommissioning

Please refer to Section iv, from page 54. No soil contamination

through accidents, spillage

or leakage.

Soil erosion Soils No loss of soil. No signs of soil erosion (gullies, rills, etc.)



Air pollution Ambient air quality Air pollution standards and local bylaws adhered to.

No excessive air pollution nuisance or complaints of odours or emissions.

Noise pollution Ambient noise Noise kept at levels safe for humans.



No contaminants or litter in surface or groundwater resources.

59


Ecological structure Alien invasive species do not establish or spread.

Use and storage of hazardous

materials, cement, hydrocarbons

and other chemicals on site

Soil contamination Soils Construction Please refer to Section iv, from page 54. No soil contamination through accidents, spillage or leakage.

Dust generation Ambient air quality Air pollution standards and local bylaws adhered to.

No complaints of dust, odours, or emissions.

Surface- and groundwater contamination


No contaminants in surface or groundwater resources.

Generation and storage of domestic waste

Litter Aesthetics Construction Please refer to Section iv, from page 54. No litter on site.

Bins/ skips not overflowing.

Soil contamination Soils No soil contamination caused by domestic waste.



No contaminants or litter in surface or groundwater resources.


Soil contamination Soils Construction Please refer to Section iv, from page 54. No soil contamination caused by hazardous waste.



No contaminants in surface or groundwater resources.


Litter Aesthetics Construction Please refer to Section iv, from page 54. Construction waste disposed of in designated skips or bins.

Soil contamination Soils No soil contamination caused by domestic waste.

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No hazardous contaminants in surface or groundwater resources.


Dust generation Ambient air quality Construction Please refer to Section iv, from page 54. No excessive dust nuisance.

No complaints of dust or emissions.

Speed limits adhered to at all times.

Removal of existing railway line Incorrect materials disposal / inadequate removal of materials

Materials and waste Construction Please refer to Section iv, from page 54. All railway components structures, and materials removed prior to commencement of mining through Pit 37.


Loss of topsoil Soils


Decommissioning Please refer to Section iv, from page 54. No loss of topsoil or seedbank.

Loss of floral and faunal habitat

Ecological structure Floral and faunal habitat restored within appropriate time period after rehabilitation.

Establishment / proliferation of alien invasive species in areas disturbed during construction

Ecological structure No alien or invasive plant species on rehabilitated site.

61

f) Impact Management Actions

(A description of impact management actions, identifying the manner in which the impact management objectives and outcomes contemplated in paragraphs (c) and (d) will be achieved).

ACTIVITY

whether listed or not listed

(E.g. Excavations, blasting, stockpiles,

discard dumps or dams, Loading,

hauling and transport, Water supply

dams and boreholes, accommodation,

offices, ablution, stores, workshops,

processing plant, storms water

control, berms, roads, pipelines,

power lines, conveyors, etc.)

POTENTIAL IMPACT

(E.g. dust, noise, drainage

surface disturbance, fly rock,

surface water contamination,

groundwater contamination, air

pollution etc.)

MITIGATION TYPE

(modify, remedy, control, or stop

through (e.g. noise measures, storm-

water control, dust control,

rehabilitation, design measures,

blasting controls, avoidance,

relocation, alternative activity etc.)

E.g.

Modify through alternative

method.


Control through management

and monitoring



Describe the time period when the measures

in the environmental management programme

must be implemented Measures must be

implemented when required. With regard to

Rehabilitation specifically this must take place

at the earliest opportunity. With regard to

Rehabilitation, therefore state either:-

Upon cessation of the individual activity or.

Upon cessation of mining, bulk sampling or

alluvial diamond prospecting as the case may

be.

COMPLIANCE WITH

STANDARDS

(a description of how each of the

recommendation in 2.11.6 read

with 2.12 and 2.15.2 herein will

comply with any prescribed

environmental management

standards or practices that may

have been identified by Competent

Authorities)

Vegetation clearing Loss of floral and faunal habitat

Soil erosion

Dust generation


Vegetation shall only be cleared in areas where the railway shall be relocated to and extended.

Prior to relocation and extension of the railway line (i.e. construction).

EMPr

Excavations of railway line area Loss of topsoil

Dust generation

Soil contamination

Soil compaction


Topsoil removal and storage shall be conducted as per Anglo guidelines.

Materials excavated should be placed on disturbed areas as far as possible.

Throughout construction phase. EMPr

Anglo American Rehabilitation

Guideline


Soil contamination

Soil compaction

Materials used for infilling shall be safe and non-hazardous.


Topsoil removal, temporary handling, and

storage

Loss of topsoil The handling shall be limited as far as possible.

Throughout construction phase. As and when

topsoil is reused within the Complex.

EMPr

Anglo American Topsoil Guideline

62

ACTIVITY










POTENTIAL IMPACT





pollution etc.)

MITIGATION TYPE







E.g.


method.



and monitoring













be.

COMPLIANCE WITH

STANDARDS








Authorities)

Topsoil should not be driven over, and spillages and leakages from vehicles or equipment onto topsoil should be avoided.

Topsoil stripping and storage shall be carried out according to Anglo guidelines.

General site management Soil contamination

Soil erosion

Dust generation

Air pollution

Noise pollution



Alien invasive species shall be regularly removed to prevent its spread.

Adequate portable ablution facilities must be provided, maintained, and regularly emptied.

Windblown litter shall be regularly cleared from the site.

Adequate storm water and erosion control measures on bare soil shall be implemented and maintained, such as revegetation of disturbed areas.

Access to the site shall be controlled.

Application of dust suppressants in areas prone to dust generation.


63

ACTIVITY










POTENTIAL IMPACT





pollution etc.)

MITIGATION TYPE







E.g.


method.



and monitoring













be.

COMPLIANCE WITH

STANDARDS








Authorities)

Ensure that the use of machines do not disrupt any services (e.g. electricity, water supply, and telephone lines).

All machinery and equipment must be maintained in good working order, and fitted with approved and specified muffler systems.

Compliance with local by-laws and regulations regarding noise, hours of operation, and speed limits shall be adhered to.

Use and storage of hazardous materials, cement, hydrocarbons and other chemicals on site

Soil contamination

Dust generation


The storage and handling of any hazardous substances, cement, or concrete shall occur in bunded or on lined areas to prevent soil, surface, and groundwater contamination.


Generation and storage of domestic waste

Litter

Soil contamination


Domestic waste should be disposed of in dedicated bins or skips, emptied on a regular basis by a registered/ authorised waste facility.


NEM: WA


Soil contamination


Contaminated materials (wash water, rags, soil etc.) shall be disposed of as such.


NEM: WA

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ACTIVITY










POTENTIAL IMPACT





pollution etc.)

MITIGATION TYPE







E.g.


method.



and monitoring













be.

COMPLIANCE WITH

STANDARDS








Authorities)

The storage and handling of any hazardous substances shall occur in bunded or on lined areas to prevent soil, surface, and groundwater contamination.

Hazardous Substances Act of 1973 (Act No. 15 of 1973)


Litter

Soil contamination


Construction material (e.g. steel, wood, rubble) shall be removed from site regularly by an authorised waste handling facility, reused, or recycled.


NEM: WA


Dust generation Dust-prone materials should be covered during transportation thereof.

Dangers associated with the movement of large vehicles shall be clearly sign-posted and vehicles shall comply with speed limits.

Vehicle movement shall be limited to pre-existing roads and along the existing and new railway line during construction.

Speed limits shall be adhered to at all times.


Removal of existing railway line Incorrect materials disposal / inadequate removal of materials

All components and materials of the existing railway line to be relocated shall be removed to prevent


65

ACTIVITY










POTENTIAL IMPACT





pollution etc.)

MITIGATION TYPE







E.g.


method.



and monitoring













be.

COMPLIANCE WITH

STANDARDS








Authorities)

damage to equipment upon commencement of mining activities within Pit 37E.

All waste materials shall be removed and reused, recycled or disposed of appropriately.


Loss of topsoil

Loss of floral and faunal habitat


All waste materials shall be removed and re-used, recycled or disposed of appropriately.

The site soils should be ripped to alleviate soil compaction, topsoil spread, revegetated, and regrowth monitored.

During closure and decommissioning phase of Amandelbult Complex.

EMPr

Mineral and Petroleum Resources Development Act (Act. No. 28 of 2002)

66

i) Financial Provision

1) Determination of the amount of Financial Provision

(a) Describe the closure objectives and the extent to which they have been aligned to the baseline

environment described under the Regulation

Rehabilitation measures have been designed to meet closure objectives. The main closure objective is to ensure that the site is left as close as

possible to the pre-mining state after decommissioning activities. Financial provision for the activity’s decommissioning will be made from the

provision of the Amandelbult Complex.

The following rehabilitation specifications have been designed to meet the closure objectives:

Surface infrastructure will be demolished;

Foundations will be removed;

Building rubble will be used as backfill or disposed of at a nearby suitable site;

All areas cleared of surface infrastructure will be rehabilitated by placement of topsoil and revegetated;

All roads that will not be used by the local population in the post-mining scenario will be ripped and vegetated; and

Any soil contamination will be removed during demolition activities prior to topsoil replacement and revegetation.

(b) Confirm specifically that the environmental objectives in relation to closure have been consulted with

landowner and interested and affected parties

The land is wholly owned by Rustenburg Platinum Mines. Further comments on the rehabilitation measures and closure objectives are expected

after review of the BAR. Should any issues be raised regarding closure objectives, they will be addressed and included in the final BAR.

(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

Financial provision for the activity’s decommissioning will be made from the provision of the Amandelbult Complex (available upon request).

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

The main closure objective is to ensure that the area is restored as close as possible to the pre-extraction state in terms of shaping and spreading

of topsoil in order to allow for the establishment of natural vegetation over time.

The rehabilitation measures are deemed to be compatible with the main closure objective as it would ensure that facility is restored as close as

possible to its pre-mining state in terms of spreading and shaping of topsoil and reseeding in order to allow for the establishment of natural

vegetation. This would eventually allow natural ecosystems to re-establish, such that the surrounding area is not severely affected by any activities

associated with the railway’s operation.

(e) Calculate and state the quantum of the financial provision required to manage and rehabilitate the

environment in accordance with the applicable guideline.

Please refer to PART A Section 3 (s).

(f) Confirm that the financial provision will be provided as determined

Anglo will arrange to provide the financial guarantee for the rehabilitation costs to DMR as part of the mine’s closure liability assessment.

67

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

SOURCE

ACTIVITY

IMPACT REQUIRING

MONITORING

PROGRAMMMES

FUNCTIONAL

REQUIREMENT FOR

MONITORING

ROLES AND RESPONSIBILITIES

(FOR THE EXECUTION OF THE MONITORING PROGRAMMES)

MONITORING AND REPORTING

FREQUENCY AND TIME PERIODS FOR

IMPLEMENTING IMPACT MANAGEMENT

ACTIONS

All construction

activities

All environmental impacts

potentially occurring during

the construction phase as set

out in Section iv, page 54.

Appointment upon commencement of project. Due to the relatively small size of the project, an Environmental Officer can be an Anglo appointment.

Environmental Officer

The Environmental Officer (EO) is a person responsible for

monitoring the implementation of the EMPr and complied with

on site on a daily basis. The EO will report to Anglo and the

Department of Mineral Resources (DMR). The EO has the

authority to stop any works if, in his/her opinion, there is or may

be a serious threat to or impact on the environment; caused

directly by Anglo or the Contractor’s actions or activities during

all phases of the proposed project. In all such work stoppage

situations, the EO is to inform Anglo or the Contractor of the

reasons for the stoppage within 24 hours.

Upon failure by Anglo or the Contractor, or their employees, to

show adequate consideration to the EMPr, the EO may

recommend to Anglo or the Contractor to have their

representative(s) or any employee(s) removed from the site, or

work suspended until the matter is resolved.

The purpose of a monitoring programme is to ensure that

mitigation measures identified and described in the EMPr

are implemented. Construction, operation and

decommissioning activities shall be monitored and

recorded by the EO and audited against the EMPr on a

monthly basis. A report must be submitted at the end of

each month prior to progress meetings, where they will

form part of the agenda. The target is to achieve 100%

compliance with the EMPr.

Impact management actions shall be implemented as

prescribed in Section iv, page 54, or as advised by the EO.

All construction and

operation activities

All environmental impacts potentially occurring during the construction phase.

Anglo appointment Engineer (Anglo)

Oversee the overall implementation of the project compliance to the EMPr and incorporation of any potential environmental aspects mentioned, into designs.

Throughout construction activities.

Construction,

operation, and

decommissioning

activities

All environmental impacts potentially occurring during construction, operation, and decommissioning phases

Anglo appointment Anglo and the Contractor

As part of being responsible for the construction, operation, and

decommissioning of the proposed activities, Anglo or the

Contractor will be responsible for the overall implementation of

the EMPr. The Contractor will nominate a representative on site

as his environmental representative, known as the Contractor’s

Environmental Control Officer (CECO). The Contractor must

Monthly reporting to the PM shall take place.

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SOURCE

ACTIVITY

IMPACT REQUIRING

MONITORING

PROGRAMMMES

FUNCTIONAL

REQUIREMENT FOR

MONITORING

ROLES AND RESPONSIBILITIES

(FOR THE EXECUTION OF THE MONITORING PROGRAMMES)

MONITORING AND REPORTING

FREQUENCY AND TIME PERIODS FOR

IMPLEMENTING IMPACT MANAGEMENT

ACTIONS

issue site instructions to rectify any environmental

noncompliance, based on the CECO’s findings. The Anglo Site

Manager can also issue site instructions.

All construction activities

All environmental impacts potentially occurring during construction

Contractor should appoint a CECO

Contractor’s Environmental Control Officer

The CECO will be responsible, on behalf of the Contractor, to

ensure that the EMPr is implemented and complied with on site

on a daily basis. The CECO will liaise with the EO in all matters

relating to the implementation of the EMP. The CECO needs a

certain amount of environmental management experience in an

appropriate field.

Inspections as per method statement requirements.

Monthly reporting to the PM shall take place.

69

l) Indicate the frequency of the submission of the performance assessment or environmental audit report

Performance Assessment Reports, as required by the NEMA EIA Regulations 2014, would be prepared and submitted to the DMR every two years

or as often as requested by DMR. In addition, the appointed EO would undertake regular site audits. Copies of the site audits reports could be

submitted to DMR, if requested.

m) Environmental Awareness Plan

1) Manner in which the applicant intends to his or her employees of environmental risk which may result from

their work

Before the commencement of any activities, the appointed Contractor's site management staff should familiarise themselves with the EMPr. All

site on staff must regularly undergo awareness training and/ or toolbox talks to understand the requirements of the EMPr.

2) Manner in which risks will be dealt with in order to avoid pollution or the degradation of the environment

The following documents will be used as reference for identifying and managing impacts:

Approved EMPr;

Approved EA; and

Anglo’s Environmental Management System.

Anglo and its contractors will be responsible for the implementation of the required mitigation measures in order to avoid pollution or degradation of the environment. Appropriate implementation of the recommended mitigation measures specified in the EMPr will be monitored through regular site audits by an EO.

n) Specific information required by the Competent Authority

(Amongst others, confirm that the financial provision will be reviewed annually)

The financial provision will be reviewed on an annual basis or as requested by DMR.

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2) UNDERTAKING

The EAP herewith confirms

a) the correctness of the information provided in the reports

b) the inclusion of comments and inputs from stakeholders and I&APs ;

c) the inclusion of inputs and recommendations from the specialist reports, where relevant;

d) that the information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested and affected parties are correctly reflected herein.

Signature of the environmental assessment practitioner

Aurecon South Africa (Pty) Ltd

Name of company

16 February 2017

Date

References

Aquatico. 2015. “Annual Water Quality Report: January 2015 to December 2105.”

Aquatico. 2016. Annual Water Quality Report: January 2016 - December 2016. Anglo American Platinum.

Department of Environmental Affairs, Department of Mineral Resources, Chamber of Mines, South African Mining and Biodiversity Forum, and South

African National Biodiversity Institute. 2013. “Mining and Biodiversity Guideline: Mainstreaming biodiversity into the mining sector.”

Pretoria.

G&A Heritage. 2016. “Heritage Impact Assessment (HIA) Report for the Proposed Re-alignment of the Railway Line at the proposed 37 Open Pit,

Amandelbult Mine, Limpopo Province.”

Limpopo CPlan. 2013. Limpopo Conservation Plan version 2.

Prime Resources. 2013. “Environmental Management Programme (EMPr) compiled for the mining and beneficiation of platinum reserves at the

Tumela mine and central services section, the Dishaba mine and associated Amandelbult concentrator, Rustenburg Platinum Mines,

Limpopo province.”

Tembele Ecological Services. 2016. “Baseline Vegetation & Vertebrate Survey on three proposed open-pit excavation sites on the Anglo American

Platinum - Dishaba Mine.”

Thabazimbi Municipality. 2007. Integrated Spatial Development Framework. Thabazimbi: Plan Wize Town and Regional Planners.

Waterberg District Municipality. 2010. Waterberg District Environmental Management Framework Report. Environomics, NRM Consulting, MetroGIS.

Waterberg Municipality. 2009. Waterberg Spatial Development Framework. The Development Partnership.

-END-

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