SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE

Transcription

1 Page i SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017 SUBMITTED FOR ENVIRONMENTAL AUTHORISATION IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (ACT 107 OF 1998) IN RESPECT OF A SECTION 24G RECTIFICATION PROCESS FOR LISTED ACTIVITIES THAT COMMENCED WITHOUT ENVIRONMENTAL AUTHORISATION NAME OF APPLICANT: TSHIPI É NTLE MANGANESE MINING (PTY) LTD) TEL NO: FAX NO: POSTAL ADDRESS: PO Box 2098, Kathu, 8446 PHYSICAL ADDRESS: Farm Mamatwan 331, Kuruman Magisterial District, Northern Cape Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE SAMRAD FILE REFERENCE NUMBER: NC 30/5/1/2/3/2 1(206) MR August 2017

2 Page ii DOCUMENT INFORMATION Title THE TSHIPI BORWA MINE Status Draft Applicant TSHIPI É NTLE MANGANESE MINING (Pty) Ltd Consultant SLR Consulting (Africa) (Pty) Ltd Project Number Project Manager Marline Medallie Report Author Marline Medallie Reviewer Alex Pheiffer Report Number 1 Date last printed 2017/07/28 09:36 AM Date last saved 2017/07/28 09:31 AM Issue Date August 2017 This report has been prepared by an SLR Group company with all reasonable skill, care and diligence, taking into account the manpower and resources devoted to it. Information reported herein is based on the interpretation of data collected, which has been accepted in good faith as being accurate and valid. No warranties or guarantees are expressed or should be inferred by any third parties. This report may not be relied upon by other parties without written consent from SLR. SLR disclaims any responsibility in respect of any matters outside the agreed scope of the work. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

3 Page iii THE TSHIPI EXECUTIVE SUMMARY BORWA MINE INTRODUCTION TO THE PROJECT Tshipi é Ntle Manganese Mining (Pty) Ltd (Tshipi) operates the Tshipi Borwa Mine, an opencast manganese mine located on the farms Mamatwan 331 (mining right and surface use areas) and Moab 700 (surface use area), approximately 20km to the south of Hotazel in the John Taolo Gaetsewe District Municipality and the Joe Morolong Local Municipality in the Northern Cape Province. The mine location is illustrated in Figure 1 and Figure 2. The mine holds a mining right (NC/30/5/1/2/2/0206MR) and an Environmental Management Programme (EMPr) issued and approved by the erstwhile Department of Minerals and Energy (currently the Department of Mineral Resources (DMR)), an environmental authorisation (EA) (NC/KGA/KATHU/37/2008) issued by the Department of Tourism, Environment and Conservation (DTEC) (currently the Department of Environment and Nature Conservation (DENC)) and an Integrated Water Use Licence (IWUL) (10/D41K/AGJ/1735) issued by the Department of Water Affairs (currently the Department of Water and Sanitation (DWS)). In terms of environmental law, the approved EMPr is now deemed to be an EA issued in terms of the National Environmental Management Act No 107 of 1998 (NEMA). Certain activities at the Tshipi Borwa Mine commenced without environmental authorisation in terms of the NEMA. These activities were the establishment of a diesel farm consisting of above ground tanks and underground pipelines, and the widening of a haul road located on the eastern boundary of the surface use area (See Figure 3). Under the NEMA, the unlawful commencement of activities may be authorised through an application for rectification made in terms of section 24G of NEMA. SLR Consulting (Africa) (Pty) Ltd (SLR Africa), an independent firm of consultants, has been appointed by Tshipi as the independent environmental practitioner (EAP) responsible for undertaking the section 24G rectification application process. This report describes the environmental assessment and public participation process followed. LEGAL FRAMEWORK For the continuation of the activities, environmental authorisation is required from the DMR in terms of the NEMA. The applicable list of activities is provided in Section 3.1 (Table 4) of this report. In the absence of regulations governing a section 24G process, this assessment report has been compiled in accordance with the requirements of section 24G of the NEMA and the DMR EIA and EMPr Report template format (as informed by the guidelines posted on the official DMR website). The public participation process has Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

4 Page iv been undertaken in line with the Environmental Impact Assessment (EIA) Regulations, 2010 (Government Notice Regulation (GNR) 982 under Government Gazette (GG) of 4 December 2014 as amended (EIA Regulations, 2014). This legal framework does not cover occupational health and safety legislation requirements. OTHER APPROVALS / PERMITS Other than the amendment of the EMPr which is required to cater for changes to the approved infrastructure layout at the site, no other approvals/permits are needed for the project at this stage. This report does not cover occupational health and safety legislation requirements. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

5 R380 Tsineng!O Wessels!O Black Rock!O R31 Hotazel!O Masankong!O Coretsi!O Magojaneng!O Magobing!O Sedibeng!O Ga Mopedi!O R380 N14 Dibeng!O R To Botswana ± To van Zylsrust To Kuruman Tshipi Borwa Mine. To Kuruman Kathu!O Legend Tshipi Borwa Mine Surface Use Area Tshipi Borwa Mine Approved Mining Right Area TSHIPI E' NTLE MANGANESE MINING Figure 1 Regional Setting Meters Scale: 1:250 A3 Projection: Transverse Mercator Datum: WGS1984, Lo23 SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) Fax: +27 (11) May 2017

6 To Hotazel/ Kuruman ± D3340 Powerline United Manganese of The Kalahari Mine Sedibeng Bulk Water Supply Point Farm Worker Residence Old Middelplaats Mine R380 Hotazel - Ferrum 132Kv Powerline Mamatwan Mine A Pyper Access to Mamatwan Train Station Dries Van Den Berg Old Railway Houses Tshipi Borwa Mine. D3457 To Kuruman Nic Fourie Sedibeng Bulk Water Supply Point Entrance to Tshipi Borwa Mine Access to Mamatwan Mine Hotazel - Sishen Railway Line To Kathu Legend Tshipi Borwa Mine Surface Use Area Tshipi Borwa Mine Approved Mining Right Area Farm Boundaries TSHIPI E' NTLE MANGANESE MINING Figure 2 Local Setting Meters Scale: 1:60 A3 Projection: Transverse Mercator Datum: WGS1984, Lo23 SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) Fax: +27 (11) May 2017

7 ± 314 2/330 To Hotazel/ Kuruman 2/ /329 3/332 4/332 8/329 6/329 R Tailings Dam Northern Waste Rock Dump 16/331 Explosive Magazine and Emulsion Silos Haul Road Mamatwan Mine Open Pit 3/ Topsoil Stockpile Area Haul Road (4.5ha) 22 56'58.704"E 27 22'51.306"S ROM Stockpile No1 Mining Equipment Tyre Bay Workshop 8/331 Dirty Water Collection Dam (4ML) Stormwater Dam Western Waste Rock Dump 17/331 Eastern Waste Rock Dump Temporary ROM Stockpile Area Offices, Plant, Workshop and Related Infrastructure New Tyre Bay 748 Topsoil Stockpile Area No.2 Product Stockpile Area No /331 Dirty Water Dams (24ML)!!!!! 18/331 Sinter Plant and Tertiary Crushing and Screening Plant 15/ SewageTreatment Plant Railway Line 7/ Diesel Farm 0.298ha 22 58'36.746"E 27 24'16.034"S Re/700 D3457 Re/700 1/ /367 Hotazel-Sishen Railway Line 3/ To Kathu 1/367 Legend Tshipi Borwa Mine Surface Use Area Tshipi Borwa Mine Approved Mining Right Area Tshipi Borwa Mine Infrastructure Section 24G Activities Tshipi é Ntle Manganese Mining (Pty) Ltd Figure 3 Infrastructure Layout Meters Scale: 1:25 A3 Projection: Transverse Mercator Datum: WGS1984, Lo23 SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) Fax: +27 (11) June 2017

8 Page viii PUBLIC PARTICIPATION PROCESS The public participation process is ongoing. As part of this process, registered interested and affected parties (RI&APs) are given the opportunity to submit questions and comments to the project team and review the issued report. All comments that have been submitted to date by the RI&APs have been included and addressed in the environmental assessment report. Further comments arising from the environmental assessment report review process will be handled in a similar manner. IMPACTS AND MITIGATION MEASURES This report provides an assessment of the impacts of the project and provides measures to mitigate the impacts or prevent any further impacts. The potential impacts associated with the project activities and infrastructure can be categorised into those that have low, medium and high significance in the unmitigated scenario. All three categories of impacts require a measure of mitigation which, if successfully implemented will reduce the significance of the impacts and the related residual risk. The table below provides a summary of the potential impacts in no particular order of importance. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

9 Page ix TABLE 1: POTENTIAL IMPACT SUMMARY ASPECT POTENTIAL IMPACT IMPACT DISCUSSION SIGNIFICANCE WITHOUT MITIGATION Topography Soil and land capability Biodiversity Surface water and Groundwater Hazardous excavations and infrastructure resulting in safety risks to third parties and animals Loss of soil resources and land capability through contamination Loss of soil resources and land capability through physical disturbance Physical destruction of biodiversity General disturbance of biodiversity Contamination of surface water and groundwater resources Hazardous excavations and infrastructure include all structures into or off which third parties and animals can fall and be harmed. Related mitigation measures focus on infrastructure safety as well as on limiting access to third parties and animals. Soil is a valuable resource that supports a variety of ecological functions and is the key to reestablishing post closure land capability. Soil and related land capability can be compromised through pollution and through physical disturbance through compaction, removal and erosion. Related mitigation measures focus on pollution prevention, implementing soil conservation procedures and limiting site clearance to what is absolutely necessary. Areas of high ecological sensitivity are functioning biodiversity areas with species diversity and associated intrinsic value. In addition, some of these areas host protected species. The linking areas have value because of the role they play in allowing the migration or movement of flora and fauna between the areas which is a key function for the broader ecosystem. Development of the project has the potential to impact on biodiversity both through physical destruction (mainly during infrastructure establishment) and on-going physical disturbance during all project phases. Related mitigation measures focus on limiting the project footprint area and operation controls to limit ongoing disturbance. The project has the potential to contaminate surface water and groundwater resources that in some cases may be used by third parties for domestic and livestock watering purposes. Related mitigation measures focus on pollution prevention, monitoring and risk based response to identified contamination occurrences. Negligible Negligible High Medium High Medium SIGNIFICANCE WITH MITIGATION Negligible Low Low Medium Low Negligible Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

10 Page x ASPECT POTENTIAL IMPACT IMPACT DISCUSSION SIGNIFICANCE WITHOUT MITIGATION Air quality Air pollution The main contaminants associated with the project includes: inhalable particulate matter less than 10 microns in size (PM10) and larger total suspended particulates (TSP) that relate to dust fallout, and gas emissions mainly from vehicles. At certain concentrations, contaminants can have health and/or nuisance impacts. Related mitigation measures focus on pollution prevention, monitoring and risk based response to identified pollution occurrences. Traffic Road disturbance and traffic safety The project will result in an increase in traffic volumes along the R380. Potential traffic safety risks include: pedestrian accidents and vehicle accidents. Related mitigation measures focus on road and pedestrian safety. High (Medium for dust fallout) High SIGNIFICANCE WITH MITIGATION Medium (Low for dust fallout) Low Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

11 Page xi ENVIRONMENTAL STATEMENT The assessment of the project presents the potential for significant negative impacts to occur (in the unmitigated scenario in particular) on the bio-physical environment both on the project site and in the surrounding area. With mitigation these potential impacts can be prevented or reduced to acceptable levels. It follows that provided the EMPr is effectively implemented there is no environmental, social or economic reason why the project should not proceed. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

12 Page i THE TSHIPI BORWA MINE CONTENTS EXECUTIVE SUMMARY... III INTRODUCTION... I PART A SCOPE OF ASSESSMENT AND ENVIRONMENTAL IMPACT ASSESSMENT REPORT... I 1 DETAILS OF THE EAP DETAILS OF THE EAP WHO PREPARED THE REPORT EXPERTISE OF THE EAP PROPERTY DESCRIPTION PROPERTY DESCRIPTION LOCALITY MAP DESCRIPTION OF THE SCOPE OF THE ACTIVITY LISTED AND SPECIFIED ACTIVITIES DESCRIPTION OF THE ACTIVITIES UNDERTAKEN CONSTRUCTION HAUL ROAD DIESEL FARM DECOMMISSIONING AND CLOSURE POLICY AND LEGISLATIVE CONTEXT NEED AND DESIRABILITY OF THE ACTIVITY ECOLOGICAL SUSTAINABLE DEVELOPMENT AND USE OF NATURAL RESOURCES PROMOTING JUSTIFIABLE ECONOMIC AND SOCIAL DEVELOPMENT MOTIVATION FOR THE PREFERRED DEVELOPMENT FOOTPRINT ON THE SITE INCLUDING THE PROCESS FOLLOWED TO DEFINE THE PREFERRED DEVELOPMENT ALTERNATIVES DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED THE NO-GO ALTERNATIVE DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED REGISTERED INTERESTED AND AFFECTED PARTY DATABASE LANDOWNER AND OCCUPIER NOTIFICATIONS RELEVANT AUTHORITY NOTIFICATIONS NOTICE BOARDS AND ADVERTISEMENTS NOTIFICATION OF OTHER RI&APS COMMENTING ON THE DRAFT ENVIRONMENTAL ASSESSMENT REPORT PUBLIC COMMENT ON ENVIRONMENTAL ASSESSMENT REPORT AUTHORITY COMMENT ON ENVIRONMENTAL ASSESSMENT REPORT SUMMARY OF ISSUES RAISED BY RI&APS ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH THE PROJECT AND ALTERNATIVES BASELINE ENVIRONMENT AFFECTED BY THE ACTIVITY GEOLOGY TOPOGRAPHY CLIMATE SOIL Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

13 Page ii LAND CAPABILITY BIODIVERSITY SURFACE WATER GROUNDWATER AIR QUALITY NOISE VISUAL ASPECTS TRAFFIC HERITAGE/CULTURAL AND PALAEONTOLOGICAL RESOURCES SOCIO-ECONOMIC CURRENT LAND USES DESCRIPTION OF SPECIFIC ENVIRONMENTAL FEATURES AND INFRASTRUCTURE ON THE SITE ENVIRONMENT AND CURRENT LAND USE MAP ENVIRONMENTAL IMPACTS AND RISKS OF THE ALTERNATIVES METHODOLOGY USED IN DETERMINING THE SIGNIFICANCE OF ENVIRONMENTAL IMPACTS POSITIVE AND NEGATIVE IMPACTS OF THE ACTIVITY AND ALTERNATIVES POSSIBLE MITIGATION MEASURES THAT COULD BE APPLIED AND THE LEVEL OF RESIDUAL RISK MOTIVATION WHERE NO ALTERNATIVE SITES WERE CONSIDERED STATEMENT MOTIVATING THE PREFERRED ALTERNATIVE FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY, ASSESS AND RANK THE IMPACTS AND RISKS THE ACTIVITY WILL IMPOSE ON THE PREFERRED SITE THROUGH THE LIFE OF THE ACTIVITY DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY IMPACTS DESCRIPTION OF THE PROCESS UNDERTAKEN TO ASSESS AND RANK THE IMPACTS AND RISKS A DESCRIPTION OF THE ENVIRONMENTAL IMPACTS AND RISKS IDENTIFIED DURING THE ENVIRONMENTAL ASSESSMENT PROCESS ASSESSMENT OF THE SIGNIFICANCE OF EACH IMPACT AND RISK AND AN INDICATION OF THE EXTENT TO WHICH THE ISSUE AND RISK CAN BE AVOIDED OR ADDRESSED BY THE ADOPTION OF MITIGATION MEASURES ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND RISK SUMMARY OF SPECIALIST REPORT FINDINGS ENVIRONMENTAL IMPACT STATEMENT SUMMARY OF KEY FINDINGS OF THE EIA FINAL SITE MAP SUMMARY OF THE POSITIVE AND NEGATIVE IMPLICATIONS AND RISKS OF THE ACTIVITY AND IDENTIFIED ALTERNATIVES IMPACT MANAGEMENT OBJECTIVES AND OUTCOMES FOR INCLUSION IN THE EMPR PROPOSED MANAGEMENT OBJECTIVES AND OUTCOMES FOR ENVIRONMENTAL AND SOCIO-ECONOMIC IMPACTS IMPACTS THAT REQUIRE MONITORING PROGRAMMES ACTIVITIES AND INFRASTRUCTURE MANAGEMENT ACTIONS ROLES AND RESPONSIBILITIES FINAL PROPOSED ALTERNATIVES ASPECTS FOR INCLUSION AS CONDITIONS OF THE AUTHORISATION ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

14 Page iii 14.1 ENVIRONMENTAL ASSESSMENT LIMIT PREDICTIVE MODELS IN GENERAL BIODIVERSITY AIR QUALITY TRAFFIC IMPACT ASSESSMENT HERITAGE/ CULTURAL AND PALAEONTOLOGICAL RESOURCES REASONED OPINION AS TO WHETHER THE ACTIVITY SHOULD OR SHOULD NOT BE AUTHORISED REASONS WHY THE ACTIVITY SHOULD BE AUTHORIZED OR NOT CONDITIONS THAT MUST BE INCLUDED IN THE AUTHORISATION SPECIFIC CONDITIONS FOR INCLUSION IN THE EMPR REHABILITATION REQUIREMENTS PERIOD FOR WHICH AUTHORISATION IS REQUIRED UNDERTAKING FINANCIAL PROVISION METHOD TO DERIVE THE FINANCIAL PROVISION CONFIRM THAT THE AMOUNT CAN BE PROVIDED FOR FROM OPERATING EXPENDITURE DEVIATIONS FROM SCOPING REPORT AND APPROVED PLAN OF STUDY DEVIATION FROM THE METHODOLOGY USED IN DETERMINING THE SIGNIFICANCE OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS MOTIVATIONS FOR DEVIATION SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A) AND (B) OF THE ACT PART B ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT... II 22 DETAILS OF THE EAP DESCRIPTION OF THE ASPECTS OF THE ACTIVITY COMPOSITE MAP DESCRIPTION OF THE IMPACT MANAGEMENT OBJECTIVES INCLUDING MANAGEMENT STATEMENT DETERMINATION OF CLOSURE OBJECTIVES THE PROCESS FOR MANAGING ENVIRONMENTAL DAMAGE AS A RESULT OF UNDERTAKING THE ACTIVITY POTENTIAL RISK OF ACID MINE DRAINAGE STEPS TAKEN TO INVESTIGATE, ASSESS AND EVALUATE THE IMPACT OF ACID MINE DRAINAGE ENGINEERING OR MINE DESIGN SOLUTIONS TO AVOID OR REMEDY ACID MINE DRAINAGE MEASURES IN PLACE TO REMEDY RESIDUAL OR CUMULATIVE IMPACT FROM ACID MINE DRAINAGE VOLUMES AND RATE OF WATER USE FOR MINING HAS A WATER USE LICENCE BEEN APPLIED FOR? IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES IMPACT MANAGEMENT OUTCOMES IMPACT MANAGEMENT ACTIONS FINANCIAL PROVISION DETERMINATION OF THE AMOUNT OF THE FINANCIAL PROVISION DESCRIPTION OF THE CLOSURE OBJECTIVES AND THE ALIGNMENT WITH THE BASELINE ENVIRONMENT Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

15 Page iv CONFIRMATION THAT THE CLOSURE OBJECTIVES HAVE BEEN CONSULTED WITH LANDOWNERS AND I&APS REHABILITATION PLAN COMPATIBILITY OF THE REHABILITATION PLAN WITH THE CLOSURE OBJECTIVES CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION CONFIRMATION THAT THE FINANCIAL PROVISION WILL BE PROVIDED MECHANISMS FOR MONITORING COMPLIANCE AND PERFORMANCE AGAINST THE EMPR FREQUENCY OF PERFORMANCE ASSESSMENT REPORT ENVIRONMENTAL AWARENESS PLAN MANNER IN WHICH APPLICANT INTENDS TO INFORM EMPLOYEES OF THE ENVIRONMENTAL RISKS ENVIRONMENTAL POLICY STEPS TO ACHIEVE THE ENVIRONMENTAL POLICY OBJECTIVES TRAINING OBJECTIVES OF THE ENVIRONMENTAL AWARENESS PLAN GENERAL CONTENTS OF THE ENVIRONMENTAL AWARENESS PLAN MANNER IN WHICH RISKS WILL BE DEALT WITH TO AVOID POLLUTION OR DEGRADATION ON-GOING MONITORING AND MANAGEMENT MEASURES PROCEDURES IN CASE OF ENVIRONMENTAL EMERGENCIES GENERAL EMERGENCY PROCEDURE IDENTIFICATION OF EMERGENCY SITUATIONS TECHNICAL, MANAGEMENT AND FINANCIAL OPTIONS SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY UNDERTAKING REFERENCES... A LIST OF FIGURES FIGURE 1: REGIONAL SETTING... V FIGURE 2: LOCAL SETTING... VI FIGURE 3: INFRASTRUCTURE LAYOUT... VII FIGURE 4: APPROVED INFRASTRUCTURE LAYOUT (METAGO, MAY 2009) FIGURE 5: GENERAL STRATIGRAPHIC COLUMN FOR THE KALAHARI MANGANESE FIELD (SLR, MARCH 2014) FIGURE 6: PERIOD, DAYTIME AND NIGHT-TIME WIND ROSES FIGURE 7: SEASONAL WIND ROSES FIGURE 8: VEGETATION TYPES (EMS, FEBRUARY 2017) FIGURE 9: CATCHMENT FIGURE 10: LAND USE MAP FIGURE 11: MONITORING PROGRAMME LIST OF TABLES TABLE 1: POTENTIAL IMPACT SUMMARY... IX TABLE 2: DETAILS OF THE EAPS TABLE 3: DESCRIPTION OF THE PROPERTY TABLE 4: LIST OF ACTIVITIES/INFRASTRUCTURE ASSOCIATED WITH THE PROJECT TABLE 5: DESCRIPTION OF THE LISTED ACTIVITIES APPLIED FOR AS PART OF THE PROJECT TABLE 6: LEGAL FRAMEWORK TABLE 7: EIA AND EMPR REPORT REQUIREMENTS Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

16 Page v TABLE 8: SUMMARY OF MONTHLY RAINFALL DATA (SLR, OCTOBER 2015) TABLE 9: FIVE GREATEST DEPTH OF RAINFALL RECORDED AT THE WINTON WEATHER STATION (SLR, OCTOBER 2015) TABLE 10: WETTEST PERIODS RECORDED ON CONSECUTIVE DAYS (SLR, OCTOBER 2015) TABLE 11: SUMMARY OF EVAPORATION DATA (SLR, OCTOBER 2015) TABLE 12: MONTHLY TEMPERATURE DATA (AIRSHED, SEPTEMBER 2015) TABLE 13: DESCRIPTION OF VEGETATION TYPES (EMS, FEBRUARY 2017) TABLE 14: SPECIES OF CONCERN LIKELY TO OCCUR AT THE TSHIPI BORWA MINE (EMS, JANUARY 2017) TABLE 15: ALIEN INVASIVE SPECIES LIKELY TO OCCUR AT THE TSHIPI BORWA MINE (EMS, JANUARY 2017) TABLE 16: RED DATA MAMMALS LIKELY TO OCCUR AT THE TSHIPI BORWA MINE (EMS, JANUARY 2017) TABLE 17: RED DATA AVIFAUNAL SPECIES LIKELY TO OCCUR AT THE TSHIPI BORWA MINE (EMS, JANUARY 2017) TABLE 18: CHATCHMENT CHARACTERISTICS (METAGO, MAY 2009) TABLE 19: DETAILS OF GROUNDWATER MONITOING POINTS (SLR, OCTOBER 2016) TABLE 20: GROUNDWATER QUALITY MONITORING RESULTS (SLR, 2016) TABLE 21: DUST FALLOUT MONITORING DATA (BOLETSHE, MARCH 2017) TABLE 22: MANUAL TRAFFIC COUNTS (SIYAZI, MAY 2017) TABLE 23: SOCIO ECONOMIC PROFILE - POPULATION TABLE 24: SOCIO-ECONOMIC PROFILE TOILET FACILITIES TABLE 25: SOCIO-ECONOMIC PROFILE POTABLE WATER ACCESS TABLE 26: SOCIO-ECONOMIC PROFILE REFUSE REMOVAL TABLE 27: SOCIO-ECONOMIC PROFILE EDUCATION TABLE 28: SOCIO-ECONOMIC PROFILE EMPLOYMENT TABLE 29: LAND OWNERSHIP WITHIN THE SURFACE USE AREA TABLE 30: LANDOWNERS ADJACENT TO THE SURFACE USE AREA TABLE 31: CRITERIA FOR ASSESSING IMPACTS TABLE 32: LIST OF IMPACTS AS THEY RELATE TO PROJECT ACTIONS / ACTIVITIES / PROCESSES TABLE 33: ASSESSMENT OF SIGNIFICANT IMPACTS AND RISKS TABLE 34: SUMMARY OF SPECIALIST REPORTS TABLE 35: SUMMARY OF POTENTIAL IMPACTS TABLE 36: ENVIRONMENTAL OBJECTIVES AND OUTCOMES TABLE 37: MEASURES TO REHABILITATE THE ENVIRONMENT AFFECTED BY THE LISTED ACTIVITIES TABLE 38: DESCRIPTION OF IMPACT MANAGEMENT OUTCOMES TABLE 39: DESCRIPTION OF IMPACT MANAGEMENT ACTIONS TABLE 40: WASTE MANAGEMENT PROCEDURES FOR GENERAL AND HAZARDOUS WASTE TABLE 41: SOIL MANAGEMENT PRINCIPLES TABLE 42: MONITORING OF COMPLIANCE AND PERFORMANCE IN TERMS OF EMPR TABLE 43: EMERGENCY RESPONSE PROCEDURES LIST OF APPENDICES APPENDIX A: PROOF OF EAP QUALIFICATIONS... A APPENDIX B: CURRICULUM VITAE OF EAP... B APPENDIX C: LOCAL AND REGIONAL SETTING...C APPENDIX D: SITE LAYOUT...D Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

17 Page vi APPENDIX E: PUBLIC PARTICIPATION DOCUMENTS... E APPENDIX F: IMPACT RATING FOR EACH POTENTIAL IMPACT... F APPENDIX G: COMPOSITE MAP... G APPENDIX H: NEMA LISTED ACTIVITIES APPROVED IN TERMS OF THE EA...H APPENDIX I: SOILS AND LAND CAPABILITY INPUT... I APPENDIX J: BIODIVERSITY INPUT... J APPENDIX K: AIR QUALITY INPUT... K APPENDIX L: TRAFFIC ASSESSMENT... L APPENDIX M: HERITAGE INPUT AND PALAEONTOLOGICAL STUDY... M APPENDIX N: SOIL OPINION...N Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

18 Page vii ACRONYMS AND ABBREVIATIONS ACRONYMS / DEFINITION ABBREVIATIONS ADEs Aquifer Dependent Ecosystems CBA Critical Biodiversity Areas DEA Department of Environmental Affairs DAFF Department of Agriculture, Forestry and Fisheries DALA Department of Agriculture and Land Affairs DEA Department of Environmental Affairs DENC Department of Environment and Nature Conservation DMR Department of Mineral Resources DPWRT Department of Public Works, Roads and Transport DRDLR Department of Rural Development and Land Reform DRU Daily Rainfall Extraction Utility DWA Department of Water Affairs DWS Department of Water and Sanitation EA Environmental Authorisation EAP Environmental Assessment Practitioner EIA Environmental Impact Assessment EMPr Environmental Management Programme EMS Ecological Management Services GG Government Gazette GNR General Notice Regulation ha Hectares HDSA Historically Disadvantaged South African I&Aps Interested and / or affected parties IDP Integrated Development Plan IUCN International Union for Conservation of Nature IWUL Integrated Water Use License JMLM Joe Morolong Local Municipality JTGDM John Taolo Gaetsewe District Municipality km Kilometres kv Kilovolts LED Local Economic Development m Metres mamsl Metres above mean sea level mcm Million cubic metres Ml Megalitres mm Milimetres MPRDA Mineral and Petroleum Resources Development Act No 28 of 2002 MW Megawatt NAAQS South African daily National Ambient Air Quality Standards NCNCA Northern Cape Nature Conservation Act No 9 of 2009 NDCR South African National Dust Control Regulations NEMA National Environmental Management Act No 107 of 1998 NEMBA National Environmental Management: Biodiversity Act No 10 of 2004 NFEPA National Freshwater Ecosystem Priority Areas 2011 NPAES National Protected Areas Expansion Strategy 2008 NWA National Water Act No 36 of 1998 PPE Personal Protective Equipment Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

19 Page viii ACRONYMS / ABBREVIATIONS RI&APs ROM SACNSP SAHRA SANBI SANS SDF SLR SLP SMS TDS Tshipi DEFINITION Registered interested and affected parties Run of mine South African Council for Natural Scientific Professionals South African Heritage Resources Agency South African National Botanical Institute South African National Standards Spatial Development Framework SLR Consulting (Africa) (Pty) Ltd Social and Labour Plan Short Message Service Total Dissolved Solids Tshipi é Ntle Manganese Mining (Pty) Ltd Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

20 Page i THE TSHIPI INTRODUCTION BORWA MINE INTRODUCTION TO THE PROJECT Tshipi operates the Tshipi Borwa Mine, an opencast manganese mine located on the farms Mamatwan 331 (mining right and surface use areas) and Moab 700 (surface use area), approximately 20km to the south of Hotazel in the John Taolo Gaetsewe District Municipality and the Joe Morolong Local Municipality in the Northern Cape Province. The mine location is illustrated in Figure 1 and Figure 2. The mine holds a mining right (NC/30/5/1/2/2/0206MR) and an EMPr issued and approved by the Department of Minerals and Energy (currently the DMR), an EA (NC/KGA/KATHU/37/2008) issued by the DTEC (currently the DENC) and an IWUL (10/D41K/AGJ/1735) issued by the Department of Water Affairs (currently the DWS). In terms of environmental law, the approved EMPr is now deemed to be an EA issued in terms of NEMA. Certain activities at the Tshipi Borwa Mine commenced without environmental authorisation in terms of NEMA. These activities were the establishment of a diesel farm consisting of above ground tanks and underground pipelines, and widening of a haul road located on the eastern boundary of the surface use area (See Figure 3). Under the NEMA the unlawful commencement of activities may be authorised through an application for rectification made in terms of section 24G of NEMA. SLR Africa, an independent firm of consultants, has been appointed by Tshipi as the independent EAP responsible for undertaking the section 24G application process. This report describes the environmental assessment and public participation process followed. LEGAL FRAMEWORK For the continuation of the activities, environmental authorization is required from the DMR in terms of the NEMA. The applicable list of activities is provided in Section 3.1 (Table 4) of this report. In the absence of regulations governing a section 24G process, this assessment report has been compiled in accordance with the requirements of section 24G of the NEMA and the DMR EIA and EMPr Report template format (as informed by the guidelines posted on the official DMR website). The public participation process has been undertaken in line with the EIA Regulations, This legal framework does not cover occupational health and safety legislation requirements. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

21 Page ii OTHER APPROVALS / PERMITS Other than the amendment of the EMPr which is required to cater for changes to the approved infrastructure layout at the site, no other approvals/permits are needed for the project at this stage. This does not cover occupational health and safety legislation requirements. ENVIRONMENTAL ASSESSMENT REPORTING PHASE OBJECTIVES The objectives of the environmental assessment process are as follows: to identify policies and legislation relevant to the project; to describe the need and desirability of the activities; to describe the activities; to provide an assessment of the environmental and social impacts of the activities; to describe mitigation measures undertaken or to be undertaken including the residual risks that need to be managed and monitored; to describe the public participation process followed and indicate how any issues raised have been addressed; and to provide an EMPr. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

22 Page i PART A SCOPE OF ASSESSMENT AND ENVIRONMENTAL IMPACT ASSESSMENT REPORT Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

23 Page DETAILS OF THE EAP 1.1 DETAILS OF THE EAP WHO PREPARED THE REPORT The details of the EAPs that were involved in the preparation of this environmental assessment report are provided in Table 2 below. TABLE 2: DETAILS OF THE EAPS DETAILS PROJECT MANAGER AND AUTHOR REVIEWER Name of the practitioner Marline Medallie Alex Pheiffer Tel No.: Fax No.: address mmedallie@slrconsulting.com - Neither SLR nor any of the specialists involved in the environmental assessment process have any interest in the project other than fair payment for consulting services rendered as part of the environmental assessment process. 1.2 EXPERTISE OF THE EAP Marline Medallie holds a Master's Degree and has over 9 years of relevant experience in the assessment of impacts associated with mining operations. Alex Pheiffer has over 16 years of relevant experience and is registered as a Professional Natural Scientist (PrSciNat) in Environmental Science with the South African Council for Natural Scientific Professions. Both Alex and Marline have been involved in several impact assessments for large scale mining developments in South Africa. Proof of registrations of the relevant practitioners is provided in Appendix A and relevant curricula vitae are attached in Appendix B. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

24 Page PROPERTY DESCRIPTION 2.1 PROPERTY DESCRIPTION A description of the property on which the activities are located is provided in Table 3. TABLE 3: DESCRIPTION OF THE PROPERTY DESCRIPTOR Farm Name Application area (Ha) Magisterial district Distance and direction from nearest town 21 digit Surveyor General Code for each farm portion DETAIL Mamatwan 331 (portions 16 and 17) Haul road Mamatwan 331 (portion 18) Diesel farm The area of disturbance is approximately 4.798ha (4.5ha for haul road and 0.298ha for diesel farm). Located within the Kuruman Magisterial District and in the John Taolo Gaetsewe District Municipality. The closest towns are Hotazel and Black Rock, located approximately 20km north and 26km north west of the Tshipi Borwa Mine, respectively. 21 DIGIT CODE FARM PORTION CO Mamatwan 331 portion 16 CO Mamatwan 331 portion 17 CO Mamatwan 331 portion LOCALITY MAP The regional and local setting of the project site is illustrated in Figure 1 and Figure 2. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

25 Page DESCRIPTION OF THE SCOPE OF THE ACTIVITY An infrastructure plan of the project, showing the location, coordinates and extent of the activities is detailed in Table 4 and illustrated in Figure LISTED AND SPECIFIED ACTIVITIES Tshipi Borwa Mine operates in accordance with an EA (NC/KGA/KATHU/37/2008) issued by the DTEC (currently the DENC). Activities that were authorised as part of the approved EIA and EMPr (Metago, May 2009) were in accordance with the NEMA EIA Regulations, 2006 (GNR 385 under GG of July 2006). Refer to Appendix H for the list of the activities authorised in terms of the EA for the project. The activities and infrastructure associated with the project are listed in Table 4 below and are illustrated in Figure 3. In each case the relevant NEMA listed activities which have been triggered by the project has been provided in Table 4. A description of each of the listed activities identified is provided in Table 5. At the time of establishing the diesel farm and haul road, environmental authorisation was required under the NEMA EIA Regulations, 2010 (GNR 543 under GG of 2 August 2010) as included in the table below. Given that the EIA Regulations, 2010 have been repealed, the corresponding/similarly listed activities under the EIA Regulations, 2014 (GNR 982 under GG of 4 December 2014) as amended, are also included in the table below. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

26 Page 3-2 TABLE 4: LIST OF ACTIVITIES/INFRASTRUCTURE ASSOCIATED WITH THE PROJECT DESCRIPTION OF ACTIVITY AERIAL EXTENT OF THE ACTIVITY (HA) LISTED ACTIVITY Site preparation Selective clearing of vegetation in areas designated for surface infrastructure, stripping and stockpiling of soil resources, bulldozing, excavations and foundations. Approximately (~) 4.798ha (including haul road ~ 4.5ha; diesel farm ~0.298ha). N/A LISTED ACTIVITY NUMBER AND APPLICABLE LISTING NOTICE Not applicable, approved in 2009 EMPr. Haul road Widening of existing gravel haul road. ~ 4.5ha X NEMA: GNR 983 (Activity 56); NEMA: GNR 544 (Activity 47). Diesel storage and handling Establishment of diesel farm including above ground storage tanks with capacity of up to litres (996m 3 ). ~ 0.298ha. X NEMA: GNR 983 (Activity 51); NEMA: GNR 544 (Activity 42). Transportation of fuel via underground pipelines. ~5 ha. X NEMA: GNR 983 (Activity 60) NEMA: GNR 544 (Activity 49) General site management Site management (contractors, monitoring, inspections, Not applicable. N/A Not applicable. maintenance, security, access control), environmental awareness training and emergency response and implementing and maintaining management plans. Demolition Dismantling and demolition of infrastructure and equipment. Within the project footprint described above. N/A Not applicable. Utilisation of approved supporting services. Rehabilitation Rehabilitation of disturbed areas in line with the mine s approved EMPr ha N/A Not applicable. Maintenance and aftercare Aftercare and maintenance of rehabilitated areas in line with the mine s approved EMPr ha. N/A Not applicable. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

27 Page 3-3 TABLE 5: DESCRIPTION OF THE LISTED ACTIVITIES APPLIED FOR AS PART OF THE PROJECT ACTIVITY NUMBER LISTED ACTIVITY ACTIVITY NUMBER LISTED ACTIVITY NEMA LISTING NOTICE 1 GNR.544 NEMA LISTING NOTICE 1 GNR.983, AS AMENDED GNR 544 List 1 Activity 42: The expansion of facilities for the storage, or storage and handling, of a dangerous good, where the capacity of such GNR 983 List 1 Activity 51: The expansion and related operation of facilities for the storage, or storage and handling, of a dangerous good, where the capacity of such GNR 544 List 1 Activity 47: GNR 544 List 1 Activity 49: storage facility will be expanded by 80 cubic meters or more. The widening of a road by more than 6 meters, or the lengthening of a road by more than 1 kilometer- (i) where the existing reserve is wider than 13,5 meters; or (ii) where no reserve exists, where the existing road is wider than 8 meters The expansion of facilities or infrastructure for the bulk transportation of dangerous goods: (ii) in liquid form, outside an industrial complex or zone, by an increased throughput capacity of 50 cubic meters or more per day; of GNR 983 List 1 Activity 56: GNR 983 List 1 Activity 60: storage facility will be expanded by more than 80 cubic metres. The widening of a road by more than 6 metres, or the lengthening of a road by more than 1 kilometre (i) where the existing reserve is wider than 13.5 metres; or (ii) where no reserve exists, where the existing road is wider than 8 metres; The expansion and related operation of facilities or infrastructure for the bulk transportation of dangerous goods - in liquid form, outside an industrial complex or zone, by an increased throughput capacity of 50 cubic metres or more per day; Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

28 Page DESCRIPTION OF THE ACTIVITIES UNDERTAKEN The project involves facilities that were established to support the opencast mining of manganese at the Tshipi Borwa Mine. These included the widening of an existing gravel haul road and establishment of a diesel farm and pipeline network. The project has an estimated surface area of disturbance of ~ 4,798ha, which includes ~4.5ha for the widening of a haul road and 0.298ha for the establishment of a diesel farm. Information provided in the following section was provided to SLR by the Tshipi project team. For completeness, and where required, relevant information from the approved EIA and EMPr (Metago, May 2009) has also been included and/or referenced CONSTRUCTION The activities being applied for took place after construction of the mine had been completed. The Tshipi Borwa Mine is in the operational stage. Construction activities that took place for the project included: Clearing of vegetation; Stripping and stockpiling of soil resources and related earthworks; Sourcing and transportation of materials for construction; Digging and establishing foundations and trenches; Laying pipelines; Installation of equipment and infrastructure; and General building activities. Existing services and support infrastructure established as part of the mine were used to support the widening of the haul road and establishment of the diesel farm and pipeline network. These included: Contractor facilities including ablution and change houses; Access roads and security access points; Internal gravel haul roads; Water supply; Power supply; Non-mineralised waste handling and management. No additional facilities or services were needed. Construction consisted of 1 shift per day from 07h00 to 17h00 from Monday to Fridays. Saturdays consisted of a half shift from 07h00 to 15h00. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

29 Page 3-5 Construction commenced towards the end of 2013 and took approximately 4 months to complete HAUL ROAD The widened haul road was previously an 8m wide gravel farm road located along the western boundary of the mine s surface use area (Figure 4). A section of this gravel road was widened to approximately 25m by Tshipi. This specific section of the existing gravel road was widened to cater for mine related traffic travelling to and from the explosives magazine and emulsion silos (Figure 3). Given the hazardous nature of explosives and emulsion, it was decided by the mining development that for safety reasons, trucks transporting this material/substances should avoid travelling through areas that are actively associated with mining operations. This haul road would continue to be used for this purpose. The haul road is constructed from suitably sized and compacted waste rock. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

30 ± To Hotazel/ Kuruman R380 Explosive Magazine 78ML Stormwater Dam Return Water Dam Northern Waste Rock Dump Mamatwan Mine Tailings Dam Stormwater Dam (Settling Dam) Topsoil Stockpile Open Pit Offices, Plant, Workshop and Related Infrastructure Stormwater Dam Western Waste Rock Dump. Low Grade Stockpiles 8m Wide Gravel Road Substation Fines Stockpile Sewage Treatment Plant Sinter Plant and Tertiary Crushing and Screening Plant Stormwater Dam Diesal Storage Facility Offices, Plant, Workshop and Related Infrastructure Railway Siding D3457 Hotazel-Sishen Railway Line To Kathu Legend Tshipi Borwa Mine Approved Infrastructure Tshipi Borwa Mine Approved Mining Right Area Tshipi Borwa Mine Surface Use Area TSHIPI E' NTLE MANGANESE MINING Figure 4 Approved Infrastructure Layout (Metago, May 2009) Meters Scale: 1:25 A3 Projection: Transverse Mercator Datum: WGS1984, Lo23 SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) Fax: +27 (11) May 2017

31 Page DIESEL FARM The EA, read together with the EMPr, authorises the storage of a total of litres (500m 3 ) of diesel at the mine, distributed across a number of satellite/mobile diesel sites located within the offices, plant and workshop area (Figure 4). This storage capacity was to be housed primarily in a main diesel farm and then transported via underground pipelines to re-fuelling stations at the offices, plant and workshop areas to reduce the number of trucks transporting diesel to the various satellite diesel facilities. The diesel farm was partially constructed following approval of the EA, but due to an undersupply of electricity, Tshipi decided to expand the storage capacity of the diesel farm to litres (996m 3 ) in late 2013 / early It is important to note that no diesel has been stored in the facility since its establishment. The diesel farm is located near the entrance of the mine adjacent to the railway loop (Figure 3) and consists of a series of above ground tanks that are completely enclosed, on an impermeable substrate and surrounded by a perimeter bund wall. It is understood from Tshipi that some of the underground pipelines supplying the refuelling stations have been partially installed and installation thereof will need to be completed. Initially a short term increase of 27 diesel trucks over a period of 2 weeks with a capacity to load 37,000l is required to fill the diesel farm. Thereafter the diesel farm will be re-filled via ten trucks per week. Any contaminated soil from accidental spills at the diesel farm would be handled in terms of the mine s waste management system. In this regard contaminated soil would be collected and temporarily stored in designated drums at the mine s salvage yard, scrap yard or the designated temporary waste storage area for treatment at the mine s on-site bioremediation facility or removal by contractors for disposal as hazardous waste. As with the existing mine, the activities will be in operation 24 hours a day for seven days a week and will remain on site for the duration of the mining operations. The anticipated life of mine is 20 years. The mine has been operational for seven years DECOMMISSIONING AND CLOSURE The haul road and diesel farm (including pipeline network) will be decommissioned as part of the overall mining operation. The approved EIA and EMPr (Metago, May 2009) noted the environmental objective is to restore the pre-mining potential of the land, wilderness and grazing land. In order to achieve this objective, the conceptual closure activities associated with the project include the following: Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

32 Page 3-8 Dismantling and demolishing of infrastructure and equipment. Utilisation of site support services. Replacing topsoil resources. Rehabilitation of the disturbed areas where infrastructure has been removed by sloping, filling in excavations, re-vegetating, and erosion control. Landscaping and re-vegetation of disturbed areas and where infrastructure was removed. Ensure that vegetation on rehabilitated areas is sustainable. Removal of alien and invasive species from rehabilitated sites. An overview of the closure activities that will take place on site during the closure phase include the following: Initiate aftercare and maintenance programme. There will be a period of active after-care followed by a passive after-care phase. Maintenance of facilities such as fencing, fire breaks, access roads and rehabilitated areas. Removal of any invasive species from the rehabilitated sites. Inspecting on an annual basis to repair any erosion gullies. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

33 Page POLICY AND LEGISLATIVE CONTEXT This section outlines the key legislative requirements applicable to the project. The table below provides a summary of the applicable legislative context and policy. TABLE 6: LEGAL FRAMEWORK APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED HOW DOES THIS DEVELOPMENT COMPLY WITH AND RESPOND TO THE POLICY AND LEGISLATIVE CONTEXT NEMA Table 7 An application for a section 24G rectification EIA Regulations (GNR 982, GNR 983 Table 7 in accordance with NEMA has been (Listing Notice 1), GNR 984 (Listing Notice submitted to the DMR. The NEMA 2), and GNR 985 (Listing Notice 3) under GG application was accepted on of 2014) as amended in terms of 27 February 2017 by the DMR. A copy of the NEMA application form and acceptance letter is attached in Appendix E. Department of Environmental Affairs (2017), Public Participation guideline in terms of NEMA EIA Regulations Guideline on the need and desirability in terms of the EIA Regulations, 2010 (GNR. 891 of 2014) Section 6.2 Section 5 The public participation process has taken these guidelines into account. Need and desirability has been taken into account as part of project planning. National Forest Act No. 84 of 1998 (NFA) Section Biodiversity has been taken into account as Northern Cape Nature Conservation Act No. part of the EIA. 9 of 2009 (NCNCA) National Veld and Forest Fire Act No. 101 of 1998 International Union for Conservation of Nature (IUCN) National Environmental Management: Biodiversity Act No. 10 of 2004 (NEM:BA) South African National Botanical Institute (SANBI) Integrated Biodiversity Information National Freshwater Ecosystem Priority Areas 2011 (NFEPA) National Protected Areas Expansion Strategy 2008 (NPAES) Section Section Section Section Section Biodiversity has been taken into account as part of the EIA. Biodiversity has been taken into account as part of the EIA. Biodiversity has been taken into account as part of the EIA. Biodiversity has been taken into account as part of the EIA. Biodiversity has been taken into account as part of the EIA. Biodiversity has been taken into account as part of the EIA. National Biodiversity Assessment Section Biodiversity has been taken into account as part of the EIA. Mining and Biodiversity Guideline (Department of Environmental Affairs (DEA) et al, 2013) Section Biodiversity has been taken into account as part of the EIA. South African Bird Atlas Project Section Biodiversity has been taken into account as Important Bird Areas part of the EIA. DWS Resources Quality Information Services (RQIS) Conservation of Agricultural Resources Act No. 43 of 1983 (CARA) NEM:BA Alien and Invasive Species Regulations (2014) John Taolo Gaetsewe District Municipality Spatial Development Framework Joe Morolong Local Municipality Integrated Development Framework Section Section , 27 & 29 Section 5. Section Biodiversity has been taken into account as part of the EIA. Identification of alien invasive species. Land planning has been taken into account as part of the EIA. Land planning has been taken into account as part of the EIA. National Heritage Resource Act No. 25 of Section and 27 Heritage has been taken into account as part Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

34 Page 4-2 APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT REFERENCE WHERE APPLIED 1999 of the EIA. National Atmospheric Emission Reporting Section 27 and 29 Regulations in terms of the National Environmental Management: Air Quality Act 39 of 2004 (the Reporting Regulations) South African National Dust Control Regulations (NDCR) The South African National Ambient Air Quality Standards (NAAQS) Spatial Planning and Land Use Management Act No. 16 of 2013 Section Section Section 27 HOW DOES THIS DEVELOPMENT COMPLY WITH AND RESPOND TO THE POLICY AND LEGISLATIVE CONTEXT Registration on the National Emissions Inventory System Monitoring regulations were taken into consideration. Monitoring regulations were taken into consideration. Land planning has been taken into account as part of the EIA. This document has been prepared in accordance with the DMR EIA and EMPr Report template format, and was informed by the guidelines posted on the official DMR website. In addition, this report complies with the requirements of section 24G of the NEMA. The table below provides a summary of the requirements, with cross references to the report sections where these requirements have been addressed. TABLE 7: EIA AND EMPR REPORT REQUIREMENTS EIA/EMPR REPORT REQUIREMENTS AS PER THE DMR TEMPLATE ENVIRONMENTAL ASSESSMENT REPORT REQUIREMENTS AS PER SECTION 24G OF NEMA REFERENCE IN THE EIA/EMPR REPORT Part A of DMR report template Section 24G (vii) Section/Appendix a) i) Details of the EAP who Section 1.1 prepared the report a) ii) Expertise of the EAP Section 1.1 and Appendix B b) Description of the property Section 2 c) Locality map Section 2.2 d) Description of the scope of the Section 3.1 proposed overall activity i) Listed and specified activities d) ii) Description of the activities to Section 3.2 be undertaken e) Policy and legislative context Section 4 f) Need and desirability of the proposed activity g) Motivation for the preferred development footprint within the approved site including g) i) Details of the development footprint alternatives considered (aa) a description of the need and desirability of the activity; Section 5 Section 6 Section 6.1 Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

35 Page 4-3 EIA/EMPR REPORT REQUIREMENTS AS PER THE DMR TEMPLATE g) ii) Details of the public participation process followed g) iii) Summary of issues raised by IAPs g) iv) Environmental attributes associated with the development footprint alternatives g) v) Impacts and risks identified including the nature, significance, consequence, extent, duration and probability of the impacts including the degree of the impacts g) vi) Methodology used in determining the nature, significance, consequence, extent, duration and probability of potential environmental impacts and risks. g) vii) The positive and negative impacts that the proposed activity (in terms of the initial site layout) and alternative will have on the environment and the community that may be affected. g) viii) The possible mitigation measures that could be applied and the level of risk g) ix) Motivation where no alternative sites were considered g) x) Statement motivating the alternative development location within the overall site h) 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) through the life of the activity i) Assessment of each identified potentially significant impact and risk ENVIRONMENTAL ASSESSMENT REPORT REQUIREMENTS AS PER SECTION 24G OF NEMA (dd) a description of the public participation process followed during the course of compiling the report, including all comments received from interested and affected parties and an indication of how the issues raised have been addressed; (cc) a description of mitigation measures undertaken or to be undertaken in respect of the consequences for or impacts on the environment of the activity; (bb) an assessment of the nature, extent, duration and significance of the consequences for or impacts on the environment of the activity, including the cumulative effects and the manner in which the geographical, physical, biological, social, economic REFERENCE IN THE EIA/EMPR REPORT Section 6.2 Section 6.3 Section 6.4 Section 6.5 Section 6.6 Section 6.7 Section 6.8 Section 6.9 Section 6.10 Section 7 Section 8 Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

36 Page 4-4 EIA/EMPR REPORT REQUIREMENTS AS PER THE DMR TEMPLATE ENVIRONMENTAL ASSESSMENT REPORT REQUIREMENTS AS PER SECTION 24G OF NEMA and cultural aspects of the environment may be affected by the proposed activity; j) Summary of specialist reports Section 9 k) Environmental impact statement Section 10 l) Proposed impact management objectives and the impact management outcomes for inclusion in the EMPr Section 11 m) Final proposed alternatives Section 12 n) Aspects for inclusion as conditions Section 13 of authorisation o) Description of any assumptions, Section 14 uncertainties and gaps in knowledge p) Reasoned opinion as to whether Section 15 the proposed activity should or should not be authorised q) Period for which environmental authorisation is required Section 16 r) Undertaking Section 17 s) Financial provision Section 18 t) Deviations from the approved scoping report and plan of study u) Other information required by the competent authority v) Other matters required in terms of section 24(4)(a) and (b) of the Act. Part B of the DMR report template REFERENCE IN THE EIA/EMPR REPORT Section 19 Section 20 Section 21 Section/Appendix 1) Draft EMPr (ee) an environmental management Section 22 a) Details of the EAP programme; b) Description of the aspects of the Section 23 activity c) Composite map Section 24 d) Description of impact Section 25 management objectives including management statements d) i) The determination of closure Section 25.1 objectives d) ii) The process for managing any Section 25.2 environmental damage, pollution, pumping and treatment of extraneous water or ecological degradation as a result of undertaking a listed activity d) iii) Potential acid mine drainage Section 25.3 d) iv) Steps taken to investigate, Section 25.4 Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

37 Page 4-5 EIA/EMPR REPORT REQUIREMENTS AS PER THE DMR TEMPLATE assess and evaluate the impact of acid mine drainage d) v) Engineering or mine design solutions to be implemented to avoid or remedy acid mine drainage d) vi) Measures that will be put in place to remedy any residual or cumulative impact that may result from acid mine drainage d) vii) Volumes and rate of water use required for the mining, trenching or bulk sampling operation. d) viii) Has a water use license been applied for? d) ix) Impacts to be mitigated in their respective phases ENVIRONMENTAL ASSESSMENT REPORT REQUIREMENTS AS PER SECTION 24G OF NEMA REFERENCE IN THE EIA/EMPR REPORT Section 25.5 Section 25.6 Section 25.7 Section 25.8 Section 25.9 e) Impact management outcomes Section 26 f) Impact management actions Section 27 i) Financial provision Section 28 Mechanisms for monitoring compliance Section 29 with and performance assessment against the environmental management programme and reporting thereon l) Indicate the frequency of the submission of the performance assessment report m) Environmental Awareness Plan Section 30 n) Specific information required by the competent authority Section 31 2) Undertaking Section 32 Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

38 Page NEED AND DESIRABILITY OF THE ACTIVITY The need and desirability of the project is described below. This section has been compiled taking into account the Department of Environmental Affairs (DEA) (2010), Guideline on Need and Desirability, in terms of the EIA Regulations, 2014 (GNR 891 of 2014). 5.1 ECOLOGICAL SUSTAINABLE DEVELOPMENT AND USE OF NATURAL RESOURCES Due to the nature of mining projects, impacts on sensitive biodiversity areas, linkages between biodiversity areas and related species and the role that they play in the ecosystem are probable. The project also had the potential to directly disturb vegetation, vertebrates and invertebrates. In addition to this, soil is a valuable resource that supports a variety of ecological functions. The project had the potential to damage soil resources through physical disturbance and/or contamination, which has a direct impact on the potential loss of the natural capability of the land. As part of the project, independent biodiversity and soil specialists were appointed to determine the sensitivity of the project area. In this regard the broader Tshipi Borwa mining right area in which the project area is located incorporates some high sensitive protected species, namely the Vachellia haematoxylon (Grey Camel Thorn) and Vachellia erioloba (Camel Thorn) which are protected under the NFA (refer to Section for further information). It is however important to note that these species did occur within the project area, specifically within the Vachellia haematoxylon Savannah and the Mixed Vachellia Savannah vegetation communities. Linked to this, is the loss of soil functionality and related land capability as an ecological driver for vegetation and ecosystems that rely on soil (Refer to Appendix F for the detailed assessment). Measures that were considered to avoid the destruction and disturbance of biodiversity and the loss of soil resources include limiting the project footprint to what was absolutely necessary. In this regard, and existing historical gravel road was widened and the diesel farm has been positioned within close proximity of other existing infrastructure (e.g. internal railway loop and access/haul roads). Where sensitive biodiversity areas could not be avoided, mitigation measures that focus on ensuring ecological sustainability through rehabilitation that aims at restoring pre-mining land capability to grazing and wilderness potential. 5.2 PROMOTING JUSTIFIABLE ECONOMIC AND SOCIAL DEVELOPMENT Community/society priorities are officially expressed through public documents including the provincial growth and development strategy and spatial development framework documents. In this regard, the priorities of the Joe Morolong Local Municipality s Integrated Development Framework (IDP) and the John Taolo Gaetsewe District Municipality s Spatial Development Framework (SDF) are mainly focused Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

39 Page 5-2 around the reduction of unemployment and halving poverty, as well as establishing cheap accommodation in towns experiencing rapid expansion by investing in key sectors and developing and upgrading basic service delivery and infrastructure. One of the ways of achieving this, according to the John Taolo Gaetsewe District Municipality s SDF (May 2016), is to discourage urban sprawl, and to promote more compact and efficient cities. In order to achieve this, development must be channelled into specific nodes and corridors (John Taolo Gaetsewe District Municipality, 2016). In addition, one of the Key Focus Areas for economic growth is the Gamagara Development Corridor. Taking the above into consideration the project will provide the necessary support to current operations of the Tshipi Borwa Mine which will in turn sustain economic benefits and negative environmental and social impacts. The mine already contributes to the national SA economy at macro level by exporting its product that leverages foreign income into the country. Direct economic benefits will be derived from wages, taxes and profits. Indirect economic benefits will be derived from the procurement of goods and services and the spending power of employees. Further to this, through employment, employees of the mine are afforded the opportunity to further their education through the skills development plan of the mine s social and labour plan (SLP). The skills development plan is not the extent of human resources development at the mine. Supplementary plans to enhance the socio-economic benefits of the project are also in place, and these include a career progression plan, a mentorship plan and internships and bursaries. In addition to these social development plans, the mine also has in place an Employment Equity Plan and targets relating to historically disadvantaged South Africans (HDSAs). The project will allow for local economic development (LED), since the mine is located within the Gamagara Development Corridor, which has been identified as a key sector to develop within the province to enhance economic growth. Further to this, the SLP includes plans in line with the IDP of the John Taolo Gaetsewe District Municipality and the Joe Morolong Local Municipality. In a broad sense this will include a housing and living conditions plan to improve living conditions of employees, an LED project plan and a procurement plan focusing on assisting HDSAs. Due to the expectation of employment associated with mining projects there is a potential for negative socio-economic impacts to occur. In this regard, an influx of job seekers to an area which in turn increases pressure on existing communities, housing, basic service delivery and raises concerns around safety and security. Management measures that will be implemented to manage and remedy these impacts include the implementation of a health policy on HIV/AIDs and tuberculosis, working together with local and regional authorities to address social service constraints and to monitor and prevent the development of informal settlements. In addition to this, formal communication structures and procurement procedures will be developed. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

40 Page MOTIVATION FOR THE PREFERRED DEVELOPMENT FOOTPRINT ON THE SITE INCLUDING THE PROCESS FOLLOWED TO DEFINE THE PREFERRED DEVELOPMENT ALTERNATIVES 6.1 DETAILS OF THE DEVELOPMENT FOOTPRINT CONSIDERED The diesel farm and haul road on the western boundary of the Tshipi Borwa Mine have already been established. It follows that the consideration of site layout, method or technology alternatives is not applicable THE NO-GO ALTERNATIVE The assessment of this option requires a comparison between the options of proceeding with the project - making use of the already widened haul road for the transportation of explosives and emulsion materials and the constructed storage and handling facilities of the diesel farm, with that of not proceeding with the project - not using and leaving the already widened haul road and constructed diesel farm. Proceeding with the project will provide support to the approved mining operations of the Tshipi Borwa Mine, which in turn will sustain economic benefits of the mine but also result in the identified negative environmental and social impacts. Not proceeding with the project leaves the status quo of the already widened haul road and constructed diesel farm and its current environmental impacts. 6.2 DETAILS OF THE PUBLIC PARTICIPATION PROCESS FOLLOWED This section describes the public participation process being followed and details the information provided to the interested and / or affected parties (I&APs). According to the NEMA EIA Regulations, 2014 I&APs include: any person, group of persons or organisation interested in or affected by such operation or activity; and any organ of state that may have jurisdiction over any aspect of the operation or activity. The intent of the public participation process was to inform I&APs of what the activities entail, in sufficient detail, in order that they may contribute meaningfully to the process as a whole including the identification of impacts REGISTERED INTERESTED AND AFFECTED PARTY DATABASE The project s registered interested and affected parties (RI&APs) database was developed by sourcing the mine s I&AP database and verifying details relating to adjacent landowners by means of a deed search. Information was also verified through networking and direct consultation with RI&APs which include landowners, occupiers of land within and surrounding the mine, state departments and other relevant I&APs. A copy of the project s RI&AP database is included in Appendix E. The database will be updated on an on-going basis throughout the environmental assessment process. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

41 Page LANDOWNER AND OCCUPIER NOTIFICATIONS During the week of the 24 th of April 2017, newsletters were sent via , post and fax to the landowners and occupiers within and surrounding the Tshipi Borwa Mine. The purpose of the newsletter was to inform landowners and occupiers about the project, the environmental assessment process, environmental impacts and means of providing input into the environmental assessment process. The letter was made available in English and Afrikaans on request. Proof of both the notification letter and delivery is attached in Appendix E RELEVANT AUTHORITY NOTIFICATIONS During the week of 24 th of April 2017, newsletters were sent to the following authorities (including the competent authority and state departments): DMR; DWS; DENC; SAHRA; DAFF; DRDLR; DALA; DPWRT; JTGDM; JMLM; and Ward councillor (Ward 4). The purpose of the newsletter was to inform authorities about the project, the environmental assessment process, environmental impacts and means of providing input into the environmental assessment process. Proof of both the notification letter and delivery is attached in Appendix E NOTICE BOARDS AND ADVERTISEMENTS On Friday, 28 th of April 2017, notice boards in English and Afrikaans were placed at key conspicuous positions in and around the project area. A map showing the laminated A2 notice boards distribution is included in Appendix E. Press adverts were placed in the Kalahari Bulletin and Kathu Gazette on 27 th of April 2017 and 29 th of April 2017, respectively. The press adverts, and site notice boards were undertaken to elicit interest from other potential I&APs that might not have been identified during the earlier stakeholder identification process. The advert and proof of notice boards are included in Appendix E. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

42 Page NOTIFICATION OF OTHER RI&APS The newsletter was sent to other RI&APs via , post or fax. The purpose of the letter was to inform other RI&APs about the project, the environmental assessment process, environmental impacts and means of providing input into the environmental assessment process. The letter was made available in English, and in Afrikaans on request. Proof of both the notification letter and delivery is attached in Appendix E COMMENTING ON THE DRAFT ENVIRONMENTAL ASSESSMENT REPORT Public comment on environmental assessment report The draft environmental assessment report will be made available for public review and comment from 2 nd of August 2017 until close of business on 1st of September 2017 (for 30 days). Full copies of the report will be placed at the following venues: JMLM; JTGDM; Hotazel Public Library; Kathu Public Library; and Black Rock Library. Electronic copies of the report will be made available on the Public Documents page of the SLR website ( RI&APs will be notified in writing of when and where the report will be available for comment via and sms. Summaries of the report will be made available to all RI&APs via and post. Following the commenting period, the final environmental assessment report inclusive of review comments from RI&APs will be submitted to the DMR Authority comment on environmental assessment report The draft environmental assessment report will be made available for review and comment by authorities registered on the I&AP database for a period of 30 days from 2 nd of August 2017 (for 30 days) until close of business on 1 st of September In this regard, electronic (where possible) and hard copies of the report will be made available to each of the authorities included on the RI&AP database. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

43 Page 6-4 Following the commenting period, the final environmental assessment report inclusive of review comments from RI&APs will be submitted to the DMR. 6.3 SUMMARY OF ISSUES RAISED BY RI&APS No issues or concerns in relation to the project have been raised by RI&APs (to date). All issues submitted in writing by the 1 st of September 2017 will be included in the final environmental assessment report. Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

44 Page ENVIRONMENTAL ATTRIBUTES ASSOCIATED WITH THE PROJECT AND ALTERNATIVES The baseline information provided is aimed at giving the reader perspective on the existing status of the cultural, socio-economic and biophysical environment relevant to the activities that are the subject of this environmental assessment report. The section below includes information sourced from the approved EIA and EMPr (Metago, May 2009) and the supporting specialist studies, where applicable, as well as additional specialist input obtained for the project BASELINE ENVIRONMENT AFFECTED BY THE ACTIVITY Geology INTRODUCTION AND LINK TO IMPACT As a baseline, the geology and associated structural features provides a basis from which to understand the potential for sterilisation of mineral reserves through the placement of the activities. Geological processes also influence soils forms (see Section ) and the potential for palaeontological resources (see Section ). To understand the basis of these potential impacts, a baseline situational analysis is described below. DATA SOURCES Information in this section was sourced from the approved EIA and EMPr (Metago, May 2009) and the geochemical analysis undertaken for the mine (SLR, March 2014). Regional and local geological data collection was done through review of available studies and topographical maps (SLR, October 2014 and Metago, May 2009). RESULTS Regional geology The world s largest land based sedimentary manganese deposit is contained in the Kalahari Manganese Field, situated 47km northwest of Kuruman in the Northern Cape. The Kalahari Manganese Field comprises five erosional, or structurally preserved, relics of the manganese bearing Hotazel Formation of the Paleoproterozoic Transvaal Supergroup. These include the Mamatwan-Wessels deposit (also known as the main Kalahari Basin), the Avontuur and Leinster deposits, and the Hotazel and Langdon Annex/Devon deposits. The Tshipi Borwa Mine is located in the Hotazel Formation (Transvaal Supergroup) towards the southern end of the Kalahari Basin (Metago, May 2009). Local and operational geology Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

45 Page 6-6 The Hotazel Formation is underlain by basaltic lava of the Ongeluk Formation (Transvaal Supergroup) and directly overlain by dolomite of the Moodraai Formation (Transvaal Supergroup) as illustrated in Figure 5 (SLR, March 2014). The Transvaal Supergroup is overlain unconformably by the Olifantshoek Supergroup which consists of arenaceous sediments, typically interbedded shale, quartzite and lavas overlain by coarser quartzite and shale (Figure 5). The different formations at the Tshipi Borwa Mine include the Mapedi and Lucknow units. The whole Supergroup has been deformed into a succession with an east-verging dip (SLR, March 2014). The Olifantshoek Supergroup is overlain by Dwyka Formation which forms the basal part of the Karoo Supergroup (Figure 5). At the Tshipi Borwa Mine this consists of tillite (diamictite) which is covered by sands, claystone and calcrete of the Kalahari Group (SLR, March 2014). Tshipi is exploiting the manganese from the Hotazel Formation (Transvaal Supergroup). The Hotazel Formation consists of Banded Iron Formation (BIF). The ore is contained within a 30 to 45 metre thick mineralised zone which occurs along the entire Tshipi Borwa Mine and is made up of three manganese rich zones; the Upper Manganese Ore Body (UMO), the Middle Manganese Ore Body (MMO) and the Lower Manganese Ore Body (LMO) (Figure 5). The UMO is 10cm to 15cm-thick and comprises moderate deposits of manganese. The poorly mineralised MMO is circa.1m-thick and not economically efficient. The LMO is a highly mineralised. The ore layer dips gradually to the north-west at approximately five degrees (SLR, March 2014). Project: SECTION 24G ENVIRONMENTAL ASSESSMENT REPORT FOR THE TSHIPI BORWA MINE August 2017

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47 Page 6-8 CONCLUSION Where infrastructure is placed within close proximity to mineable ore there is the possibility that sterilization can occur however this is not the case for this project. Placement of activities has not sterilized any mineable ore reserves Topography INTRODUCTION AND LINK TO IMPACT Changes to topography through the development of the project may impact on surface water drainage (Section ), visual aspects (Section ) and the safety of both people and animals. To understand the basis of these potential impacts, a baseline situational analysis is described below. DATA SOURCES Information in this section was sourced from site visits undertaken by the project team and topographical data. RESULTS The Tshipi Borwa Mine is located in an area that is relatively flat with a gentle slope towards the North West. The elevation on site varies from 1087 m to 1107 m above mean sea level (mamsl). The highest topographical features near the mine are the Mamatwan waste rock dumps (from 1099 m to mamsl) adjacent to the eastern boundary of the Tshipi Borwa Mine. The Vlermuisleegte River is located approximately 2km west of the nearest section of the Tshipi Borwa Mine boundary. The natural topography of the Tshipi Borwa Mine has been disturbed as a result of the existing mining infrastructure and activities. CONCLUSION Infrastructure has the potential to alter the topography and the natural state of areas. An alteration of the natural topography has the potential to present safety risks to both animals and third party people however this is not the case for this project. Infrastructure has not altered the topography and the natural state of the area Climate INTRODUCTION AND LINK TO IMPACT Climate can influence the potential for environmental impacts and related project design. Specific issues are listed below: Rainfall could influence erosion, evaporation, vegetation growth, rehabilitation planning, dust suppression, and surface water management planning;

48 Page 6-9 Temperature could influence air dispersion through impacts on atmospheric stability and mixing layers, vegetation growth, and evaporation which could influence rehabilitation planning; and Wind could influence erosion, the dispersion of potential atmospheric pollutants, and rehabilitation planning. To understand the basis of these potential impacts, a baseline situational analysis is described below. DATA SOURCES Information in this section was sourced from the review of available studies undertaken for nearby mining operations (SLR, November 2015 and Airshed, September 2015) and the approved EIA and EMPr (Metago, May 2009). Rainfall data was extracted from three sources, namely the Daily Rainfall Extraction Utility (DRU) programme, the DWS online database and the Water Resources of South Africa 2005 Study (WR2005). The rainfall data extracted using the DRU program includes the South African Weather station, Milner ( W). The rainfall data extracted from the DWS online database was for the Kuruman weather station (D4E004). The rainfall data extracted from the WR2005 database was for the quaternary catchment D41K (SLR, November 2015). Rainfall depth and wettest period data was sourced from the Winton weather station ( W). The Winton weather station is considered to have the highest percentage reliability given that it has the greatest number of years (104) of recorded data when compared to the Milner weather station ( W) (85 years) and as such the Winton weather station was chosen to determine the five greatest rainfall depths (SLR, August 2015). Evaporation data was obtained from the Water Resources of South Africa 2005 Study, (WR2005, 2009). The evaporation data obtained is based on Symons pan evaporation measurements and was converted to lake evaporation using factors obtained from WR2005 (SLR, August 2015). Monthly temperature and wind data was sourced from the Mesoscale Model 5 (2011 to 2013) (Airshed, September 2015). RESULTS Regional climate The mine falls within the Northern Steppe Climatic Zone, as defined by the South African Weather Bureau. This is a semi-arid region characterised by seasonal rainfall, hot temperatures in summer, and colder temperatures in winter (Metago, May 2009). Rainfall, rainfall depths and wettest periods

49 Page 6-10 Monthly rainfall data for the Milner, Winton and Kuruman weather stations including rainfall data for quaternary catchment D41K is summarised in Table 8 below (SLR, August 2015). The closest weather stations to the Tshipi Borwa Mine are the Milner and Kuruman weather stations at approximately 3.6km and 40km from the mine respectively (Metago, May 2009). TABLE 8: SUMMARY OF MONTHLY RAINFALL DATA (SLR, OCTOBER 2015) MONTH RAINFALL (MM) Winton ( W) Milner ( W) Kuruman (D4E004) WR2005 (Quaternary catchment D41K) January February March April May June July August September October November December Annual The WR2005 data indicates that the mean annual precipitation (MAP) for the quaternary catchment D41K is 344 mm, which correlates reasonably well with the Winton station. In addition to this, given that the Winton weather station is considered to be the most reliable in terms of data, the adopted MAP for the mine site is 335mm. A review of the daily rainfall records from the Winton weather station shows that the maximum daily rainfall depth between 1878 and 2000 was mm. Several other high rainfall depths are also shown in Table 9 (SLR, October 2015). TABLE 9: FIVE GREATEST DEPTH OF RAINFALL RECORDED AT THE WINTON WEATHER STATION (SLR, OCTOBER 2015) DATE RAINFALL (MM) 22/12/ /03/ /03/ /03/ A review of the wettest multi-day periods recorded are presented in Table 10, which shows the maximum depth of rain falling over consecutive days for the Winton weather station, ranging from 1 to 30 days. The

50 Page 6-11 greatest depth of rain falling within a 30 day period was mm which exceeds the MAP and the greatest depth within a 180 day period was mm which is nearly three times the MAP. It is concluded that whilst MAP in this area is low there has been significant rainfall on occasions (SLR, October 2015). TABLE 10: WETTEST PERIODS RECORDED ON CONSECUTIVE DAYS (SLR, OCTOBER 2015) Number of consecutive days Total depth of rainfall (mm) Evaporation The Tshipi Borwa Mine lies within evaporation zone 8A, which has a total mean annual evaporation (MAE) of 2351 mm. Table 11 provides a monthly summary of the adopted evaporation for the mine (SLR, October 2015). TABLE 11: SUMMARY OF EVAPORATION DATA (SLR, OCTOBER 2015) MONTHS SYMONS PAN EVAPORATION (MM) LAKE EVAPORATION FACTOR LAKE EVAPORATION (MM) January February March April May June July August September October November December Total 2351 N/A 1972 Temperature Monthly mean, maximum and minimum temperatures for the project area are provided in Table 12 below. Temperatures ranged between -0.6 C and 35 C altho ugh local residents have recorded lower

51 Page 6-12 temperatures. During the day, temperatures increase to reach maximum at around 15:00 in the afternoon. Ambient air temperature decreases to reach a minimum at around 06:00 just before sunrise (Airshed, September 2015). TABLE 12: MONTHLY TEMPERATURE DATA (AIRSHED, SEPTEMBER 2015) MONTHS MINIMUM MAXIMUM AVERAGE January February March April May June July August September October November December Wind Wind roses comprise 16 spokes which represent the directions from which winds blew during the period. The colours reflected the different categories of wind speeds, the orange area, for example, representing winds of 3 m/s to 6 m/s. The dotted circles provide information regarding the frequency of occurrence of wind speed and direction categories. The frequency, at which calms occurred, i.e. periods during which the wind speed was below 1 m/s, is also indicated. The period wind field and diurnal variability in the wind field are shown in Figure 6, while the seasonal variations are shown in Figure 7. Wind direction within the project area is dominated by winds from the north, northeast and east, with an average wind speed of 3.4 m/s. The strongest winds (more than 6 m/s) were also from the east and northeast and occurred mostly during the day (06:00 to 18:00). Calm conditions occurred 8.55 % of the time. A distinct increase in winds from the south occurred at night (18:00 to 06:00). Wind direction within mine area shows considerable differences between the seasons. During summer, autumn and winter the dominant winds are from the east, northeast and south, while in spring, the southerly winds dominate (Airshed, September 2015). CONCLUSION

52 Page 6-13 The Tshipi Borwa Mine is characterised by hot summers and cool winters with rain generally occurring in the form of thunderstorms that last for short periods at a time during rainy periods. High evaporation rates reduce infiltration, while rainfall events can increase the erosion potential and the formation of erosion gullies. The presence of vegetation does however reduce the effects of erosion. The mixing of layers resulting in the formation of temperature inversions, and the presence of cloud cover limits the dispersion of pollutants into the atmosphere. Wind significantly affects the amount of material that is suspended from exposed surface to the atmosphere. The wind speed determines the distance of downward transport as well as the rate of dilution of pollutants in the atmosphere. On average, wind speeds are below 5.3 m/s and not able to carry all types of dust particles. These climatic aspects have been used to inform the impact assessment and need to be taken into consideration during rehabilitation and surface water management planning.

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55 Page Soil INTRODUCTION AND LINK TO IMPACT Soils are a significant component of most ecosystems. As an ecological driver, soil is the medium in which most vegetation grows and a range of vertebrates and invertebrates exist. In the context of mining operations, soil is even more significant if one considers that mining is a temporary land use where after rehabilitation (using soil) is the key to re-establishing post closure land capability that will support post closure land uses. Mining projects have the potential to damage soil resources through physical loss of soil and/or the contamination of soils, thereby impacting on the soils ability to sustain natural vegetation and altering land capability. Contamination of soils may in turn contribute to the contamination of surface and groundwater resources. Loss of the topsoil resource reduces chances of successful rehabilitation and restoration. To understand the basis of these potential impacts, a baseline situational analysis is described below. DATA SOURCES Information in this section was sourced from the soil study undertaken by ARC (ARC, October 2008) as part of the approved EIA and EMPr (Metago, May 2009). As part of the project, the specialist confirmed that the results of the soil study undertaken in October 2008 are still relevant. The specialist opinion is included in Appendix N. Information was sourced through the review of available literature as well as studies undertaken near the Tshipi Borwa Mine (ARC, October 2008). RESULTS Soil forms The soil study undertaken for the approved EIA and EMPr (Metago, May 2009) indicated that the soil form associated with the Tshipi Borwa Mine is Hutton. A more detailed description of the Hutton soil form is provided below (ARC, October 2008). Hutton (Hu) The Hutton soil form comprises the following characteristics: Homogeneous in terms of texture, structure, and soil depth Reddish brown apedal sandy topsoil on yellowish red apedal sandy subsoil Has a low clay content Consists of deep (>1.5m) windblown sand and therefore drains rapidly Soil chemical characteristics

56 Page 6-17 The cation exchange capacity (CEC) values are low, due to the low clay content of the soil. The Hutton soil form is generally slightly acidic to mildly alkaline with low fertility levels due to a deficiency of key nutrients such as phosphorus (P) (ARC, October 2008). Soil Physical Characteristics Dry land agriculture potential The Hutton soil form located at the Tshipi Borwa Mine has a low agricultural potential due to the rapid drainage nature of the soil and lack of soil fertility. In addition to this the hot, dry nature of the climatic regime, is not suited to dryland arable agriculture (ARC, October 2008). Irrigation potential The soils would have a moderate potential for irrigation, due to the very low clay content (ARC, October 2008). CONCLUSION The Hutton soil form found at the Tshipi Borwa Mine is homogeneous in terms of texture, structure, and soil depth. This soil form is a well-drained sandy soil which allows for high infiltration rates and low organic content. These soils are therefore highly erodible. The rapid drainage nature of the Hutton soil form reduces the dry production potential as well as the irrigation potential. The soil fertility is low due to a deficiency in key nutrients such as phosphorus. In general the soil forms located at the Tshipi Borwa Mine are difficult to work and have a limited utilization potential. Taking the above into consideration soils located at the Tshipi Borwa Mine will require appropriate management measures to prevent the loss of soil resources through pollution and erosion as soil resources form a crucial role during rehabilitation Land capability INTRODUCTION AND LINK TO IMPACT The land capability classification is based on the soil properties and related potential to support various land use activities. Mining operations have the potential to significantly transform the land capability. To understand the basis of this potential impact, a baseline situational analysis is described below. DATA SOURCES Information in this section was sourced from the soil study undertaken by ARC (ARC, October 2008) as part of the approved EIA and EMPr (Metago, May 2009). As part of the project, the specialist confirmed that the results of the soil study undertaken in October 2008 are still relevant. The specialist opinion is included in Appendix N.

57 Page 6-18 Land capability was assessed in terms of arable land, grazing land, wilderness land and wetlands, as defined by the MEM Guideline for planning and authorization (Department of Minerals and Energy, 2000) (ARC, October 2008). RESULTS The land capability at the Tshipi Borwa Mine is considered to be of low agricultural potential due to the low clay content of the soils and the low rainfall. Given this, the land capability at the Tshipi Borwa Mine is classified as having a grazing potential (ARC, October 2008). CONCLUSION The land capability at the Tshipi Borwa Mine is classified as having a grazing potential. The land capability at the Tshipi Borwa Mine has changed due to the presence of approved infrastructure and activities. Therefore, impact management and rehabilitation planning is required to achieve acceptable post rehabilitation land capabilities Biodiversity INTRODUCTION AND LINK TO IMPACT In the broadest sense, biodiversity provides value for ecosystem functionality, aesthetic, spiritual, cultural, and recreational reasons. The known value of biodiversity and ecosystems is as follows: Soil formation and fertility maintenance; Primary production through photosynthesis, as the supportive foundation for all life; Provision of food and fuel; Provision of shelter and building materials; Regulation of water flows and water quality; Regulation and purification of atmospheric gases; Moderation of climate and weather; Control of pests and diseases; Maintenance of genetic resources. The establishment of infrastructure and on-going project activities have the potential to result in the loss of vegetation, habitat and related ecosystem functionality through physical disturbance and/or contamination of soil and/or water resources. As a baseline, this section provides an outline of the type of vegetation occurring on site and the status of the vegetation, highlights the occurrence of sensitive ecological environments including sensitive/ endangered species (if present) that require protection and/or additional mitigation should they be disturbed.

58 Page 6-19 DATA SOURCES Information in this section was sourced from the biodiversity study undertaken for the project (EMS, February 2017) included in Appendix J. This section needs to be read in conjunction with Figure 8. RESULTS - FLORA Vegetation types The study area falls within the Kathu Bushveld. The Kathu Bushveld is described as an open savannah with the Camel Thorn (Vachellia erioloba) (formerly known as Acacia erioloba) and Shepards Tree, (Boscia albitrunca) as the prominent trees. The shrub layer contains the Grey Camel Thorn, Vachellia haematoxylon (formerly known as Acacia haematoxylon) Black thorn (Senegalia mellifera), (formerly known as Acacia mellifera) Blue bush (Diospyros lycioides) and River Honey-thorn, and Lycium hirsutum. The grass layer is variable. Three vegetation types occur at the mine, namely the Mixed Vachellia Savannah, the Vachellia haematoxylon Savannah and the Grewia flava Scrub. For a distribution of these vegetation types within the mine area, refer to Figure 8. Further information on the various vegetation types at the project area is provided in Table 13 below. TABLE 13: DESCRIPTION OF VEGETATION TYPES (EMS, FEBRUARY 2017) VEGETATION TYPE Mixed Vachellia Savannah DESCRIPTION This vegetation type is characterised by the height of the tree layer which is mainly comprised of tall Vachellia erioloba trees. Three vegetation strata are evident within this vegetation unit. There is a prominent tree layer between 2.5m 6m, a shrub layer, between 1.5m 2.5m and a grass layer with an average height of 70cm. Vachellia erioloba, Vachellia haematoxylon, and Vachellia hebeclada, are prominent within this vegetation type, however Ziziphus muconata, Grewia flava and Vachellia mellifera also occur. The grass layer contained species such as Eragrostis lehmanniana, Stipagrostis uniplumis, Schmidtia kalihariensis, Aristida stipitata and Aristida congesta were common. Other common species include, Gnidia polycephala, Tribulus zeyheri, Chrysocoma ciliata and Walafrida geniculate. Vachellia haematoxylon Savannah Grewia flava Scrub Within this vegetation type there are areas that contain a significantly higher percentage of Vachellia erioloba trees. These areas form distinctive patches but have not been mapped as a separate vegetation unit as they cover relatively small areas and do not show a significantly different floristic composition. This community has a moderate grass cover (50-60%), the shrub layer is moderately developed. Vachellia haematoxlyon is the dominant shrub species. The tree layer is poorly developed with individuals of Vachellia erioloba occurring within the community. Common grass species include, Schmidtia pappophoroides (dominant), Eragrostis lehmanniana, (Lehmanns love grass), Eragrostis micrantha (Finessa grass), Stipagrostis uniplumis (Silky bushmans grass), Aristida congesta and Aristida stipitata (Long-awned Three awn). Other common species within this vegetation type include, Acanthosicyos naudiniana, Tribulus zeyheri, Gnidia polycephala, Helichrysum argyrosphaerum and Monochema incanum. This vegetation type is characterised by a high percentage occurrence of Grewia flava. This vegetation type is characteristically shorter although scattered individuals of taller trees do occur. Vachellia haematoxylon, Lycium hirsutum and Senegalia mellifera are also present within this community. The grass layer is very patchy, but in some areas it is moderately well developed. Species such as, Schmidtia pappophoroides, Eragrostis lehmanniana, Pogonarthria

59 Page 6-20 VEGETATION TYPE DESCRIPTION squarrosa, Aristida meridionalis and Aristida congesta are common. With reference to Figure 8, these vegetation types have been disturbed by the presence of existing mining infrastructure associated with the Tshipi Borwa Mine. Species of concern As part of the biodiversity assessment (EMS, February 2017) undertaken for the project, several species of concern were identified. These included the Vachellia erioloba (Camel Thorn) and the Vachellia haematoxylon (Grey Camel Thorn) which are protected in accordance with the NFA. In addition to this, the species Moraea longistyla which is considered to be a Schedule 2 (protected) species in accordance with the NCNCA. Other species of concern that are likely to occur at the Tshipi Borwa Mine are included in Table 14 below. TABLE 14: SPECIES OF CONCERN LIKELY TO OCCUR AT THE TSHIPI BORWA MINE (EMS, JANUARY 2017) SPECIES COMMON NAME LEGISLATION CONSERVATIONAL STATUS* Vachellia erioloba Camel Thorn NFA Protected Vachellia haematoxylon Grey Camel Thorn Protected Moraea longistyla Goldblatt NCNCA Schedule 2 Moraea pallida Geeltulp Schedule 2 Babiana hypogaea Bobbejaankalkoentjie Schedule 2 Harpagophytum Devil s claw Schedule 1 procumbens Boophone Disticha Poison bulb Schedule 2 Brunsvigia radula Limestone hedgehogs Schedule 2 Orthanthera jasminiflora Sandmelktou, Schedule 2 Moerwortel Boscia albitrunca Shepherd s Tree Schedule 2 Crassula captella Aanteelrosie Schedule 2 Kalanchoe brachyloba Gelobde plakkie Schedule 2 Ruschia griquensis - Schedule 2 Olea europaea African olive Schedule 2 Oxalis haedulipes - Schedule 2 * Endangered (Schedule 1), protected (schedule 2) Alien invasive species Alien invaders are plants that are of exotic origin and are invading previously pristine areas or ecological niches. Alien invasive species caused a decline in species diversity, local extinction of indigenous species, ecological imbalance, decreased productivity of grazing pastures and increased agricultural

60 Page 6-21 costs. Alien and invasive species likely to occur at the Tshipi Borwa Mine in terms of Regulation 15 and Regulation 16 (R. 280 of 2001) of CARA are outlined in Table 15 below. TABLE 15: ALIEN INVASIVE SPECIES LIKELY TO OCCUR AT THE TSHIPI BORWA MINE (EMS, JANUARY 2017) SCIENTIFIC NAME COMMON NAME CATEGORY Argemone mexicana Yellow flowered Mexican Poppy 1 Atriplex nummularia Old Man Salt Bush 2 Pennisetum setaceum Fountain Grass 1 Prosopis cf. glandulosa Mesquite 2 Opuntia humifusa Prickly pear 1 Achyranthes aspera Bur weed 1 Xanthium spinosum Spiny cocklebur 1 Argemone ochroleuca White flowered Mexican poppy 1 According to the Regulation 15 and Regulation 16 (R. 280 of 2001) of the CARA, Category 1 species must be removed and destroyed immediately. Category 2 species include alien invasive species that may only be grown under controlled conditions. These plants have certain useful qualities and are allowed in demarcated areas. In other areas, these species must be eradicated and controlled. RESULTS - FAUNA Mammals For a list of mammal species that are likely to occur at the Tshipi Borwa Mine refer to Table 16 below. TABLE 16: RED DATA MAMMALS LIKELY TO OCCUR AT THE TSHIPI BORWA MINE (EMS, JANUARY 2017) SCIENTIFIC NAME Rhinolophus denti Mellivora capensis Atelerix frontalis COMMON NAME Dent s Horseshoe Bat Honey badger South African Hedgehog CONSERVATIONAL STATUS Near threatened Least concern Near threatened SUITABLE HABITAT Limited Requires substantial cover such as caves and rock crevices. High As they are catholic in habitat requirements, they are likely to occur on-site. High Require ample groundcover and dry places for nesting. OCCURANCE POTENTIAL Very little Roosting habitat in the form of rock crevices may be available in the old mining area adjacent to the site. However, as the landscape in the area is flat sand veld and does not offer suitable roosting habitat for this species, it is unlikely that this species would have colonised the adjacent mining areas. High Suitable habitat within the study area. High to Medium Suitable habitat available.

61 Page 6-22 Avifaunal A few avifaunal species are likely to occur at the Tshipi Borwa Mine as outlined in Table 17 below (EMS, January 2017). TABLE 17: RED DATA AVIFAUNAL SPECIES LIKELY TO OCCUR AT THE TSHIPI BORWA MINE (EMS, JANUARY 2017) SCIENTIFIC NAME Polemaetus bellicosus Sagittarius serpentarius Neotis ludwigii COMMON NAME CONSERVATIONAL STATUS (REGIONAL, GLOBAL) SUITABLE HABITAT Martial Eagle Endangered, Vulnerable Woodland, savannah or grassland with clumps of large trees or power pylons for nest sites Secretarybird Vulnerable, Vulnerable Requires open grassland with scattered trees, shrubland, open Mixed Savannah. Ludwig s Bustard Endangered, Endangered Requires semi-arid dwarf shrublands, occasionally visiting the southern Kalahari. OCCURANCE POTENTIAL High Nesting habitat in the Mixed Savannah High Patches of open savannah will accommodate this species. Medium Moderate to high shrub density throughout the sit Reptiles and amphibians No red data reptiles or amphibians are likely to occur at the Tshipi Borwa Mine. RESULTS - ECOLOGICAL SENSITIVITY National and provincial databases The section below provides information on the sensitivity of the Tshipi Borwa Mine in accordance with national and provincial databases in place at the time of the specialist study. It is important to note, that although all data sources used provide useful and often verifiable, high quality data, the various databases used do not always provide an entirely accurate indication of the actual site characteristics. This information is however considered to be useful as background information. The goal of the NPAES is to achieve cost effective protected area expansion for ecological sustainability and adaptation to climate change. The NPAES sets targets for protected area expansion, provides maps of the most important areas for protected area expansion, and makes recommendations on mechanisms for protected area expansion. The Mining Biodiversity Guideline (2012) provides explicit direction in terms of where mining-related impacts are legally prohibited, where biodiversity priority areas may present high risks for mining projects, and where biodiversity may limit the potential for mining. No protected areas, National Protected Area Expansion Strategy Focus Areas or National Biodiversity Priority Areas in terms of the South African National Biodiversity Institute (SANBI) Grasslands Programme s Mining and Biodiversity Guidelines (2012) occur within the mining right area. However, the Tshipi Borwa Mine is located near an area identified as a potential protected area the Eastern Kalahari Bushveld.

62 Page 6-23 At present there is no Systematic Biodiversity Conservation Plan for the Northern Cape other than the Namakwa District Biodiversity Sector Plan. However, draft Critical Biodiversity Areas (CBAs) have been defined for this area, but the map was not available for consideration at the time of writing this report. It is believed that the CBAs will provide information on the fine scale distribution of aquifer dependent ecosystems (ADEs), type of plant association (singly, in stands or gallery forests), aquifer association, condition of vegetation etc. and therefore a precautionary approach should be taken when developing in and around these systems until such time that the research data indicates whether or not they are in fact CBAs. ADEs particularly in arid ecosystems provide habitats for an array of species and are considered important in ecological processes and making available resources for the biodiversity in an area that would otherwise not be available. ADE s within the area that would be particularly critical are the terrestrial ADE s associated with species such as Vachellia erioloba, and Vachellia haematoxylon. The NEMBA provides for listing of threatened or protected ecosystems, in one of four categories: critically endangered, endangered, vulnerable or protected. Threatened ecosystems are listed in order to reduce the rate of ecosystem and species extinction by preventing further degradation and loss of structure, function and composition of threatened ecosystems. The purpose of listing threatened ecosystems is primarily to conserve sites of exceptionally high conservation value (SANBI, BGIS). According to the National List of Threatened Terrestrial Ecosystems (2011) the Tshipi Borwa Mine is not located in any threatened ecosystems. The NFEPA (2011) database was consulted to define the aquatic ecology of the wetlands or river systems close to the Tshipi Borwa Mine that may be of ecological importance. The Tshipi Borwa Mine does not fall within a NFEPA, but the Vlermuisleegte River located approximately 1.86km to the west of the Tshipi Borwa Mine is considered to be a Class B (largely natural) river. Site sensitivity Two of the identified habitats have high sensitivity ratings, namely mixed Vachellia Savannah and the Vachellia haematoxylon Savannah. This is due to the higher density of protected species that occur within these communities. CONCLUSION The placement of infrastructure and on-going project activities have the potential to disturb and/or destroy vegetation, habitat units and related ecosystem functionality including the disturbance of sensitive/ endangered species. Species of conservation concern likely to occur in the mining right area includes two faunal species classified as Endangered, one classified as Vulnerable, two of which are Near Threatened and one of Least Concern. Fourteen of the floral species identified are protected and one species is endangered

63 Page 6-24 under the NCNCA. A few of the dominant tree species present within the Tshipi Borwa Mine includes Vachellia erioloba, V. haematoxylon and Boscia albitrunca which are protected in terms of the NFA. The diesel farm and haul road fall within two of the habitats identified as having high sensitivity ratings. Mitigation measures need to be implemented to reduce the impacts that the project may have towards these areas.

64 314 2/330 To Hotazel/ Kuruman 2/329 ± 330 6/329 3/332 4/332 8/329 6/329 R /331 Mamatwan Mine 3/328 17/ /331!!! 14/331 18/331!! 15/ / Re/700 Re/700 1/ /367 Hotazel-Sishen Railway Line 3/ To Kathu 1/367 Legend Tshipi Borwa Mine Surface Use Area Tshipi Borwa Mine Approved Mining Right Area Tshipi Borwa Mine Infrastructure Section 24G Activities Vegetation Types Vachellia haematoxylon Grewia f lava Scrub Mixed Vachellia Savannah TSHIPI E' NTLE MANGANESE MINING Figure 8 Vegetation Types Meters Scale: 1:25 A3 Projection: Transverse Mercator Datum: WGS1984, Lo23 SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) Fax: +27 (11) June 2017

65 Page Surface water INTRODUCTION AND LINK TO IMPACT Surface water resources include drainage lines and paths of preferential flow of stormwater runoff. Project activities have the potential to alter the drainage of surface water through the establishment of infrastructure and/or result in the contamination of the surface water resources through seepage and/or spillage of hydrocarbons. To understand the basis of these potential impacts, a baseline situational analysis is described below. DATA SOURCES The information in this section was sourced from the approved EIA and EMPr (Metago, May 2009). Information pertaining to catchments, mean annual run-off and water management areas was sourced from the Water Resources of South Africa Manual WR2012 (WR 2012). Information regarding the relevant rivers surrounding the mine was sourced from the review of topographical data and on-site observations. RESULT Catchments within the context of South Africa The Tshipi Borwa Mine is located within the Lower Vaal Water Management Area (National Water Resource Strategy, 2004). The major rivers associated with this water management area include the Molopo River, Harts River and the Vaal River which ultimately drain into the Orange River. Regional hydrology The Tshipi Borwa Mine falls within the quaternary catchment D41K (Figure 9) which has a gross total catchment area of 4216 km 2, with a net MAR of 6.53 million cubic meters (mcm) (WR2012). The major river within quaternary catchment D41K is the Ga-Mogara drainage channel which is located approximately 6km north west of the Tshipi Borwa Mine (Figure 9). The Ga-Mogara drainage channel forms a tributary of the Kuruman River. The Kuruman River flows west joining the Molopo River approximately 250 km from the confluence of the Ga-Mogara drainage channel and Kuruman River. The Molopo River drains in a southerly direction eventually joining the Orange River. Local hydrology The nearest watercourses to the Tshipi Borwa Mine are the non-perennial Vlermuisleegte (approximately 2km west) and the non-perennial Witleegte (approximately 10km northeast) (Figure 9). It follows that no watercourses are located within the Tshipi Borwa Mine surface use area. Both the Vlermuisleegte and the Witleegte are tributaries of the Ga-Mogara River. The catchment characteristics of the Witleegte and the Vlermuisleegte tributaries are provided in Table 18 below (Metago, May 2009).

66 Page 6-27 TABLE 18: CHATCHMENT CHARACTERISTICS (METAGO, MAY 2009) CATCHMENT CATCHMENT AREA (KM 2 ) MAR (NETT) (MILLION M 3 /ANNUM) WATERCOURSE LENGTH (KM) DRAINAGE DENSITY (KM/KM 2 ) Witleegte catchment Vlermuisleegte catchment The normal dry weather flow of watercourses in the region is no flow. Surface water quality No water sampling of natural water sources within the mine area has been conducted because there are no permanent surface water features. Given this, no surface water quality data is available. Surface water use Due to the ephemeral nature of Witleegte and Vlermuisleegte Rivers, there is no third party reliance on surface water. Floodlines No floodlines were determined, as no watercourses are located within the surface use area (Metago, May 2009). Wetlands No wetlands are located within the surface use area (Metago, May 2009). CONCLUSION Project infrastructure/activities are such that they indirectly present potential for pollution of water resources. The project must therefore be managed/implemented in a way that pollution of water resources is prevented.

67

68 Page Groundwater INTRODUCTION AND LINK TO IMPACT Groundwater is a valuable resource and is defined as water which is located beneath the ground surface in soil/rock pore spaces and in the fractures of lithological formations. Activities such as the handling, storage and spillage of hazardous materials (hydrocarbons) have the potential to result in the loss of groundwater resources, both to the environment and third party users, through pollution. To understand the basis of these potential impacts, a baseline situational analysis is described below. DATA SOURCES Information in this section was sourced from the approved EIA and EMPr (Metago, May 2009), the groundwater study (Water Geosciences Consulting, February 2009), the geochemical analysis undertaken for the mine (SLR, March 2014) and the water quality monitoring report (SLR, October 2016). RESULTS Presence of groundwater Two aquifers are present beneath the project site: a shallow aquifer comprising the Kalahari sands and calcrete; and a deeper fractured aquifer comprising Dwyka clay and Mooidraai dolomite formation. The aquifers are classified as poor to minor aquifers. Although borehole yields in the deeper aquifer are generally low, structural features such as faults and fractures could support higher yielding boreholes. As some farmers in the area rely on borehole water for their water supply, some sections of the aquifers may be classed as sole source aquifers. However, this depends on the feasibility of the farmers obtaining alternative water from the Sedibeng Vaal-Gamagara Water Scheme, to which some have access. Groundwater levels and flow Groundwater flows across the project site in accordance with the topography in a west-north-west direction. Groundwater levels vary from 41 to 74m below groundwater level. This is indicative of low rainfall in the area and highly permeable soils. Groundwater quality As part of quarterly monitoring, groundwater sampling was undertaken at six of the eight sampling points within the mine. The location of the sampling points is illustrated in Figure 11. Further details pertaining to the various sampling points are provided in Table 19 below.

69 Page 6-30 TABLE 19: DETAILS OF GROUNDWATER MONITOING POINTS (SLR, OCTOBER 2016) SAMPLE ID LOCATION AQUIFER MONITORED NT1 Surrounding Area Upstream of Mine Deep fractured rock aquifer NT8 Surrounding Area North West of Mine Deep fractured rock aquifer NT15 Surrounding Area East of Mine Deep fractured rock aquifer TSH01 Within Project Area Downstream of Mine Deep fractured rock aquifer TSH02 Within Project Area Downstream of Mine Deep fractured rock aquifer TSH03 Within Project Area Downstream of Mine Deep fractured rock aquifer TSH04 Within Project Area Downstream of Mine Deep fractured rock aquifer TSH06 / NEX108 Within Project Area Downstream of Mine Deep fractured rock aquifer Groundwater quality obtained as part of the quarterly monitoring was compared to the SANS 241 (2015) Water Quality Standards and DWS Target Water Quality Range for Livestock Watering. A summary of the results is provided in Table 20. The results indicate the following: Concentrations of the majority of elements were low and many recorded at concentrations below relevant water quality standards. Electrical Conductivity (EC) - concentrations ranged between 57.9mS/m in TSHNT1 and 388mS/m in NT15. The concentration in NT15 exceeded the SANS 241:2015 limit for Aesthetics (170mS/m). Concentrations in NT15 have consistently been elevated since monitoring began, however the June 2016 result was significantly lower than previous data which are normally in excess of 350 m/sm. The concentration in NT15 has subsequently returned to the elevated levels during the October monitoring. There is a steady increase in the EC of TSH04 which exceeded the SANS 241:2015 screening criteria during the last monitoring event. Total Dissolved Solids (TDS) concentrations ranged between 292mg/L in TSH03 and 4166mg/L in NT15. The concentration in NT15 exceeded the SANS 241:2015 limit for Aesthetics (1200mg/L) along with the DWAF TWQR for Livestock Watering (dairy, pigs and poultry 1000mg/L). Similar to EC, concentrations in NT15 have consistently been elevated since monitoring began, however the June 2016 is significantly lower than previous data which are normally in excess of 2000mg/L. The concentration has subsequently increased to previously monitored levels. Concentrations recorded in other boreholes are generally consistent with previous data, however the concentration recorded for June 2016 in NT8 is also lower than expected. This trend continues through the current monitoring period. Chloride (Cl) concentrations ranged between 24mg/L in NT1 and 805mg/L in NT15. The concentration recorded in NT15 exceeded the SANS 241:2015 limit of 300mg/L. Concentrations recorded in all the boreholes are consistent with previous data, except for NT15 where lower than expected values were recorded in June 2016 with the value returning to expected levels during the current monitoring period. Nitrate (NO 3 ) concentrations ranged from below the laboratory detection limit of <0.1mg/L to 196mg/L in NT15. The concentrations recorded in NT15 and TSH01 exceed the SANS 241:2015 limit for Acute Health (11mg/L) and the DWAF TWQR of 22mg/L. Concentrations in NT15 have consistently been

70 Page 6-31 elevated since monitoring began, however the June 2016 result is significantly lower than previous data which are normally in excess of 150mg/L. Concentrations in all other boreholes are consistent with previous data. Arsenic (As) concentrations ranged from below the laboratory detection limit of <0.001mg/L to 0.130mg/L at NT15. The concentrations recorded in NT15, NT8, NT1 and TSH01 exceeded the SANS 241:2015 limit for chronic health (0.1mg/L) in the first sampling quarter. Iron (Fe) concentrations ranged from below the laboratory detection limit of <0.025mg/L and 21.3mg/L in TSH04. Concentrations recorded in four (4) boreholes exceeded water quality standards: o Concentrations recorded in TSH04 and TSH06 / NEX108 exceeded both the SANS 241:2015 limit for Aesthetics (0.1mg/L) and SANS 241:2015 limit for Chronic Health (2mg/l); and o The concentration recorded in NT8 and TSH03 exceeded the SANS 241:2015 limit for Aesthetics. Manganese (Mn) concentrations ranged from below the laboratory detection limit of <0.025mg/L and 2.641mg/L in TSH04. Concentrations recorded in four (4) boreholes exceeded water quality standards: ο Concentrations recorded in NT8, TSH01, TSH03, TSH04 and TSH06 / NEX108 exceeded the SANS 241:2015 limit for Aesthetics (0.1mg/L). ο The concentration recorded in TSH04 (2.641mg/L) also exceeded the SANS 241:2015 limit for Chronic Health (0.4mg/L). Nickel (Ni) concentrations ranged from below the laboratory detection limit of <0.001mg/L to 0.114mg/L at TSH04. The concentrations recorded in TSH04 exceeded the SANS 241:2015 limit for chronic health (0.07mg/L) only in the October 2016 sampling quarter. Selenium (Se) concentrations ranged from below the laboratory detection limit of <0.001mg/L to 0.238mg/L at NT15. The concentrations recorded in boreholes NT15 (June and October 2016), NT8 (October 2016) and TSH06 (October 2016) exceeded the DWA SANS 241:2015 standard limit guideline of 0.05mg/L. Ammonia (NH 3 ) concentrations ranged from below the laboratory detection limit of <0.001mg/L to 139mg/L at TSH04. The concentrations recorded in TSH04 and TSH06 (June 2016, February 2017 and April 2017), NT8 (June 2016) and TSH03 (April 2017) exceeded the SANS 241:2015 limit for aesthetic health (1.5mg/L). From the aforementioned elements, the key chemicals of concern are considered to be EC, TDS, Fe, Mn, Se, Ni and NO 3. Although this can be related to mining operations, they are also associated with the natural geology and site setting of the Tshipi Mine. No rising trend was observed in concentrations, and some elements were elevated in boreholes located up-gradient of the mine, thus it is unlikely that these concentrations are a result of Tshipi mining operations. Borehole NT15 remains the most contaminated borehole with elevated levels of TDS, EC, Cl, NO 3, As and Se.

71 Page 6-32 Groundwater use The majority of the groundwater sampled is of the Mg-Ca-HCO 3 type and is used to supply drinking water for cattle and in some instances supply water for domestic use.

72 Page 6-33 TABLE 20: GROUNDWATER QUALITY MONITORING RESULTS (SLR, 2016) Date Sample ID Lab ID Ag Al As Au B Ba Be Bi Ca Cd Ce Co Cr Cs Cu Dy Er Eu Fe Ga Gd Ge Hf Hg Ho In Ir K Unit mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l OVERALL MINIMUM OVERALL MAXIMUM SANS 241 (2015) Operational N/A 0.3 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A SANS 241 (2015) Aesthetic N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 0.3 N/A N/A N/A N/A N/A N/A N/A N/A N/A SANS 241 (2015) Acute Heath N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A SANS 241 (2015) Chronic Health N/A N/A 0.01 N/A N/A N/A N/A N/A N/A 0.05 N/A 2 N/A N/A N/A 2 N/A N/A N/A N/A N/A N/A N/A N/A DWAF Water Quality Guidelines (Livestock Watering) Target Quality Range N/A 5 1 N/A 5 N/A N/A N/A N/A 1 1 N/A N/A N/A N/A 10 N/A N/A N/A N/A N/A N/A N/A N/A N/A 2016/01/26 NT1 GW <0.010 < < <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.25 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < /01/26 NT15 GW <0.010 < < <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < /01/26 NT8 GW <0.010 < < <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < /01/26 TSH01 GW <0.010 < < <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < /01/26 TSH03 GW <0.010 <0.100 <0.010 < <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < /01/26 TSH04 GW <0.010 <0.100 <0.010 < <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < /06/30 NT1 GW < < < < < < < < < < < < < < < < < < < < < < < /06/30 NT15 GW < < < < < < < < < < < < < < < < < < < < < < /06/30 NT8 GW < < < < < < < < < < < < < < < < < < < < < < < /06/30 TSH01 GW < < < < < < < < < < < < < < < < < < < < < < < < /06/30 TSH03 GW < < < < < < < < < < < < < < < < < < < < < < < /06/30 TSH04 GW < < < < < < < < < < < < < < < < < < < < < < < TSH06 / < < /06/30 NEX108 GW < < < < < < < < < < < < < < < < < < < < /10/06 Blank < < < < < < < < < < < < < < < < < < < < < < /10/06 NT15 GW < < < < < < < < < < < < < < < < < < < < /10/06 NT8 GW < < < < < < < < < < < < < < < < < < < < < /10/06 TSH01 GW < < < < < < < < < < < < < < < < < < < < < < < /10/06 TSH03 GW < < < < < < < < < < < < < < < < < < < < < < /10/06 TSH04 GW < < < < < < < < < < < < < < < < < < < < < TSH06 / < < < < < < < < < < < < /10/06 NEX108 GW < < < < < < < < < /04/19 NT1 GW 3071 < < < < < < < < < < < < < < < < < < < < < < < < /04/19 NT15 GW 3073 < < < < < < < < < < < < < < < < < < < < < < < < /04/19 NT8 GW 3072 < < < < < < < < < < < < < < < < < < < < < /04/19 TSH01 GW 3067 < < < < < < < < < < < < < < < < < < < < < < /04/19 TSH03 GW 3068 < < < < < < < < < < < < < < < < < < < < < < < /04/19 TSH04 GW 3069 < < < < < < < < < < < < < < < < < < < < < < < TSH06/N < < /04/19 EX108 GW 3070 < < < < < < < < < < < < < < < < < < < < < /02/23 NT1 GW < < < < < < < < < < < < < < < < < < < < < < < < /02/23 NT8 GW < < < < < < < < < < < < < < < < < < < < < < /02/23 NT15 GW < < < < < < < < < < < < < < < < < < < < < < < < /02/23 TSH01 GW < < < < < < < < < < < < < < < < < < < < < < < < /02/23 TSH03 GW < < < < < < < < < < < < < < < < < < < < < < /02/23 TSH04 GW < < < < < < < < < < < < < < < < < < < < < < < TSH06 / GW < < /02/23 NEX108 < < < < < < < < < < < < < < < < < < < < Note: Highlighted cells indicate which water quality standard has been exceeded

73 Page 6-34 Date Sample ID Lab ID La Li Lu Mg Mn Mo Na Nb Nd Ni Os P Pb Pd Pr Pt Rb Rh Re Ru S Sb Sc Se Si Sm Sn Sr Unit mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l OVERALL MINIMUM OVERALL MAXIMUM SANS 241 (2015) Operational N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A SANS 241 (2015) Aesthetic N/A N/A N/A N/A 0.1 N/A 200 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A SANS 241 (2015) Acute Heath N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A SANS 241 (2015) Chronic Health N/A N/A N/A N/A 0.4 N/A N/A N/A N/A 0.07 N/A N/A 0.01 N/A N/A N/A N/A N/A N/A N/A N/A 0.02 N/A 0.04 N/A N/A N/A N/A DWAF Water Quality Guidelines (Livestock Watering) Target Quality Range N/A N/A N/A N/A N/A 1 N/A N/A 0.1 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 0.05 N/A N/A N/A N/A 2016/01/26 NT1 GW <0.010 <0.010 < <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 <0.010 < <0.010 < /01/26 NT15 GW <0.010 <0.010 < < <0.010 < < <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 < <0.010 < /01/26 NT8 GW <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 <0.010 < <0.010 < /01/26 TSH01 GW < < <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 < <0.010 < /01/26 TSH03 GW <0.010 <0.010 < < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < <0.010 <0.010 < <0.010 < /01/26 TSH04 GW < < < <0.010 <0.010 <0.010 < <0.010 <0.010 < <0.010 < <0.010 <0.010 < <0.010 < /06/30 NT1 GW < < < < < < < < < < < < < < < < < < < < < /06/30 NT15 GW < < < < < < < < < < < < < < < < < < < < /06/30 NT8 GW < < < < < < < < < < < < < < < < < < < < < /06/30 TSH01 GW < < < < < < < < < < < < < < < < < < < /06/30 TSH03 GW < < < < < < < < < < < < < < < < < < < < < /06/30 TSH04 GW < < < < < < < < < < < < < < < < < < TSH06 / < < < < < < < < < < < < < < /06/30 NEX108 GW < < < /10/06 Blank < < < < < < < < < < < < < < < < < < < < /10/06 NT15 GW < < < < < < < < < < < < < < < < < /10/06 NT8 GW < < < < < < < < < < < < < < < < < < /10/06 TSH01 GW < < < < < < < < < < < < < < < < < < /10/06 TSH03 GW < < < < < < < < < < < < < < < < < < < < /10/06 TSH04 GW < < < < < < < < < < < < < < < < < TSH06 / < < < < < < < < < < < < < /10/06 NEX108 GW < < /04/19 NT1 GW 3071 < < < < < < < < < < < < < < < < < < < < < < /04/19 NT15 GW 3073 < < < < < < < < < < < < < < < < < < < < < < /04/19 NT8 GW 3072 < < < < < < < < < < < < < < < < < < < < < /04/19 TSH01 GW 3067 < < < < < < < < < < < < < < < < < < < < /04/19 TSH03 GW 3068 < < < < < < < < < < < < < < < < < < < < < /04/19 TSH04 GW 3069 < < < < < < < < < < < < < < < < < < TSH06/N < < < < < < < < < < < < < < /04/19 EX108 GW < < < < /02/23 NT1 GW < < < < < < < < < < < < < < < < < < < < < < /02/23 NT8 GW < < < < < < < < < < < < < < < < < < < < < /02/23 NT15 GW < < < < < < < < < < < < < < < < < < < < < /02/23 TSH01 GW < < < < < < < < < < < < < < < < < < < /02/23 TSH03 GW < < < < < < < < < < < < < < < < < < < < /02/23 TSH04 GW < < < < < < < < < < < < < < < < < < < TSH06 / GW < < < < < < < < < < < < < < /02/23 NEX < < < <

74 Page 6-35 Date Sample ID Ta Tb Te Th Ti Tl Tm U V W Y Yb Zn Zr ph Electrical Total Conducti Dissolve vity d Solids Suspend ed Solids Total Alkalinity as CaCO3 Bicarbon ate as HCO3 Carbonat Chloride e as CO3 as Cl Lab ID Unit mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l ph Unit ms/m mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l mg/l OVERALL MINIMUM OVERALL MAXIMUM SANS 241 (2015) Operational N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A SANS 241 (2015) Aesthetic N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 5 N/A N/A N/A N/A N/A N/A N/A N/A 1.5 SANS 241 (2015) Acute Heath N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 500 N/A 11 N/A SANS 241 (2015) Chronic Health N/A N/A N/A N/A N/A N/A N/A 0.03 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 1.5 N/A N/A DWAF Water Quality Guidelines (Livestock Watering) Target Quality Range N/A N/A N/A N/A N/A N/A N/A N/A 1 N/A N/A N/A 20 N/A N/A N/A 2000 (Cattle an N/A N/A N/A N/A Sulphate as SO4 & poultry) Fluoride as F Nitrate as N Free & Saline Ammonia as N r livestock0 22 N/A 2016/01/26 NT1 GW <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < < < < < /01/26 NT15 GW <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < < < /01/26 NT8 GW <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < < < < /01/26 TSH01 GW <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < < < /01/26 TSH03 GW <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < < < < /01/26 TSH04 GW <0.010 <0.010 <0.010 < <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 < < < < /06/30 NT1 GW < < < < < < < < < < < < < /06/30 NT15 GW < < < < < < < < < < < < < /06/30 NT8 GW < < < < < < < < < < < < < < < /06/30 TSH01 GW < < < < < < < < < < < < < /06/30 TSH03 GW < < < < < < < < < < < < < < < /06/30 TSH04 GW < < < < < < < < < < < < < < TSH06 / < < < < < < < < < < < < < /06/30 NEX108 GW /10/06 Blank < < < < < < < < < < < < < /10/06 NT15 GW < < < < < < < < < < < /10/06 NT8 GW < < < < < < < < < < < < <5 178 < /10/06 TSH01 GW < < < < < < < < < < < < < /10/06 TSH03 GW < < < < < < < < < < < < <5 123 < /10/06 TSH04 GW < < < < < < < < < < < < <5 153 < TSH06 / < < < < < < < < < < < < < /10/06 NEX108 GW < /04/19 NT1 GW 3071 < < < < < < < < < < < < < /04/19 NT15 GW 3073 < < < < < < < < < < < < < < /04/19 NT8 GW 3072 < < < < < < < < < < < < <5 178 < /04/19 TSH01 GW 3067 < < < < < < < < < < < < < < /04/19 TSH03 GW 3068 < < < < < < < < < < < < <5 118 < /04/19 TSH04 GW 3069 < < < < < < < < < < < < <5 141 < TSH06/N < < < < < < < < < < < < < /04/19 EX108 GW 3070 < /02/23 NT1 GW < < < < < < < < < < < < < /02/23 NT8 GW < < < < < < < < < < < < < <5 178 < /02/23 NT15 GW < < < < < < < < < < < < < /02/23 TSH01 GW < < < < < < < < < < < < /02/23 TSH03 GW < < < < < < < < < < < <5 119 < /02/23 TSH04 GW < < < < < < < < < < < < < <5 137 <2 0.6 < TSH06 / GW < < < < < < < < < < < < < < /02/23 NEX108 < *1000 (Dairy, pigs & poultry), 2000 (Cattle and horses), 3000 (Sheep) # 1500 (Monogastric & poultry), 3000 (Other livestock) ~ 0 2 (all other livestock, 0 6 (Ruminants)

75 Page 6-36 CONCLUSION Project infrastructure/activities are such that they indirectly present potential for pollution of groundwater resources through spillages of hydrocarbons. The project must be managed in a way that the reduction of groundwater resources through pollution is prevented.

76 Page Air quality INTRODUCTION AND LINK TO IMPACT Project activities have the potential to contribute to ambient air quality. Existing sources of emissions in the region and the characterisation of existing ambient pollution concentrations is fundamental to the assessment of cumulative air impacts. A change in ambient air quality can result in a range of impacts which in turn may cause a disturbance and/or health impacts to nearby receptors. Potential receptor sites include the residential areas that have been described in Section To understand the basis of these potential impacts, a baseline situational analysis is described below. DATA SOURCES Information in this section was sourced from the air quality assessment undertaken by Airshed Planning Professionals (Airshed, February 2017) for the project and included in Appendix K. Dust fallout monitoring data was sourced from the annual monitoring report compiled by Boletshe Trading Enterprise CC (Boletshe, March 2016). RESULTS Ambient air quality within the region As part of the air quality study (Airshed, February 2017), the following regional sources of emissions were identified: Fugitive dust: Occur as a result of vehicle entrainment of dust from local paved and unpaved roads, wind erosion from open areas and dust generated by agricultural activities. Given that the agriculture in the area is primarily restricted to livestock and game farming, agriculture is not anticipated to contribute significantly to ambient dust rates. Vehicle entrainment from the various unpaved farm and public roads is anticipated to be a significant but localised source of dust. Current mining operations in the area: Operating mines in relatively close proximity to the Tshipi Borwa Mine include Assmang s N Chwaning and Gloria Mines, Samancor s Wessels and Mamatwan Mines, BHP Billition s Hotazel Manganese Mines, Delta Electrical industries Limited and United Manganese of Kalahari. Fugitive dust sources from the abovementioned mining operations may include wind blown dust from open areas, vehicle entrained dust from paved and unpaved roads, dust from materials handling operations and crushing and screening operations. Mamatwan opencast and sintering operations may also include fugitive dust emissions from drilling and blasting as well as point source emissions from the sinter plant. Delta Electrolytic Manganese Dioxide (EMD), owned by Delta Electrical industries Limited, is an ore reduction facility. Atmospheric emissions from this facility may occur as a result of fugitive dust sources (materials handling, vehicle entrainment, wind erosion, etc.) in addition to process emissions from their kiln operations Long-Range Transport of Aerosols: Regionally-transported, aged aerosols (particulates) have been shown to contribute significantly to background particulate concentrations over much of the country

77 Page 6-38 including remote sites. The four main source types include Aeolian crustal material consisting of mineral soil dust, marine aerosols from the two adjacent oceans, biomass burning particles, aerosols from industrial emissions Biomass burning: biomass burning emissions include with carbon monoxide (CO), methane (CH 4 ) and nitrogen dioxide (NO 2 ) gases Veld burning: represent significant sources of combustion-related emissions in many areas of the country Rail related emissions: Emissions from diesel generated locomotives include particulates, nitrogen oxides (NO 2 ), sulphur dioxide (SO 2 ), carbon monoxide (CO) and various volatile organic compounds including polycyclic aromatic hydrocarbons Household fuel combustion: It is likely that households within the district municipality utilise coal or wood for cooking and space heating (during winter) purposes. Emissions from domestic burning include PM 10, nitrogen dioxide (NO 2 ), carbon dioxide (CO 2 ), carbon monoxide (CO), polycyclic aromatic hydrorcarbons, particulate benzo(a)pyrene and formaldehyde Vehicle tailpipe emissions: Significant primary pollutants include carbon dioxide (CO 2 ), carbon monoxide (CO), hydrocarbons (HCs), sulphur dioxide (SO 2 ), oxides of nitrogen (mainly NOx), particulates. Secondary pollutants include NO 2, photochemical oxidants (ozone), sulphur acid, sulphates and nitric acid. Emission sources associated with the Tshipi Borwa Mine The activities associated with the Tshipi Borwa Mine that contribute to ambient air quality include: Diesel generators Vehicle tail pipe emissions Material handling such as crushing, tipping of waste rock and ore, conveying of ore, stockpiles Dust generation from open cast operations (blasting and material handling) Vehicle activity on paved and unpaved roads Wind erosion from exposed working surfaces. These emissions contribute towards both nuisance value, mainly in the immediate area of the source (large particle deposition) and potential increased health impacts (PM 10 ). Dust fallout data Tshipi has a monthly dust fallout monitoring programme in accordance with the approved EIA and EMPr (Metago, May 2009) that commenced in February 2012 and consists of five directional dust buckets. The position of the dustfallout monitoring points is illustrated in Figure 11. Annual dust fallout monitoring results for the period January 2016 to December 2016 are provided in Table 21 below. Dust fallout monitoring results are compared to the non-residential dust fallout limits (600<D<1200) in accordance with the National Dust Control Regulations (NDCR).

78 Page 6-39 Based on the results provided below, dust fallout limits for DW-01, DW-02 and DW-04 remain within the prescribed NDCR non-residential acceptable dust fall rates. Dust fallout for DW-03 and DW-05 exceeded the NDCR non-residential rates six times during The NDCR allows for the exceedance of the nonresidential limits (600 <D< 1200) two times in a year with no sequential months. It follows that DW-03 and DW-05 are in exceedance of the alert dustfall threshold rate of 1200mg/m 2 /day and the permitted frequency of the non-residential dust fall rate. TABLE 21: DUST FALLOUT MONITORING DATA (BOLETSHE, MARCH 2017) DIRECTION MONTHS Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec DW-01 Northern mine boundary North ND East ND South ND ND West ND DW-02 Southern mine boundary North ND East ND South ND West ND DW-03 Eastern mine boundary North ND East ND South ND West ND DW-04 Western mine boundary North ND East ND South ND West ND DW-05 Central location North ND ND ND East ND ND ND South ND ND ND 51.0 West ND ND ND * No data CONCLUSION

79 Page 6-40 Monitoring results indicate that mining and surrounding activities and infrastructure contribute towards sources of emissions such as dust fallout and PM 10 that occasionally exceed relevant NAAQS and NDCR limits. The project presents additional sources of pollutants that may influence existing pollutant concentrations. The activities should therefore be carefully managed to ensure that contributions from the project remain within acceptable limits with associated acceptable impacts Noise INTRODUCTION AND LINK TO IMPACT Certain noise generating activities associated with the project infrastructure/activities could contribute to an increase in ambient noise levels in and around the project area. This may cause a disturbance to nearby receptors. Potential receptor sites include the residential areas that have been described in Section To understand the basis of these impacts, a baseline situational analysis is described below. DATA SOURCE Information in this section was sourced from the approved EIA and EMPr (Metago, May 2009). RESULTS The greater area is generally defined by rural features and is not subjected to elevated noise levels. Existing noise in the project area is mainly caused by surrounding farming activities, localised traffic, train movements, and mining operations. Previously measured ambient noise levels vary from 39 dba during the day to 33 dba during the night. CONCLUSION Project activities have the potential to contribute to disturbing noise levels within and surrounding the project area. It is however important to note that the current land use activities within and surrounding the project area already generate noise. An increase in disturbing noise levels may influence potential noise receptors however this is not the case for this project. Given the relatively small scale of project infrastructure/activities and location immediately adjacent to existing mining activities, the project is absorbed into the overall mining activities and infrastructure.

80 Page Visual aspects INTRODUCTION AND LINK Project infrastructure has the potential to alter the landscape character of the site and surrounding area through the establishment of temporary infrastructure. To understand the basis of these potential impacts, a baseline situational analysis is described below. DATA SOURCE For both the approved EIA and EMPr (Metago, May 2009) and the current project, data collection was sourced from on-site observations by the SLR project team and the review of relevant maps. RESULTS Landscape character The landscape character within the surface use area has been transformed due to Tshipi s approved mining activities. The landscape character towards the south east, south and west of the surface use area is characterised by flat open areas associated with semi-arid vegetation, non-perennial drainage line (Vlermuisleegte River), isolated farmsteads the regional road (R380), gravel roads and the regional powerline. The landscape character directly to the east of the surface use area has been transformed by existing mining activities associated with the Mamatwan Mine, regional road (R380), gravel roads, railway line and powerline infrastructure. The landscape character to the north and north west and north east of the surface use area consists of a combination of open flat areas associated with semi-arid vegetation and non-perennial drainage lines (Witleegte River), mining activities (United Manganese of Kalahari (Pty) Ltd and the old Middelplaats mine), roads and powerline infrastructure. Scenic quality The scenic quality of the project site and surrounding area is linked to the type of landscapes that occur within an area. In this regard, scenic quality can range from high to low as follows: High these include the natural features such as mountains, koppies and drainage systems Moderate these include agricultural activities, smallholdings, and recreational areas Low these include towns, communities, roads, railway line, industries and existing mines. Although numerous mining related structures dominate the landscape to the north, east and north east of the surface use area and the R380, gravel roads, powerlines and the railway line are located to the south, and east of the surface use area, the overall scene is characterised by the Vlermuisleegte and Witleegte Rivers and open views of the bushveld. The result is a landscape with a moderate scenic quality. Sensitivity of Visual Resource It follows that the highest value visual resource described above is also the most sensitive to changes. In contrast, areas that are not considered to have a high scenic value, are expected to be the least sensitive

81 Page 6-42 to change such as the mining and infrastructure areas. Sense of place The sense of place results from the combined influence of landscape diversity and distinctive features. The primary informant of these qualities is the spatial form and character of the natural landscape taken together with the cultural transformations and traditions associated with the historic use and habitation of the area. The site is located within a mining belt. The mining activity, and the infrastructure that supports these mines, dominates the area to the north, east and north east of the surface use area. It follows that the immediate area within and surrounding the surface use area has a relatively weak sense of place (when the viewer is within the mining belt). However, when seen in context with the site surrounded by large open spaces of arid vegetation the harsh nature of the mining activities is softened. When the viewer views the area from outside the mining belt, the larger area has a stronger sense of place. Visual receptors When viewed from the perspective of tourists and residences within the area, mining activities could be associated with a sense of disenchantment. People who benefit from the project (employees, contractors, service providers etc.) may not experience this disenchantment but rather see the mine with a sense of excitement and anticipation. It follows that the sensitive viewer locations are located towards the west and southwest of the surface use area (isolated farmsteads).the less sensitive viewer locations are from within the surface use area as well as areas located to the east, north and north west of the surface use area. CONCLUSION When considering landscape character, scenic quality, visual resource, sense of place and visual receptors the areas within and surrounding the project area have a moderate to low visual value. This indicates that mining and infrastructure activities impact on the available visual resources and that visual resource management must be considered for both current and future operations. Given the relatively small scale of project infrastructure/activities and location immediately adjacent to existing mining activities, the project is absorbed into the overall mining activities and infrastructure Traffic INTRODUCTION AND LINK Traffic from mining developments has the potential to affect the capacity of existing road networks as well as result in noise, air quality and public road safety issues. This section provides an overview of the current road network, conditions and road use. Understanding the layout, use and conditions of transport systems relevant to the project provides a basis for understanding a change as a result of project contributions.

82 Page 6-43 DATA COLLECTION Information was sourced from the traffic specialist study (Siyazi, May 2017) included in Appendix L. The study comprised sourcing relevant data from a site inspection of the existing road network, consultations with the roads authorities, traffic counts, calculations and reference to relevant traffic impact assessment guideline documents. Further details are provided in the traffic study. RESULTS Existing road network Numerous roads are located within and surrounding the Tshipi Borwa Mine. These include the following: The R380 provincial tar road from Hotazel to Khathu, directly adjacent and to the east of Tshipi Borwa Mine; The D3457 gravel road that runs to the south of the project site, leading to the old Middelplaats Mine; and The D3340 gravel road that goes past Rissik. Existing traffic data Manual traffic counts were undertaken at six points within and around the Tshipi Borwa Mine. These included the following: The D3457 and Tshipi Borwa Mine access gate 1; The D3457 and Tshipi Borwa Mine access gate 2; The R380 and R31 intersection; The R380 and D3457 intersection; The D3457 and Mamatwan Mine access road; and The R380 and UMK Mine access road. The results of the manual peak hour traffic counts are include in Table 22 below.

83 Page 6-44 TABLE 22: MANUAL TRAFFIC COUNTS (SIYAZI, MAY 2017) INTERSECTION PEAK TRAFFIC NUMBERS D3457 and Tshipi Borwa Mine access gate 1 06:00 07:00 AM :30 16:30 PM 76 D3457 and Tshipi Borwa Mine access gate 2 06:00 07:00 AM 53 15:30 16:30 PM 43 R380 and R31 intersection 06:00 07:00 AM :30 16:30 PM 378 R380 and D3457 intersection 06:00 07:00 AM :30 16:30 PM 193 D3457 and Mamatwan Mine access road 06:00 07:00 AM :30 16:30 PM 112 R380 and UMK Mine access road. 06:00 07:00 AM :30 16:30 PM 142 Based on the results of the manual traffic counts, the peak traffic hours occur between 06:00 and 07:00 (AM peak), and 15:30 and 16:30 (PM peak). The traffic specialist has concluded that the current level of service for all intersections that were investigated were considered to be operating at a good level of service and are predicted to operate at good levels of service as part of the project. CONCLUSION Impacts on traffic due to the project are manageable on the relevant roads network as long as the mitigation measures are implemented as recommended Heritage/cultural and palaeontological resources INTRODUCTION AND LINK This section describes the existing status of the heritage and cultural environment that may have been affected by the project. Heritage (and cultural) resources include all human-made phenomena and intangible products that are the result of the human mind. Natural, technological or industrial features may also be part of heritage resources as places that have made an outstanding contribution to the cultures, traditions and lifestyles of the people or groups of people of South Africa. Paleontological resources are fossils, the remains or traces of prehistoric life preserved in the geological (rock stratigraphic) record. They range from the well-known and well publicized (such as dinosaur and mammoth bones) to the more obscure but nevertheless scientifically important fossils (such as palaeobotanical remains, trace fossils, and microfossils). Paleontological resources include the casts or impressions of ancient animals and plants, their trace remains (for example, burrows and trackways), microfossils (for example, fossil pollen, ostracodes, and diatoms), and unmineralised remains (for example, bones of Ice Age mammals).

84 Page 6-45 DATA SOURCE Information in this section was sourced from the heritage study (PGS, March 2009) undertaken as part of the approved EIA and EMPr (Metago, May 2009) process and the heritage letter (PGS, February 2017). Data collection was obtained through the review of aerial photographs, topographical maps and existing literature in order to identify topographical areas of possible historic and pre-historic activity. In addition to this, a site survey was undertaken to identify any cultural/heritage resources located within the surface use area (PGS, March 2009). RESULTS The Tshipi Borwa Mine is situated in an area that as a whole has a relatively low human presence due to the dryness of the region, and as such if there are human settlements they tend to be located on or near water courses. As part of the heritage study (PGS, March 2009) undertaken for the approved EIA and EMPr process, no sites of heritage/cultural significance were identified within the surface use area. The low significance heritage resources identified have since been destroyed. The palaeontological sensitivity of the project area is found to be very low. Based on the geology of the area and the palaeontological record it can be assumed that the project will not have any impact on the Kalahari Formation or pose a substantial threat to local fossil heritage. CONCLUSION No palaeontological or heritage resources were found within the project area.

85 Page Socio-economic INTRODUCTION AND LINK Project activities have the potential to result in both positive and negative socio-economic impacts. The positive impacts are usually economic in nature with the project providing support to the mine, which in turn contributes directly towards employment, procurement, skills development and taxes on a local, regional and national scale. In addition, mines indirectly contribute to economic growth in the national, local and regional economies by strengthening the national economy and because the increase in the number of income earning people has a multiplying effect on the trade of other goods and services in other sectors. The negative impacts can be both social and economic in nature. In this regard, the project in support of the mine can cause: Influx of people seeking job opportunities which can lead to increased pressure on basic infrastructure and services (housing, health, sanitation and education), informal settlement development, increased trespassing, increased crime, introduction of diseases and disruption to the existing social structures within communities. A change to not only pre-existing land uses, but also the associated social structure and meaning associated with these land uses and way of life. This is particularly relevant in the closure phase when the economic support provided by mines ends, the natural resources that were available to the pre-mining society are reduced, and the social structure that has been transformed to deal with the threats and opportunities associated with mining finds it difficult to readapt. DATA SOURCE Information in this section was sourced from the JMLM Integrated Development Plan of 2016 and StatsSA. RESULTS Population The Northern Cape Province has a population number of The JTDGM has a population number of while JMLM has a total population of people. The Hotazel community has a total of approximately people. Dwellings The most dominant type of dwelling utilized within the Northern Cape Province, the JTGDM, the JMLM and Hotazel is a formally constructed house or brick structure. This consists of 76% in the Northern Cape Province, 73% within the JTGDM, 71% within the JMLM and 82% within Hotazel. Traditional dwellings (e.g. huts/ structures made of traditional material) are the second highest used dwelling type with percentages ranging from 12% to 22% within the JTGDM and the JMLM respectively. No traditional

86 Page 6-47 dwellings are located within the town Hotazel, rather the second highest used dwelling type is flats. The second highest dwelling type within the Northern Cape Province is informal dwellings (eg. shacks). The population profile of the Northern Cape Province, JTGDM and JMLM demonstrates a consistent average household size of four people per household despite the significant decline in population numbers between the regional levels as reflected in Table 23 below. The local community of Hotazel has a slightly more favourable household size with an average of three members per household. These results are relatively typical of rural or semi-rural developing communities, however the low household density within Hotazel may be attributed to the fact that the town is largely a mining community established for and servicing surrounding mines. TABLE 23: SOCIO ECONOMIC PROFILE - POPULATION CATEGORY NORTHERN CAPE PROVINCE JOHN TAOLO GAETSEWE DISTRICT MUNICIPALITY JOE MOROLONG LOCAL MUNICIPALITY Number of households Average number of people per household HOTAZEL Basic services In general, despite the relatively formalized housing infrastructure, basic services infrastructure appears to be far less formalized. With reference to Table 24, majority of the Northern Cape Province have access to flush toilets and Hotazel primarily utilising the flush toilets, however the JTGDM and the JMLM mostly make use of pit toilets. Similarly, while in general the Northern Cape Province and Hotazel have access to piped water inside dwellings and yards, a large percentage of households rely on piped water to community stands at varying distances from their dwellings in both the JTGDM and the JMLM (Table 24). A total of 64% of the households in the Northern Cape Province have their waste removed by the local municipality or a private company once a week. This depicts that basic services are not provided to the whole province, with 36% of the province not receiving refuse removal services (Table 26). The occurrence of refuse removal by the JTGDM and JMLM constitutes only 26% and 6% of households respectively, however Hotazel is largely (96%) receiving the required services (Table 26). In general, Hotazel is well formalised in terms of basic services. This may be attributed to the Hotazel area being more urbanized having been developed and supported by surrounding mines in recent years. TABLE 24: SOCIO-ECONOMIC PROFILE TOILET FACILITIES CATEGORY NORTHERN CAPE PROVINCE JOHN TAOLO GAETSEWE DISTRICT MUNICIPALITY JOE MOROLONG LOCAL MUNICIPALITY None 8% 9% 10% 1% Flush toilet (connected to sewerage system) 60% 26% 6% 97% Flush toilet (with septic tank) 6% 3% 1% 1% HOTAZEL

87 Page 6-48 CATEGORY NORTHERN CAPE PROVINCE JOHN TAOLO GAETSEWE DISTRICT MUNICIPALITY JOE MOROLONG LOCAL MUNICIPALITY Chemical toilet 1% 1% 2% 0% Pit toilet with ventilation (VIP) 9% 22% 40% 0% Pit toilet without ventilation 11% 34% 37% 1% Bucket toilet 4% 2% 2% 0% Other 2% 2% 2% 1% HOTAZEL TABLE 25: SOCIO-ECONOMIC PROFILE POTABLE WATER ACCESS CATEGORY NORTHERN CAPE PROVINCE JOHN TAOLO GAETSEWE DISTRICT MUNICIPALITY JOE MOROLONG LOCAL MUNICIPALITY HOTAZEL Piped (tap) water inside dwelling/institution 46% 23% 9% 89% Piped (tap) water inside yard 32% 18% 7% 11% Piped (tap) water on community stand: distance less than 200m from dwelling/institution 13% 35% 50% 0% Piped (tap) water on community stand: distance between 200m and 500m from dwelling/institution 4% 13% 18% 0% Piped (tap) water on community stand: distance between 500m and 1000m (1km) from dwelling 2% 5% 5% 0% /institution Piped (tap) water on community stand: distance greater than 1000m (1km) from dwelling/institution 1% 3% 4% 0% No access to piped (tap) water 3% 4% 8% 0% TABLE 26: SOCIO-ECONOMIC PROFILE REFUSE REMOVAL CATEGORY NORTHERN CAPE PROVINCE JOHN TAOLO GAETSEWE DISTRICT MUNICIPALITY JOE MOROLONG LOCAL MUNICIPALITY HOTAZEL Removed by local authority/private company at least once a week 64% 26% 6% 96% Removed by local authority/private company less often 2% 1% 1% 1% Communal refuse dump 2% 2% 1% 0% Own refuse dump 25% 59% 80% 2% No rubbish disposal 5% 7% 11% 1% Other 2% 4% 1% 0% Unspecified 0% 0% 0% 0% Not applicable 0% 0% 0% 0% Education In general, statistics throughout the identified regions indicate poor educational profiles. With reference to Table 27, significant numbers of the population have received no schooling (9% of JTGDM, 13% of JMLM and 8% of the Northern Cape Province) or only limited primary education (35% of JTGDM, 42% of JMLM, 33% of Northern Cape Province and 22% of Hotazel). The average number across the regions

88 Page 6-49 profiled of people completing high school education were relatively consistent (on average 25%) however there is greater disparity when considering Grade 12 education, further education and training and tertiary education. The education profile within Hotazel is more positive in terms of the percentage of the population that have received further education and tertiary education when compared to the Northern Cape Province, the JGDM and the JMLM. TABLE 27: SOCIO-ECONOMIC PROFILE EDUCATION CATEGORY NORTHERN CAPE PROVINCE JOHN TAOLO GAETSEWE DISTRICT MUNICIPALITY JOE MOROLONG LOCAL MUNICIPALITY HOTAZEL No Schooling 8% 9% 13% 3% Primary School 33% 35% 42% 22% High School 28% 24% 21% 27% Grade 12 / Std 10 / Form 5 14% 12% 7% 17% Further Education and Training 1% 2% 0% 5% Tertiary Education 4% 4% 2% 14% Not applicable 12% 14% 15% 13% Other 0% 0% 0% 0 % Economic profile Majority of the population within the Northern Cape, JGDM and JMLM are not economically active, while 48% of the Hotazel population is employed (Table 28). In general, Table 28 is an indication of the job scarcity of the area. TABLE 28: SOCIO-ECONOMIC PROFILE EMPLOYMENT CATEGORY NORTHERN CAPE PROVINCE JOHN TAOLO GAETSEWE DISTRICT MUNICIPALITY JOE MOROLONG LOCAL MUNICIPALITY HOTAZEL Employed 25% 19% 9% 48% Unemployed 9% 8% 5% 5% Discouraged work-seeker 3% 5% 7% 2% Other not economically active 27% 29% 33% 23% Not applicable 36% 39% 46% 23% CONCLUSION In general mining activities has the potential to influence socio-economic conditions both positively and negatively. In the context of this project and it s supporting role to the Tshipi Borwa Mine which will in turn sustain positive socio-economic influences including contributions in various ways to the local and regional economies, while no additional negative socio-economic influences will be included (e.g. inward migration of people with the resultant pressure on basic infrastructure and services, informal settlement

89 Page 6-50 development, increased crime, introduction of diseases and disruption to the existing social structures within established communities) CURRENT LAND USES INTRODUCTION AND LINK Project activities have the potential to affect land uses. This can be caused by physical land transformation and through direct or secondary impacts. The key related potential environmental impacts are: loss of soil, loss of biodiversity, air pollution. To understand the basis of the potential land use impacts, a baseline situational analysis is described below. DATA SOURCE Mining right and land ownership details were sourced from Tshipi and a deedsearch undertaken by SLR as part of the project. On-site and surrounding land use data was sourced from site observations, and the review of topographical maps and satellite imagery. RESULTS MINING AND PROSPECTING RIGHTS Tshipi holds an approved mining right (Reference number NC/30/5/1/2/2/0206MR) on a portion of portion 1 (Currently portion 16) and a portion of portion 2 (Currently portion 17) of the farm Mamatwan 331. The mining right was granted on 7th April 2010 to Ntsimbintle Mining (Pty) Ltd and transferred by registered section 11 to Tshipi on 17th March RESULTS - LAND OWNERS WITHIN THE MINING RIGHT AREA The surface right owners and corresponding title deeds numbers of the land in and adjacent to the surface use area is listed in Table 29 and Table 30 respectively. TABLE 29: LAND OWNERSHIP WITHIN THE SURFACE USE AREA PORTION LANDOWNER TITLE DEED NUMBER Mamatwan 331 Portion 16 (Portion of portion 1) Tshipi é Ntle Manganese Mine T416/2014 Portion 17 (Portion of portion 2) Tshipi é Ntle Manganese Mine T416/2014 Portion 18 (Portion of portion 3) Tshipi é Ntle Manganese Mine T416/2014 Moab 700 Portion 3 Hotazel Manganese Mines (Pty) Ltd T953/2009 TABLE 30: LANDOWNERS ADJACENT TO THE SURFACE USE AREA PORTION LANDOWNER TITLE DEED NUMBER Mamatwan 331 Remaining extent Andries Mathys Van Den Berg T594/ 1987 Portion 1 Hotazel Manganese Mines (Pty) Ltd T2426/2010 Portion 2 T2426/2010

90 Page 6-51 PORTION LANDOWNER TITLE DEED NUMBER Portion 3 T953/2009 Portion 7 Transnet T666/1965 Portion 8 T515/1992 Moab 700 Remaining extent Machiel Andries Kruger T594/1987 Portion 1 Transnet (Pty) Ltd T250/1983 Sinterfontein 748 Portion 0 Hotazel Manganese Mines (Pty) Ltd T2426/2010 Middelplaats 332 Remaining Extent Saltrim Ranches (Pty) Ltd T2297/2006 Portion 1 Terra Nominees (Samancor Manganese) T2397/1996 Portion 4 Hotazel Manganese Mines (Pty) Ltd T2426/2010 Middleplaats184 Whole farm Abraham Johannes De Klerk T1135/1965 Adams 328 Remaining Extent Saltrim Ranches (Pty) Ltd T2297/2006 Portion 1 Elektriesiteitsvoorsieningskommissie T347/1971 Portion 2 T1162/1982 Portion 3 Transnet T1107/1992 Portion 4 Hotazel Manganese Mines (Pty) Ltd T338/2009 Rissik 330 Portion 0 Gideon Poolman Familie Trust T3211/2015 Portion 1 Terra Nominees (Samancor Manganese) T2395/1996 Portion 2 Transnet T515/1992 Portion 3 United Manganese of Kalahari Pty Ltd T2092/2009 Goold 329 Portion 1 Kruger Machiel Andries T399/1977 Portion 2 Kruger Nicolaas Philippus Fourie T455/2010 Portion 5 Hotazel Manganese Mines (Pty) Ltd T2426/2010 Portion 6 Gideon Poolman Familietrust T3211/2015 Portion 8 Transnet T515/1992 Portion 9 Hotazel Manganese Mines (Pty) Ltd T2821/2011 Shirley 367 Portion 0 Leatitia Penny Trust T3464/1997 Portion 1 Annalien Elizabeth Fourie T730/1984 Portion 2 Pretorius Hester Johannes T718/1979 Portion 3 Transnet T43/1993 Smartt 314 Portion 0 Terra Nominees (Samancor Manganese) T2396/1996 Portion 1 Transnet T221/1966 Alton 368 Portion 0 Booysen Jacomina Maria T285/1979 Portion 1 Andries Matthys Duvenhage Testamentere T905/2009 Milner 327 Whole Farm Kruger Machiel Andries T26/1931

91 Page 6-52 RESULTS - LAND CLAIMS According to the Department of Rural Development and Land Reform no land claims have been lodged on the farms Mamatwan 331 and Moab 700. Refer to Appendix E for the proof of consultation with the Department of Rural Development and Land Reform. RESULTS LAND USE WITHIN THE SURFACE USE AREA Land use within the surface use area is limited to the mining activities and infrastructure associated with the Tshipi Borwa Mine. RESULTS LAND USE SURROUNDING THE SURFACE USE AREA Land use surrounding the surface use area is a mixture of agriculture, isolated residence/ residential areas, infrastructure/servitudes and mining activities. More detail is provided below: Agriculture Agricultural activities currently undertaken within the areas surrounding the surface use area includes game farming and livestock grazing. Isolated residence/ residential area With reference to Figure 10, the nearest residential areas to the Tshipi Borwa Mine include the following: The Black Rock mining community located approximately 26 km north west of the mine The Hotazel town situated about 18 km north of the mine The town Kuruman located approximately 48km south east of the mine The town Kathu located approximately 46km to the south of the mine. Due to the lack of available surface water resources in the area, no informal settlements are located in immediate proximity to the Tshipi Borwa Mine. There are sparsely situated residences and farmhouses on the surrounding farms. These are owned and/or occupied by farmers and farm workers and include the following: Farm workers residence located on the farm Middelplaats 332 located approximately 2km north west from the mine (Figure 10) Permanent farm homestead (A. Pyper) located on the farm Middelplaats 332 approximately 2km west of the mine (Figure 10) Permanent farm homestead (Andries van den Berg) located on the farm Mamatwan 331 approximately 2.5km south west of the mine (Figure 10) Permanent farm homestead (Nic Fourie) located on the farm Shirley 367 approximately 2km south of the mine (Figure 10).

92 Page 6-53 Infrastructure and servitudes A 132kV powerline passes to the east of the site, along the R 380 Hotazel to Kathu road (Figure 10). The Sedibeng Vaal-Gamagara water supply pipeline supplies the Tshipi Borwa Mine with process and potable water. A pipeline connection to the Sedibeng Vaal-Gamagara pipeline is located approximately 500m east of the Tshipi Borwa Mine (Figure 10). A railway line connecting Sishen, Mamatwan and Hotazel runs along the east of the surface use area, parallel to the R380 (Figure 10). A servitude right is held by Ntsimbintle Mining (Pty) Ltd for the establishment of a railway siding located on portion 3 of the farm Moab 700 and portion 18 (Portion of portion 3) of the farm Mamatwan 331. Surrounding mines Various other mining operations located in the immediate vicinity of the surface use area include: United Manganese of Kalahari (Pty) Ltd Located approximately 2km north east from the nearest section of the surface use area BHP Billiton (Mamatwan Mine) Located directly adjacent to the eastern boundary of the surface use area) The old Middelplaats Mine (dormant/closed) located approximately 1.6 km north west from the nearest section of the surface use area The old Adams Mine (dormant/closed) Located approximately 600 m east of the nearest section of the surface use area. Sebilo Resources (Pty) Ltd (Sebilo Mine) Located approximately 7.6 km north from the nearest section of the surface use area Mining operations located further afield from the surface use area include the following: Assmang (Pty) Ltd (Gloria Mine) Located approximately 20 km north from the nearest section of the surface use area Kalagadi Manganese (Pty) Ltd (Kalagadi Mine) Located approximately 18 km north west form the nearest section of the surface use area Kudumane Manganese (Pty) Ltd (Kudumane Mine) Located approximately 12 km north from the nearest section of the surface use area The old Hotazel Mine (dormant/closed) Located approximately 15 km north east from the nearest section of the surface use area The old York Mine (dormant/closed) Located approximately 12.8 km north from the nearest section of the surface use area

93 Page 6-54 The old Devon mine (dormant/closed) Located approximately 14.7 km north east from the nearest section of the surface use area CONCLUSION Mining is the only land use that surrounds the project area which may be influenced by the project and associated potential environmental impacts. Given the relatively small scale of project infrastructure/activities and location immediately adjacent to existing mining activities, the project is absorbed into the overall mining activities and infrastructure DESCRIPTION OF SPECIFIC ENVIRONMENTAL FEATURES AND INFRASTRUCTURE ON THE SITE The environmental features in the surface use area are described in Section above, however no notable features are located within the surface use area. Infrastructure within and close to the mine is discussed in Section above. The notable infrastructure within the surface use area includes the Hotazel-Sishen railway siding, the Tshipi Borwa Mine pit and plant infrastructure ENVIRONMENT AND CURRENT LAND USE MAP A conceptual map showing topographical information as well as land uses on and immediately surrounding the surface use area is provided in Figure 10.

94 R ± / Sebilo Mine To Hotazel/ Kuruman 276 1/276 2/ / / /316 3/316 1/ Witleegte 1/ /330 1/ Ga-Mogara UMK Mine 2/ /329 2/366 3/332 4/ Hotazel - Ferrum 132Kv Powerline Middelplaats 8/329 6/329 6/ Solar Plant 16/ Tshipi Borwa Mine /331 3/328 Mamatwan Mine 1/328 2/ / Adams / /331 15/331 7/ Re/700 Re/700 1/ / /367 2/ /367 1/368 1/393 6/ / Vlermuisleegte 2/ /389 2/389 To Kathu Legend TSHIPI E' NTLE MANGANESE MINING Tshipi Borwa Mine Surface Use Area Tshipi Borwa Mine Approved Mining Right Area #* Operating Manganese Mines!( Closed/Dormant Mines Main Roads Secondary Roads!! Power Line Cultivated Land Wetlands (NFEPA) Figure 10 Local Land Use Rivers and Streams 20m Contour Lines Railway Farm Boundaries Farm Portions Meters Scale: 1:62 A3 Projection: Transverse Mercator Datum: WGS1984, Lo23 SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) Fax: +27 (11) May 2017

95 Page ENVIRONMENTAL IMPACTS AND RISKS OF THE ALTERNATIVES This section provides a list of potential impacts on environmental and socio-economic aspects that have been identified in respect of each of the main project actions / activities and processes for each of the project phases in terms of the project alternatives. With reference to Section 6.1 no project alternatives were considered and as such an assessment of alternatives is not applicable to the project.

96 Page METHODOLOGY USED IN DETERMINING THE SIGNIFICANCE OF ENVIRONMENTAL IMPACTS The method for the assessment of environmental issues is set out in Table 31 below. Part A in Table 31 below provides a list of criteria that can be selected in order to rank the severity, duration and spatial scale of an impact. The consequence of the impact is determined by combining the selected criteria ratings allocated for severity, spatial scale and duration in part B of Table 31. The significance of the impact is determined in Part C of Table 31 whereby the consequence determined in part B is combined with the probability of the impact occurring. The interpretation of the impact significance is given in Part D. This assessment methodology enables the assessment of environmental issues including: cumulative impacts, the severity of impacts (including the nature of impacts and the degree to which impacts may cause irreplaceable loss of resources), the extent of the impacts, the duration and reversibility of impacts, the probability of the impact occurring, and the degree to which the impacts can be mitigated. TABLE 31: CRITERIA FOR ASSESSING IMPACTS PART A: DEFINITION AND CRITERIA* Definition of SIGNIFICANCE Definition of CONSEQUENCE Criteria for ranking of the SEVERITY of environmental impacts Criteria for ranking the DURATION of impacts Criteria for ranking the SPATIAL SCALE of impacts H M L Significance = consequence x probability Consequence is a function of severity, spatial extent and duration Substantial deterioration (death, illness or injury). Recommended level will often be violated. Vigorous community action. Moderate/ measurable deterioration (discomfort). Recommended level will occasionally be violated. Widespread complaints. Minor deterioration (nuisance or minor deterioration). Change not measurable/ will remain in the current range. Recommended level will never be violated. Sporadic complaints. L+ Minor improvement. Change not measurable/ will remain in the current range. Recommended level will never be violated. Sporadic complaints. M+ Moderate improvement. Will be within or better than the recommended level. No observed reaction. H+ Substantial improvement. Will be within or better than the recommended level. Favourable publicity. L M H L M H Quickly reversible. Less than the project life. Short term Reversible over time. Life of the project. Medium term Permanent. Beyond closure. Long term. Localised - Within the site boundary. Fairly widespread Beyond the site boundary. Local Widespread Far beyond site boundary. Regional/ national PART B: DETERMINING CONSEQUENCE SEVERITY = L DURATION Long term H Medium Medium Medium Medium term M Low Low Medium Short term L Low Low Medium

97 Page 6-58 SEVERITY = M DURATION Long term H Medium High High Medium term M Medium Medium High Short term L Low Medium Medium SEVERITY = H DURATION Long term H High High High PROBABILITY (of exposure to impacts) Medium term M Medium Medium High Short term L Medium Medium High L M H Localised Within site boundary Site PART C: DETERMINING SIGNIFICANCE Fairly widespread Beyond site boundary Local SPATIAL SCALE Widespread Far beyond site boundary Regional/ national Definite/ Continuous H Medium Medium High Possible/ frequent M Medium Medium High Unlikely/ seldom L Low Low Medium L M H CONSEQUENCE PART D: INTERPRETATION OF SIGNIFICANCE Significance Decision guideline High It would influence the decision regardless of any possible mitigation. Medium It should have an influence on the decision unless it is mitigated. Low It will not have an influence on the decision. *H = high, M= medium and L= low and + denotes a positive impact. 6.7 POSITIVE AND NEGATIVE IMPACTS OF THE ACTIVITY AND ALTERNATIVES With reference to Section 6.1 no project alternatives were considered and as such an assessment of alternatives is not applicable to the project.

98 Page POSSIBLE MITIGATION MEASURES THAT COULD BE APPLIED AND THE LEVEL OF RESIDUAL RISK No issues or concerns have been raised by RI&APs (to date) in relation to the project and as such this section cannot be completed at this stage. Where comments are received during the review of the environmental assessment report, this section will be updated to include possible mitigation measures that are available to accommodate or address issues and concerns raised by RI&APs as well as provide an assessment of the impact or risks associated with the identified possible mitigation measures. 6.9 MOTIVATION WHERE NO ALTERNATIVE SITES WERE CONSIDERED The diesel farm and haul road on the western boundary of the Tshipi Borwa Mine have already been established. It follows that the consideration of site layout, method or technology alternatives is not applicable STATEMENT MOTIVATING THE PREFERRED ALTERNATIVE With reference to Section 6.1, no site layout alternatives were considered and as such this section is not applicable.

99 Page FULL DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY, ASSESS AND RANK THE IMPACTS AND RISKS THE ACTIVITY WILL IMPOSE ON THE PREFERRED SITE THROUGH THE LIFE OF THE ACTIVITY 7.1 DESCRIPTION OF THE PROCESS UNDERTAKEN TO IDENTIFY IMPACTS Environmental and socio-economic impacts associated with the project were identified through site visits, undertaken by SLR, consideration of the project description and site layout and specialist studies. As part of the public participation process, I&APs (Section 6.2) were given an opportunity to provide input to the project through the review of the notification newsletter and adverts. RI&APs will be given a further opportunity to provide input through the review of the environmental assessment report and/or summary. 7.2 DESCRIPTION OF THE PROCESS UNDERTAKEN TO ASSESS AND RANK THE IMPACTS AND RISKS A description of the assessment methodology used to assess the severity of identified impacts (including the nature of impacts and the degree to which impacts may cause irreplaceable loss of resources), the extent of the impacts, the duration and reversibility of impacts, the probability of the impact occurring, and the degree to which the impacts can be mitigated is provided in Section A DESCRIPTION OF THE ENVIRONMENTAL IMPACTS AND RISKS IDENTIFIED DURING THE ENVIRONMENTAL ASSESSMENT PROCESS This section below (Table 32) provides a description of the impacts on environmental and socioeconomic aspects in respect of each of the main project actions / activities and processes that will be assessed in Section 8. TABLE 32: LIST OF IMPACTS AS THEY RELATE TO PROJECT ACTIONS / ACTIVITIES / PROCESSES MAIN ACTIVITY/PROCESS IMPACTS (UNMITIGATED) Site preparation, earthworks and civil works Haul road Diesel storage and handling Hazardous excavations and infrastructure Loss of soil resources and land capability through pollution Loss of soil resources and land capability through physical disturbance Physical destruction of biodiversity General disturbance of biodiversity Contamination of surface water resources Air pollution Road disturbance and traffic safety Hazardous excavations and infrastructure Loss of soil resources and land capability through pollution Loss of soil resources and land capability through physical disturbance Physical destruction of biodiversity General disturbance of biodiversity Contamination of surface water and groundwater resources Air pollution

100 Page 7-2 MAIN ACTIVITY/PROCESS General site management Demolition Rehabilitation Maintenance and aftercare IMPACTS (UNMITIGATED) Hazardous excavations and infrastructure Loss of soil resources and land capability through pollution Loss of soil resources and land capability through physical disturbance Physical destruction of biodiversity General disturbance of biodiversity Contamination of surface water and groundwater resources Air pollution Hazardous excavations and infrastructure Loss of soil resources and land capability through pollution Loss of soil resources and land capability through physical disturbance Physical destruction of biodiversity General disturbance of biodiversity Contamination of surface water and groundwater resources Air pollution Hazardous excavations and infrastructure Loss of soil resources and land capability through pollution Loss of soil resources and land capability through physical disturbance Physical destruction of biodiversity General disturbance of biodiversity Contamination of surface water and groundwater resources Air pollution Hazardous excavations and infrastructure Loss of soil resources and land capability through pollution Loss of soil resources and land capability through physical disturbance Physical destruction of biodiversity General disturbance of biodiversity Contamination of surface water and groundwater resources Air pollution 7.4 ASSESSMENT OF THE SIGNIFICANCE OF EACH IMPACT AND RISK AND AN INDICATION OF THE EXTENT TO WHICH THE ISSUE AND RISK CAN BE AVOIDED OR ADDRESSED BY THE ADOPTION OF MITIGATION MEASURES The assessment of the significance of the impacts identified for the project area included in Section 8. The extent to which the identified impacts can be avoided or addressed by the adoption of mitigation measures is included in Section 8.

101 Page ASSESSMENT OF EACH IDENTIFIED POTENTIALLY SIGNIFICANT IMPACT AND RISK A summary of the assessment of the environmental and socio-economic impacts associated with the project is provided in Table 33 below. A full description of the assessment is included in Appendix F. All identified impacts are considered in an incremental manner.

102 Page 8-2 TABLE 33: ASSESSMENT OF SIGNIFICANT IMPACTS AND RISKS ACTIVITY Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling POTENTIAL IMPACT Hazardous excavations and infrastructure resulting in safety risks to third parties and animals Loss of soil resources and land capability through contamination Loss of soil resources and land capability through physical disturbance Physical destruction of biodiversity ASPECTS AFFECTED Topography Soils and land capability Biodiversity PHASE Construction Operation Decommissioning Closure Construction Operation Decommissioning Closure Construction Operation Decommissioning Closure Construction Operation Decommissioning Closure SIGNIFICANCE (UNMITIGATE D) MITIGATION TYPE Negligible Control through exiting access control Control through existing management and monitoring in place Control through rehabilitation Remedy through emergency response procedure (Section ) High Manage through the implementation of soil conservation management plan and waste management plan Control through rehabilitation Remedy through emergency response procedure (Section ) Medium Manage through the implementation of soil conservation management plan and waste management plan Control through rehabilitation Control through limiting project footprint High Control through limiting the project footprint Control through alien invasive species programme SIGNIFICANCE (MITIGATED) Negligible Low Low Medium EXTENT TO WHICH THE IMPACT CAN BE AVOIDED OR ADDRESSED THROUGH THE IMPLEMENTATION OF MANAGEMENT MEASURES Can be managed/mitigated to acceptable levels Can be managed/mitigated to acceptable levels Can be managed/mitigated to acceptable levels Can be managed/mitigated to acceptable levels

103 Page 8-3 ACTIVITY General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare POTENTIAL IMPACT General disturbance of biodiversity Contamination of surface water and groundwater resources ASPECTS AFFECTED Surface water and Groundwater PHASE Construction Operation Decommissioning Closure Construction Operation Decommissioning Closure Air pollution Air quality Construction Operation Decommissioning Closure SIGNIFICANCE (UNMITIGATE D) MITIGATION TYPE Remedy through rehabilitation close to pre-mining conditions as practically possible. Medium Control through dust control Control through training of employees Control through waste management procedures. Negligible Control through monitoring Remedy through emergency response procedure (Section ) High (Medium for dust fallout) SIGNIFICANCE (MITIGATED) Low Negligible Control through monitoring Medium (Low for dust fallout) EXTENT TO WHICH THE IMPACT CAN BE AVOIDED OR ADDRESSED THROUGH THE IMPLEMENTATION OF MANAGEMENT MEASURES Can be managed/mitigated to acceptable levels Can be managed/mitigated to acceptable levels Can be managed/mitigated to acceptable levels Site preparation Road disturbance Traffic Construction High Control through appropriate design Low Can be managed/mitigated

104 Page 8-4 ACTIVITY Diesel storage and handling POTENTIAL IMPACT and traffic safety ASPECTS AFFECTED PHASE Operation Decommissioning SIGNIFICANCE (UNMITIGATE D) MITIGATION TYPE Control through training of employees Remedy through emergency response procedure (Section ) SIGNIFICANCE (MITIGATED) EXTENT TO WHICH THE IMPACT CAN BE AVOIDED OR ADDRESSED THROUGH THE IMPLEMENTATION OF MANAGEMENT MEASURES to acceptable levels

105 Page SUMMARY OF SPECIALIST REPORT FINDINGS The relevant specialist studies that were undertaken as part of the project, including the recommendations made by the specialists are summarised in Table 32 below. All relevant specialist reports have been attached in the appendices to this environmental assessment report.

106 Page 9-2 TABLE 34: SUMMARY OF SPECIALIST REPORTS STUDIES UNDERTAKEN Soils and land capability Biodiversity study Air Quality Impact Assessment RECOMMENDATION OF SPECIALIST In 2008, the report for the project concerning soils and associated agricultural aspects was compiled by ARC- Institute for Soil, Climate & Water (report no. GW/A/2008/68). The main findings of the report were that the soils in the area were very homogeneous, deep red and yellow sands, but that the main restricting factor was the low annual rainfall, coupled with hot climatic conditions. This had the effect of causing the prevailing arable agricultural potential to be classed as low. Subsequently, the proposed infrastructure layout for the project has been somewhat altered, but remaining within the original project study area. Due to the homogeneous nature of the soils and climate limitations as outlined above, it can confidently be anticipated that there will be no significant change in the soil-related impacts from the project, and thus no need for any further field investigation or report alteration. Mitigation measures to decrease the significance of the construction of the haul road and diesel storage area are limited, as usually, mitigation measures such as a search and rescue operation for protected species are conducted prior to land clearing. Thus mitigation measures would be mainly restricted to rehabilitation of the area post mining. It is recommended that the project include the following mitigation measures: A comprehensive monitoring programme of the protected trees within the area must be undertaken. This monitoring will need to be conducted on an individual basis as well as monitoring at a community level. A suitably qualified professional should assist in developing such a monitoring programme. A long-term comprehensive alien eradication programme should be compiled by a relevant specialist and implemented this process will need to be continuously monitored and updated. It is recommended that the project include the following mitigation measures: A comprehensive dust management plan is required for the mine with specific mitigation measures, the frequency of application and the responsible divisions and persons indicated. This should follow on the dust management measures in the approved EIA and EMPr (Metago, May 2009). Implementation of a dust fallout monitoring network and a PM10 monitoring network as proposed in the approved EIA and EMPr (Metago, May 2009) before any changes or additions to the mine infrastructure are allowed. Traffic assessment The haul road will be located within the mining development boundaries and will not intersect with any public roads nor would it generate any additional vehicle trips outside of the mining development boundaries and therefore no SPECIALIST RECOMMENDATIONS THAT HAVE BEEN INCLUDED IN THE ENVIRONMENTAL ASSESSMENT REPORT (MARK WITH AN X) REFERENCE TO APPLICABLE SECTION IN THIS REPORT X Section 29 X X Section 27 and Section 29 Section 27 and Section 29 X Section 29

107 Page 9-3 STUDIES UNDERTAKEN Heritage assessment RECOMMENDATION OF SPECIALIST calculations or further investigations were conducted for the haul road from a traffic engineering point of view. The project will generate insignificant volumes of traffic along the R380, R31 and the D3457 during peak periods as a result of the transportation of materials for the diesel farm. The project will have a negligible impact on heritage resources and will further not present a loading on any cumulative impact on heritage resources in the area, as the bulk of heritage finds are confined to the riverine areas about 1 km to the west of the study area. Palaeontological The development of the project is unlikely to impact on the local palaeontology. However, should fossil remains be discovered during any phase of construction, either on the surface or exposed by fresh excavations, the ECO responsible for these developments should be alerted immediately. Such discoveries ought to be protected (preferably in situ) and the ECO should alert SAHRA so that appropriate mitigation (e.g. recording, sampling or collection) can be taken by a professional palaeontologist. The specialist involved would require a collection permit from SAHRA. Fossil material must be curated in an approved collection (e.g. museum or university collection) and all fieldwork and reports should meet the minimum standards for palaeontological impact studies developed by SAHRA. SPECIALIST RECOMMENDATIONS THAT HAVE BEEN INCLUDED IN THE ENVIRONMENTAL ASSESSMENT REPORT (MARK WITH AN X) REFERENCE TO APPLICABLE SECTION IN THIS REPORT X Section 29 X Section 27 and Section 29

108 Page ENVIRONMENTAL IMPACT STATEMENT SUMMARY OF KEY FINDINGS OF THE EIA This section provides a summary of the findings of identified and assessed impacts on the receiving environment in both the unmitigated and mitigated scenarios. A summary of the impacts (as per Section 8) in the unmitigated and mitigated scenarios for all project phases is included in Table 35 below. TABLE 35: SUMMARY OF POTENTIAL IMPACTS SECTION POTENTIAL IMPACT SIGNIFICANCE OF THE IMPACT Topography Soils and land capability Hazardous excavations and infrastructure resulting in safety risks to third parties and animals Loss of soil resources and land capability through contamination Loss of soil resources and land capability through physical disturbance (THE RATINGS ARE NEGATIVE UNLESS OTHERWISE SPECIFIED) Unmitigated High Medium Negligible Mitigated Biodiversity Physical destruction of biodiversity High Medium Surface water and Groundwater General disturbance of biodiversity Medium Low Contamination of surface water and groundwater resources Air quality Air pollution High (Medium for dust fallout) Negligible Low Low Medium (Low for dust fallout) Traffic Road disturbance and traffic safety High Low The assessment of the project presents the potential for significant negative impacts to occur (in the unmitigated scenario in particular) on the bio-physical environment, both on the project site and in the surrounding area. It follows that provided the EMPr is effectively implemented there is no environmental, social or economic reason why the project should not proceed FINAL SITE MAP The final site layout plan is included in Appendix G.

109 Page SUMMARY OF THE POSITIVE AND NEGATIVE IMPLICATIONS AND RISKS OF THE ACTIVITY AND IDENTIFIED ALTERNATIVES With reference to Section 6.1, no site layout, method or technology alternatives were considered as part of the project and as such this section is not applicable.

110 Page IMPACT MANAGEMENT OBJECTIVES AND OUTCOMES FOR INCLUSION IN THE EMPR Based on the outcome of the impact assessment and where applicable the recommendations from specialists, the proposed management objectives and outcomes for inclusion into the EMPr are detailed in this section. These align with the mine s approved EIA and EMPr PROPOSED MANAGEMENT OBJECTIVES AND OUTCOMES FOR ENVIRONMENTAL AND SOCIO- ECONOMIC IMPACTS Specific environmental objectives to control, remedy or stop impacts emanating from the project are provided in Table 36 below. TABLE 36: ENVIRONMENTAL OBJECTIVES AND OUTCOMES ASPECT ENVIRONMENTAL OBJECTIVE OUTCOME Topography To prevent physical harm to third parties and To ensure the safety of people and animals animals from potentially hazardous excavations and infrastructure Soil and land capability Biodiversity Surface water and Groundwater To prevent soil pollution and to minimise the loss of soil resources and related land capability through physical disturbance, erosion and compaction To prevent the unacceptable disturbance and loss of biodiversity and related ecosystem functionality through physical destruction To prevent pollution of surface water and groundwater resources and related harm to water users To handle, manage and conserve soil resources to be used as part of rehabilitation and re-establishment of the pre-mining land capability To limit the area of disturbance as far as practically possible To ensure surface water and groundwater quality remains within acceptable limits for both domestic and agricultural purposes. Air To prevent air pollution health impacts To ensure that any pollutants emitted as a result of the project remains within acceptable limits. Traffic To reduce the potential for safety and vehicle related impacts on road users To ensure the mine s use of public roads is done in a responsible manner IMPACTS THAT REQUIRE MONITORING PROGRAMMES Outcomes of the environmental objectives are the implementation of monitoring programmes. Impacts that require monitoring include: Hazardous excavations and infrastructure resulting in safety risks to third parties and animals; Physical destruction and general disturbance of biodiversity; Contamination of surface water and groundwater resources; Increase in air pollution; Traffic increase and road use.

111 Page ACTIVITIES AND INFRASTRUCTURE The source activities of impacts which require management are detailed in Section 3.1 and listed below. Site preparation Demolition Use of haul road Rehabilitation Diesel storage and handling Maintenance and aftercare General site management MANAGEMENT ACTIONS Management actions which will be conducted to control the project activities or processes which have the potential to pollute or result in environmental degradation are detailed in Section ROLES AND RESPONSIBILITIES The key personnel to ensure compliance to this EMPr will be the general manager and the environmental officer and the SHE manager. As a minimum, these roles as they relate to the implementation of monitoring programmes and management activities will include: o Ensure that the monitoring programmes and audits are scoped and included in the annual mine budget; o Identify and appoint appropriately qualified specialists/engineers to undertake the programmes; and o Appoint specialists in a timeously manner to ensure work can be carried out to acceptable standards. Stakeholder Engagement Department and SLP manager o Liaise with the relevant structures in terms of the commitments in the SLP; o Ensure that commitments in the SLP are developed and implemented timeously; o Establish and maintain good working relations with surrounding communities and landowners; and o Facilitate stakeholder communication, information sharing and grievance mechanisms.

112 Page FINAL PROPOSED ALTERNATIVES With reference to Section 6.1, no site layout, method or technology alternatives were considered as part of the project and as such this section is not applicable.

113 Page ASPECTS FOR INCLUSION AS CONDITIONS OF THE AUTHORISATION Management measures including monitoring requirements as outlined in Sections 27 and 29 need to form part of the conditions of the environmental authorisation. With reference to Section 26 of GN.982 of NEMA, additional conditions that need to form part of the environmental authorisation that are not specifically included in the EIA and EMPr report include the following: Tshipi must comply with all applicable environmental legislation whether specifically mentioned in this document or not and which may be amended from time to time.

114 Page ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE Assumptions, uncertainties and limitations associated with the project are included below. No assumptions, uncertainties or limitations were applicable to the following aspects: Topography; Climate; Soils and land capability; Surface water; Groundwater; Noise; Visual; Socio-economic; Economic; and Closure cost ENVIRONMENTAL ASSESSMENT LIMIT The environmental assessment report focused on third parties only and did not assess health and safety impacts on workers because the assumption was made that these aspects are separately regulated by health and safety legislation, policies and standards, and that Tshipi will adhere to these PREDICTIVE MODELS IN GENERAL All predictive models are only as accurate as the input data provided to the modellers. If any of the input data is found to be inaccurate or is not applicable because of project design changes that occur over time, then the model predictions will be less accurate BIODIVERSITY The following assumptions apply to the biodiversity study undertaken for the project (EMS, February 2017): A potential limitation associated with the sampling approach is the narrow temporal window of sampling undertaken as part of the original survey (EMS, November 2008). Ideally, a site should be visited several times during different seasons to ensure that the full complement of plant and animal species present are captured. However, this is rarely possible due to time and cost constraints. The information presented in this report represents the wet/summer season survey (Summer or wet season data is always preferable in the northern cape as it facilitates identification). A full plant species list was compiled for the site from the site visits; this was complemented by a list of any listed

115 Page 14-2 species which are known from other studies to occur in the broad vicinity of the site. The lists of amphibians, reptiles and mammals for the site are based on those observed at the site as well as those likely to occur in the area based on their distribution and habitat preferences. This represents a sufficiently conservative and cautious approach that takes account of the study limitations. The Tshipi Borwa Mine is not located in any known CBA s. No information is currently available on the fine scale distribution of Aquatic Dependent Ecosystems (ADEs), type of plant association, (singly, in stands or gallery forests), aquifer association, condition of vegetation etc. and therefore a precautionary approach should be taken when developing in and around these systems until such time that the research data indicates whether or not they are in fact CBAs. There is no quantitative analysis of the resource base for the protected trees (Vachellia erioloba and Vachellia haematoxylon) thus it is not known how many of the trees can be removed from an area without detrimentally affecting the overall population numbers. No additional survey was undertaken as part of this updated report. The vegetation map presented in this report has therefore been compiled from the original survey, thus the areas that have subsequently been mined and developed have not been included, and are still represented by the original vegetation communities. There is a constraint with respect to reporting the effect of disturbance and additional impacts when the raw data is out of date. As the vegetation data has not been updated the report can only assess the area as if it had not been disturbed at all and express an opinion as to how the project may or may not have affected the biodiversity based on the original data. It is important to note that impacts are unlikey to change, however additional management actions may be required based on the findings of the monitoring programme AIR QUALITY The study followed a qualitative approach, with no emissions quantified for the project. The following was assumed: The mining rate would remain the same; and The modelled impacts from the 2009 study were used to qualitatively assess the potential for any increases in ground level concentrations TRAFFIC IMPACT ASSESSMENT The relevant property of the existing mining development is currently zoned for mining purposes. For the purpose of this traffic impact assessment, the following assumptions are made: That the average rate of growth of vehicle traffic in the area under investigation that is not relevant to the existing mining development (background traffic) between the 2017 manual traffic counts and the 2027 scenarios was anticipated at 3% per annum; and

116 Page 14-3 That the vehicle traffic absorption rate (rate at which existing developments attract vehicular traffic) by all other types of completed developments will maintain the same status for the next ten years HERITAGE/ CULTURAL AND PALAEONTOLOGICAL RESOURCES The accuracy and reliability of desktop Palaeontological Impact Assessments as components of heritage impact assessments are normally limited by the following restrictions: Fossil databases that have not been kept up-to-date or are not computerised. These databases do not always include relevant locality or geological information. The accuracy of geological maps where information may be based solely on aerial photographs and small areas of significant geology have been ignored. The sheet explanations for geological maps are inadequate and little to no attention is paid to palaeontological material. Impact studies and other reports (e.g. of commercial mining companies) - is not readily available for desktop studies. Large areas of South Africa have not been studied palaeontologically. Fossil data collected from different areas but in similar Assemblage Zones might however provide insight on the possible occurrence of fossils in an unexplored area. Desktop studies therefore usually assume the presence of unexposed fossil heritage within study areas of similar geological formations.

117 Page REASONED OPINION AS TO WHETHER THE ACTIVITY SHOULD OR SHOULD NOT BE AUTHORISED REASONS WHY THE ACTIVITY SHOULD BE AUTHORIZED OR NOT The assessment of the project presents the potential for significant negative impacts to occur (in the unmitigated scenario in particular) on the bio-physical environment both on the project site and in the surrounding area. However, with mitigation these impacts can be prevented or reduced to acceptable levels. It follows that provided the EMPr is effectively implemented, there is no environmental, social or economic reason why the project should not proceed CONDITIONS THAT MUST BE INCLUDED IN THE AUTHORISATION Specific conditions for inclusion in the EMPR Refer to Section Rehabilitation requirements Refer to Section 28.

118 Page PERIOD FOR WHICH AUTHORISATION IS REQUIRED The estimated life of mine is 20 years. The mine has been operational for seven years.

119 Page UNDERTAKING I, Marline Medallie, the Environmental Assessment Practitioner responsible for compiling this report, undertake that: the information provided herein is correct; the comments and inputs from stakeholders and I&APs have been included; inputs and recommendations from the specialist reports have been included where relevant; and any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested or affected parties. Signature of EAP Date Signature of commissioner of oath Date

120 Page FINANCIAL PROVISION METHOD TO DERIVE THE FINANCIAL PROVISION The financial provision for the project has been incorporated into the financial provision for the overall Tshipi Borwa Mine as at December 2016 and in accordance with the Guideline Document for the Evaluation of the Quantum of Closure-Related Financial Provision Provided by a Mine (DMR guideline). The next financial provision for the overall mine will be determined in accordance with the NEMA Regulations (1147 of 2015) pertaining to the financial provision for mining operations. Further detail is provided in Section CONFIRM THAT THE AMOUNT CAN BE PROVIDED FOR FROM OPERATING EXPENDITURE The amount required in order to manage and rehabilitate the environment is provided for in the operating costs.

121 Page DEVIATIONS FROM SCOPING REPORT AND APPROVED PLAN OF STUDY DEVIATION FROM THE METHODOLOGY USED IN DETERMINING THE SIGNIFICANCE OF POTENTIAL ENVIRONMENTAL IMPACTS AND RISKS This section is not applicable given that a section 24G rectification process only requires the submission of an environmental assessment report and does not include a scoping phase MOTIVATIONS FOR DEVIATION With reference to Section above, this section is not applicable.

122 Page SPECIFIC INFORMATION REQUIRED BY THE COMPETENT AUTHORITY To date, no specific information other than the requirements specified in section 24G (1) of the NEMA was requested by the DMR.

123 Page OTHER MATTERS REQUIRED IN TERMS OF SECTIONS 24(4)(A) AND (B) OF THE ACT No other matters are required in terms of Section 24(4)(a) and (b) of the act.

124 Page ii PART B ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

125 Page DETAILS OF THE EAP It is hereby confirmed that the details of the EAP who undertook the EIA and prepared this EMPr are provided in Part A, Section 1 of the environmental assessment report.

126 Page DESCRIPTION OF THE ASPECTS OF THE ACTIVITY It is hereby confirmed that the activities covered by this EMPr are fully described in Part A, Section 3 of the environmental assessment report.

127 Page COMPOSITE MAP A map indicating all surface infrastructure superimposed on the environmental sensitive areas of the preferred site is included in Appendix G.

128 Page DESCRIPTION OF THE IMPACT MANAGEMENT OBJECTIVES INCLUDING MANAGEMENT STATEMENT 25.1 DETERMINATION OF CLOSURE OBJECTIVES The closure objectives for the project were adopted from the mine s approved EMPr and determined taking into account the existing type of environment as described in Section 6.4.1, in order to ensure that the closure objectives strive to achieve a condition approximating its natural state as far as possible. Further information pertaining to the closure objectives identified for the project, refer to Section THE PROCESS FOR MANAGING ENVIRONMENTAL DAMAGE AS A RESULT OF UNDERTAKING THE ACTIVITY The management measures outlined in Section 27 have been identified in order to manage and reduce impacts associated with the project in order to prevent unnecessary damage to the environment as a result of the project. In the event that incidents occur that may result in environmental damages the emergency response procedure as outlined in Section 30.2 will be implemented to avoid pollution or degradation POTENTIAL RISK OF ACID MINE DRAINAGE The project does not have the potential to generate acid mine drainage STEPS TAKEN TO INVESTIGATE, ASSESS AND EVALUATE THE IMPACT OF ACID MINE DRAINAGE With reference to Section 25.3, the project does not have the potential to generate acid mine drainage and as such this section is not applicable ENGINEERING OR MINE DESIGN SOLUTIONS TO AVOID OR REMEDY ACID MINE DRAINAGE With reference to Section 25.3, the project does not have the potential to generate acid mine drainage and as such this section is not applicable MEASURES IN PLACE TO REMEDY RESIDUAL OR CUMULATIVE IMPACT FROM ACID MINE DRAINAGE With reference to Section 25.3, the project does not have the potential to generate acid mine drainage and as such this section is not applicable.

129 Page VOLUMES AND RATE OF WATER USE FOR MINING Existing water supply services and support infrastructure established as part of the mine were used to support the widening of the haul road and establishment of the diesel farm and pipeline network. No additional water supply is required as part of the project HAS A WATER USE LICENCE BEEN APPLIED FOR? The infrastructure components applied for as part of this report do not require a water use license. It follows that applying for a water use license as part of the project is not applicable IMPACTS TO BE MITIGATED IN THEIR RESPECTIVE PHASES The section below focuses on mitigation measures that are specific to listed activities based on actions outlined in Section 27.

130 Page 25-1 TABLE 37: MEASURES TO REHABILITATE THE ENVIRONMENT AFFECTED BY THE LISTED ACTIVITIES ACTIVITIES (LISTED: NEMA) PHASE SIZE AND Number Description SCALE OF DISTURBANC E GNR 983 List 1 Activity 51: GNR 983 List 1 Activity 60 The expansion and related operation of facilities for the storage, or storage and handling, of a dangerous good, where the capacity of such storage facility will be expanded by more than 80 cubic meters. The expansion and related operation of facilities or infrastructure for the bulk transportation of dangerous goods in liquid form, outside an industrial complex, using pipelines, exceeding 1,000 meters in length, with a throughput capacity more than 50 cubic meters per day. Constructio n Operation Decommiss ioning Closure Constructio n Operation Decommiss ioning Closure MITIGATION MEASURES ~5 ha. Mitigation measures that have been identified as part of this project include the following: At closure the hazardous infrastructure will be removed and the disturbed area rehabilitated in a manner that it does not present a long term safety and/or stability risk litres (996m 3 ) ~ 0.298ha. Mitigation measures that have been identified as part of this project include the following: Specifications for post rehabilitation audit should be determined and implemented to ascertain whether the remediation of any polluted soils and re-establishment of soil functionality has been successful and if not, to recommend and implement further measures. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: Rehabilitation will be undertaken in line with an approved mine closure plan that ensures a suitable post-closure land use is achieved. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: Tshipi will continue to implement a biodiversity action plan COMPLIANCE WITH STANDARDS The mitigation action to implement an alien invasive species programme is in accordance with the NEMBA Alien and Invasive Species Regulations (2014) that requires the control of invasive species. Compliance with the National Heritage Resource Act No. 25 of 1999 in the event of any chance finds. TIME PERIOD FOR IMPLEME NTATION As required As required On-going On-going

131 Page 25-2 ACTIVITIES (LISTED: NEMA) PHASE SIZE AND Number Description SCALE OF DISTURBANC E GNR 983 List 1 Activity 56: The widening of a road by more than 6 metres, or the lengthening of a road by more than 1 kilometre (i) where the existing reserve is wider than 13.5 metres; or (ii) where no reserve exists, where the existing road is wider than 8 metres; Constructio n Operation Decommiss ioning Closure Widening of existing gravel roads ~ 4.5ha MITIGATION MEASURES that will be refined and implemented in consultation with DAFF and a qualified specialist. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: Tshipi will implement an alien/invasive/weed management programme in collaboration with the DENC and DAFF to control the spread of these plants onto and from disturbed areas. Care will be taken to prevent the encroachment of these species into rehabilitated areas. COMPLIANCE WITH STANDARDS TIME PERIOD FOR IMPLEME NTATION On-going

132 Page IMPACT MANAGEMENT OUTCOMES The section below provides a description of the outcomes and objective of mitigation actions in order to manage, remedy, control or modify potential impacts. The mitigation actions identified to achieve these outcomes and objectives are described in Section 27. TABLE 38: DESCRIPTION OF IMPACT MANAGEMENT OUTCOMES ACTIVITY POTENTIAL IMPACT AFFECTED ASPECT PHASE MITIGATION TYPE STANDARD TO BE ACHIEVED (IMPACT MANAGEMENT OUTCOME/OBJECTIVES) Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Hazardous excavations and infrastructure resulting in safety risks to third parties and animals Loss of soil resources and land capability through contamination Loss of soil resources and land capability through physical disturbance Topography Soils and land capability Soils and land capability Construction Operation Decommissioning Closure Construction Operation Decommissioning Closure Construction Operation Decommissioning Closure Control through exiting access control Control through existing management and monitoring in place Control through rehabilitation Remedy through emergency response procedure (Section ) Manage through the implementation of soil conservation management plan and waste management plan Control through rehabilitation Remedy through emergency response procedure (Section ) Manage through the implementation of soil conservation management plan and waste management plan Control through rehabilitation Control through limiting project To ensure the safety of people and animals in order to prevent physical harm from potentially hazardous excavations and infrastructure To ensure that soil resources are handled and managed properly in order to conserve these resources for use as part of rehabilitation which will assist with the restoration of pre-mining land capability as far as possible. To ensure that soil resources are handled and managed properly in order to conserve these resources for use as part of rehabilitation which will assist with the restoration

133 Page 26-2 ACTIVITY POTENTIAL IMPACT AFFECTED ASPECT PHASE MITIGATION TYPE STANDARD TO BE ACHIEVED (IMPACT MANAGEMENT OUTCOME/OBJECTIVES) Maintenance and aftercare footprint of pre-mining land capability as far as possible. Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling General site management Demolition Physical destruction of biodiversity General disturbance of biodiversity Contamination of surface water and groundwater resources Biodiversity Biodiversity Surface water and Groundwater Construction Operation Decommissioning Closure Construction Operation Decommissioning Closure Construction Operation Decommissioning Closure Air pollution Air quality Construction Operation Decommissioning Closure Control through limiting the project footprint Control through alien invasive species programme Remedy through rehabilitation close to pre-mining conditions as practically possible. Control through dust control Control through training of employees Control through waste management procedures. Control through monitoring Remedy through emergency response procedure (Section ) To prevent the unacceptable disturbance and loss of biodiversity and related ecosystem functionality through physical destruction and to limit the area of disturbance as far as possible. To prevent the unacceptable disturbance and loss of biodiversity and related ecosystem functionality through physical disturbance. To ensure surface water and groundwater quality remains within acceptable limits for both domestic and agricultural purposes to prevent pollution of surface water and groundwater resources and related harm to water users. Control through monitoring To ensure that any pollutants emitted as a result of the proposed project remain with acceptable limits so as to prevent health related

134 Page 26-3 ACTIVITY POTENTIAL IMPACT AFFECTED ASPECT PHASE MITIGATION TYPE STANDARD TO BE ACHIEVED (IMPACT MANAGEMENT OUTCOME/OBJECTIVES) Rehabilitation impacts. Maintenance and aftercare Site preparation Diesel storage and handling Road disturbance and traffic safety Traffic Construction Operation Decommissioning Control through appropriate design Control through training of employees Remedy through emergency response procedure (Section ) To ensure the mine s use of public roads is done in a responsible manner to reduce the potential for safety and vehicle related impacts on road users.

135 Page IMPACT MANAGEMENT ACTIONS The mitigation actions for all phases (operation, decommissioning and closure) to achieve the objectives and outcomes set out in Section 26 are listed in tabular format below. The action plans include the timeframes for implementing the mitigation actions together with a description of how mitigation actions comply with relevant standards. Mitigation actions and recommendations identified by specialists have been summarised and are included in Table 39 below. TABLE 39: DESCRIPTION OF IMPACT MANAGEMENT ACTIONS ACTIVITY Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling POTENTIAL IMPACT Hazardous excavations and infrastructure resulting in safety risks to third parties and animals Loss of soil resources and land capability through MITIGATION MEASURES Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: In case of incident or death due to hazardous excavations, the emergency response procedure in Section will be followed. Mitigation measures that have been identified as part of this project include the following: Tshipi will survey its mining and surface use area on a routine basis to ensure that the position and extent of all potential hazardous infrastructure is known as part of decommissioning. Tshipi will furthermore ensure that appropriate management actions are taken to mitigate the related safety risks to third parties and animals. At closure the hazardous infrastructure will be removed and the disturbed area rehabilitated in a manner that it does not present a long term safety and/or stability risk. Until hazardous excavations (infrastructure) are rehabilitated and closed, they will each have a barrier to prevent access by people and animals. The barrier may be in the form of fences, walls or berms. In addition, the barriers must have warning signs at appropriate intervals. These warning signs must be in picture format and/or written in English. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: Tshipi will conduct all potentially polluting activities (i.e. transportation, handling and storage) in a manner that pollutants (such as hazardous chemicals (explosives) (new TIME PERIOD FOR IMPLEMENTATION On-going As required On-going As required On-going COMPLIANCE WITH STANDARDS Not applicable Not applicable

136 Page 27-2 ACTIVITY General site management Demolition Rehabilitation Maintenance and aftercare POTENTIAL IMPACT contamination MITIGATION MEASURES and used) and fuel) are contained at source do not pollute soils. In this regard, the mine will ensure that: o All vehicles and mobile equipment are serviced and that this is done in workshops and washbays with contained impermeable, floors, dirty water collection facilities and oil traps; o All new and used chemicals (explosives) and fuel storage and handling facilities will be designed and operated in a manner that all spillages are contained in impermeable areas and cannot be released into the environment; o Ad hoc spills of potentially polluting substances (whether in dirty areas or in the environment) will be reported to the environmental manager immediately and cleaned up/remediated immediately; and o The waste management practices, as set out in Table 40 below is implemented. TIME PERIOD FOR IMPLEMENTATION COMPLIANCE WITH STANDARDS Site preparation Use of haul road Diesel storage and handling General site management Demolition Loss of soil resources and land capability through physical disturbance Mitigation measures that have been identified as part of this project include the following: All employees (temporary and permanent) are educated and trained in pollution prevention Steps are in place to enable fast reaction to contain and remediate pollution incidents. Specifications for post rehabilitation audit should be determined and implemented to ascertain whether the remediation of any polluted soils and re-establishment of soil functionality has been successful and if not, to recommend and implement further measures. In case of major spillage incidents the emergency response procedure in Section will be followed. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: Tshipi will implement the soil conservation procedure as set out in Table 41. Rehabilitation will be undertaken in line with an approved mine closure plan that ensures a suitable post-closure land use is achieved. On-going On-going As required As required On-going On-going Not applicable

137 Page 27-3 ACTIVITY Rehabilitation Maintenance and aftercare Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare POTENTIAL IMPACT Physical destruction of biodiversity MITIGATION MEASURES Mitigation measures that have been identified as part of this project include the following: Land disturbance by on-going activities will be limited to those activities and areas that are described in the environmental assessment report. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: Tshipi will continue to implement a biodiversity action plan that will be refined and implemented in consultation with DAFF and a qualified specialist. Pods of the Camel Thorn (Vachellia erioloba) and the Grey Camel Thorn (Vachellia haematoxylon) will continue to be collected in order to aid in the re-establishment of these species. Necessary steps (such as artificial scarring/acid washing) will be taken in order to aid in germination of these species. Management of the rehabilitated areas will consider an after care programme, which will aid in ensuring that the correct species are able to re-establish. TIME PERIOD FOR IMPLEMENTATION On-going On-going On-going On-going COMPLIANCE WITH STANDARDS In addition, a biodiversity offset will be implemented should this be requested by DAFF in accordance with the relevant biodiversity offset guidelines. Issues that will be considered in the biodiversity offset with guidance from DAFF are as follows: The size of the potentially affected area The conservation status of the potentially affected area The offset ratio (in terms of the required size of the offset site) to be applied Evaluation of alternative offset sites on the basis of: compensation for the mine s negative impact on biodiversity, long term functionality, long term viability, contribution to biodiversity conservation in the Northern Cape including linkages to areas of conservation importance, acceptability to IAPs, management of negative impacts on local communities, distances from other mines in relation to dust fallout and other impacts, and biodiversity condition scores as compared to that at the UMK site Land ownership now and in the future Status/security of the offset site, ie. will it receive conservation status Measures to guarantee the security, management, monitoring and auditing of the offset Capacity of Tshipi to implement and manage the offset (collaboration with On-going

138 Page 27-4 ACTIVITY Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare POTENTIAL IMPACT General disturbance of biodiversity MITIGATION MEASURES surrounding mine s offsets may be an option) Identification of unacceptable risks associated with the offset The start up and ongoing costs associated with the offset for the life of the project. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: Tshipi will implement an alien/invasive/weed management programme in collaboration with the DENC and DAFF to control the spread of these plants onto and from disturbed areas. Care will be taken to prevent the encroachment of these species into rehabilitated areas. Mitigation measures that have been identified as part of this project include the following: Vertebrates should be kept away from the illuminated areas with appropriate fencing where feasible There is training for workers on the value of biodiversity and the need to conserve the species and systems that occur at the Tshipi Borwa Mine There is zero tolerance of the killing or collecting of any biodiversity by anybody working for or on behalf of Tshipi Strict speed control measures are used for any vehicles driving within the Tshipi Borwa Mine area Noisy and/or vibrating equipment will be well maintained to control noise and vibration emission levels Dust control measures will be implemented as discussed under the air quality section in this appendix Pollution and litter prevention measures will be implemented as outlined in Table 40 and Table 41. A comprehensive monitoring programme of the protected trees will be implemented, on an individual tree basis as well as monitoring at a community level. The area will be defined with input from a specialist. A suitably qualified specialist should assist in developing such a monitoring programme. Depending on the results of the monitoring programme, additional management actions can be recommended by the qualified specialist. In case of major spillage incidents the emergency response procedure in Section TIME PERIOD FOR IMPLEMENTATION On-going On-going On-going On-going On-going On-going On-going On-going On-going As required COMPLIANCE WITH STANDARDS

139 Page 27-5 ACTIVITY Site preparation Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare POTENTIAL IMPACT Contamination of surface water and groundwater resources MITIGATION MEASURES will be followed. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: All hazardous chemicals (explosives (new and used) and fuel) must be handled in a manner that they do not pollute surface water. This will be implemented by means of the following: o Pollution prevention through maintenance of equipment; o Pollution prevention through education and training of workers (permanent and temporary); o Pollution prevention through appropriate management of hazardous materials as outlined in Table 40; o The required steps to enable containment and remediation of pollution incidents; o Specifications for post rehabilitation audit criteria to ascertain whether the remediation has been successful and if not, to recommend and implement further measures. Tshipi will implement a monitoring programme for surface water within and outside the vicinity of its operations. The surface water monitoring programme must also focus on surface water sampling of different project dirty water streams, any unplanned discharges, and monitoring both up and downstream of the Vlermuisleegte of the mining operations when possible (the possibility of monitoring water in the Vlermuisleegte River may only arise during heavy periods of rain). Details of the surface water monitoring programme is outlined in Section 29. Should any surface water resource contamination be detected, the mine will immediately notify DWS. Tshipi in consultation with DWS and an appropriately qualified person, will then notify potentially affected users, identify the source of contamination, identify measures for the prevention of this contamination (in the short term and the long term) and then implement these measures. Any related loss caused by the mine (in the short and long term) will be addressed through compensation, which may include an alternative water supply of equivalent quality and quantity. Tshipi will continue to monitor groundwater quality (refer to Section 29 for the monitoring programme). The existing monitoring network is considered sufficient to detect any pollution related to the revised site layout. Should any off-site TIME PERIOD FOR IMPLEMENTATION On-going On-going As required On-going COMPLIANCE WITH STANDARDS Not applicable.

140 Page 27-6 ACTIVITY Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare POTENTIAL IMPACT Air pollution MITIGATION MEASURES contamination be detected, the mine will immediately notify DWS. The mine, in consultation with DWS and an appropriately qualified person, will then notify potentially affected users, identify the source of contamination, identify measures for the prevention of this contamination (in the short term and the long term) and then implement these measures. If water users experience any Tshipi related contamination and related loss of water supply, Tshipi will provide compensation, which could include an alternative water supply of equivalent water quality and quantity. Prior to closure, the ground water model will be re-run to consider potential pollution impacts without the retardation effect of pit dewatering. If necessary, provision will be made by the mine for post closure compensation that may be required for any future negative impacts. This will form part of detailed closure planning. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: The following specific measures will be implemented: o o o Treatment as many roads as possible; A target dust control efficiency of 90% can be achieved by maintaining strict control of driving speeds and a combination of chemical dust binding agent and/or water suppression along roads; A 90% reduction in PM10, TSP, and Mn emissions from vehicle movement of paved roads can be achieved through sweeper on paved road surfaces. Tshipi will develop and implement other key elements of an air quality control system. This system will include inter alia: o Monitoring in accordance with Section 29. TIME PERIOD FOR IMPLEMENTATION As required As required On-going On-going COMPLIANCE WITH STANDARDS Not applicable. Mitigation measures that have been identified as part of this project include the following: A comprehensive dust management plan is required for the mine with specific mitigation measures, the frequency of application and the responsible divisions and persons indicated. This should follow on the dust management measures in the approved EIA and EMPr (Metago, May 2009). A complaints register should be available at the mine. The date and time noted on the complaints register should be the date and time that the reported problem is On-going On-going

141 Page 27-7 ACTIVITY Site preparation Diesel storage and handling POTENTIAL IMPACT Road disturbance and traffic safety MITIGATION MEASURES observed, not the date and time that the complaint is logged. If used correctly, the complaints register can be compared to monitoring data as well as recorded meteorological data to identify problem areas and to iteratively adjust the dust management plan to ensure efficient and effective mitigation of fugitive dust sources. If monitoring determines that third parties (surrounding land uses) will be exposed to cumulative concentrations of manganese or PM10 a health risk assessment will be commissioned. Commissioning this health risk assessment, including the implementation of any related management actions, is the responsibility of both Tshipi and other contributing mines. Mitigation measures included below are taken from the mine s approved EMPr and apply to this project: Tshipi will provide data to Transnet regarding the number of vehicles making use of the railway crossing on the D3457. Transnet will be requested to comment on the related safety issues and whether there is a need to upgrade this crossing. If there is a need to upgrade the crossing all relevant role players will have to work together to implement the upgrade. In regard to road maintenance, Tshipi in conjunction with the relevant road authorities and other role players in the area will continue to monitor the quality and lifespan of the roads used by the mines and determine if a road maintenance plan should be implemented. The mine will record and respond, appropriately and immediately, to any complaints about usage of roads by mine vehicles. TIME PERIOD FOR IMPLEMENTATION As required On-going On-going As required COMPLIANCE WITH STANDARDS Not applicable Mitigation measures that have been identified as part of this project include the following: Provide mine and contractor workers with training on road safety and adhering of road rules. Road safety and awareness campaigns should be run at the mine. In case of a person or animal being injured by transport activities the emergency response procedure in Section will be followed. On-going On-going As required

142 Page 27-8 The waste management and soil conservation procedures applicable to the Tshipi Mine and approved in the EIA and EMPr (Metago, 2009) that will be applied to the project are included in Table 40 and Table 41 below. TABLE 40: WASTE MANAGEMENT PROCEDURES FOR GENERAL AND HAZARDOUS WASTE Items to be considered General Specific Classification General and record keeping Waste opportunity analysis Waste management Classification Safety data sheets Inventory of wastes produced Labelling and inventory of waste produced Disposal record Record keeping Collection points Laydown/ salvage areas General waste Scrap metal and building rubble Hazardous wastes Intentions The waste management procedure for the mine will cover the storage, handling and transportation of waste to and from the mine. The mine will ensure that the contractor s responsible are made aware of these procedures. In line with DWEA s strategy to eliminate waste streams in the longer term, Tshipi will assess each waste type to see whether there are alternative uses for the material. This will be done as a priority before the disposal option. Wastes (except those listed in Annexure 1 of the new Waste Regulations) will be classified in accordance with SANS within one hundred and eighty (180) days of generation. Waste will be re-classified every five (5) years, or within 30 days of modification to the process or activity that generated the waste, changes in raw materials or other inputs, or any other variation of relevant factors. The mine will maintain, where required in terms of the Regulations, the safety data sheets for hazardous waste (prepared in accordance with SANS 10234). The mine will keep an accurate and up to date record of the management of the waste they generate, which records must reflect: the classification of the wastes; the quantity of each waste generated, expressed in tons or cubic metres per month; the quantities of each waste that has either been re-used, recycled, recovered, treated or disposed of; and by whom the waste was managed. Any container or storage impoundment holding waste must be labelled, or where labelling is not possible, records must be kept, reflecting: the specific category or categories of waste in the container or storage impoundment as identified in terms of the National Waste Information Regulations, 2012; and the classification of the waste in terms of Regulation 4 once it has been completed (if required). Written evidence of safe disposal of waste will be kept. Records will be retained for a period of at least 5 years and will be made available to the Department on request. Designated waste collection points will be established on site. Care will be taken to ensure that there will be sufficient collection points with adequate capacity and that these are serviced frequently. During decommissioning and closure, lay down areas for re-usable non-hazardous materials will be established. Will be stored in designated skips and removed by an approved contractor for disposal at a licenced facility. Care will be taken to ensure that scrap metal and building rubble does not become polluted or mixed with any other waste. The scrap metal will be collected in a designated area for scrap metal. It will be sold to scrap dealers. Building rubble will either be disposed off-site or buried in the pit at closure. Medical waste, laboratory chemicals and related packaging, used chemicals and chemical containers will be temporarily stored in sealed containers in a bunded store before removal by an approved waste contractor and disposal in a licenced facility.

143 Page 27-9 Items to be considered General Specific Old explosives waste Used and/or spilled oil and grease Disposal Any soil polluted by a spill Mixing of wastes Particles and salts from the sinter scrubbers and reverse osmosis plant Offsite waste disposal facilities Intentions It is stored in an old explosives storage box prior to being destroyed at the on-site destruction bay In designated areas used and/or spilt oil and grease will be collected in suitable containers at identified collection points. The identified collection points will be bunded and underlain by impervious materials to ensure that any spills are contained. In general areas used and/or spilt oil and grease will be collected in suitable containers and deposited in a designated storage area. Notices will be erected at each waste oil point giving instructions on the procedure for waste oil discharge and collection. An approved subcontractor will remove oil from site. If soil (whether stockpiled or in its undisturbed natural state) is polluted, the first management priority is to treat the pollution by means of in situ bio-remediation at the designated site. In situ remediation is generally considered to be the preferred option because with successful in situ remediation the soil resource will be retained in the correct place. The in situ options include bioremediation at the point of pollution, or removal of soils for washing and/or bio remediation at a designated area after which the soils are returned. If remediation of the soil in situ is not possible, the soils will be classified as a waste in terms of the Waste Regulations and will be disposed of at an appropriate permitted waste facility. Waste will not be mixed or treated where this would reduce the potential for re-use, recycling or recovery; or result in treatment that is not controlled and not permanent. This material will either be recycled into the process through the thickeners or there is the option of storage in sealed drums and removal to an appropriately licenced waste site. Waste will be disposed of at appropriate permitted waste disposal facilities. For general waste the closest permitted site is in Kuruman. For hazardous waste, the closest permitted site is at Holfontein. Unless collected by the municipality, the mine must ensure that the waste is assessed in accordance with the Norms and Standards for Assessment of Waste for Landfill Disposal set in terms of section 7(1) of the NEM:WA prior to the disposal of the waste to landfill. Unless collected by the municipality, the mine must ensure that the disposal of their waste to landfill is done in accordance with the Norms and Standards for Disposal of Waste to Landfill set in terms of section 7(1) of the NEM:WA. Waste transport Contractor A qualified waste management subcontractor will undertake the waste transport. The contractor will provide an inventory of each load collected and of proof of disposal at a licenced facility. Banned practices Long-term stockpiling of waste Burying of waste Stockpiling of waste is a temporary measure. Waste stockpiling sites must have an impervious floor, be bunded and have a drainage system for collection and containment of water on the site. No wastes will be placed on site. TABLE 41: SOIL MANAGEMENT PRINCIPLES STEPS FACTORS TO CONSIDER Delineation of areas to be stripped DETAIL Stripping will only occur where soils are to be disturbed by activities that are described in the EMPr report, and where a clearly defined end rehabilitation use for the stripped soil has been identified. Soil stripping should be conducted a suitable period ahead of mining.

144 Page STEPS FACTORS TO CONSIDER Reference to biodiversity action plan DETAIL All requirements for moving and preserving fauna and flora according to the biodiversity action plan will be adhered to. Stripping Topsoil As a general rule 50cm of topsoil must be stripped unless a soils expert advises otherwise. Subsoil Given the nature of the soils, no distinction needs to be made between subsoil and the topsoil. Delineation of Location Stockpiling areas will be identified in close proximity to the source of the soil to limit stockpiling areas handling and to promote reuse of soils in the correct areas. Designation of the areas Soil stockpiles will be clearly marked to identify both the soil type and the intended area of rehabilitation. All topsoil will be stockpiled in areas clearly demarcated on the infrastructure layout and should be defined as no-go areas. Topsoil stockpiles must be located outside of areas susceptible to erosion. Stockpile management Management of disturbed land Rehabilitation of disturbed land: restoration of land capability Vegetation establishment and erosion control Storm water controls Height and slope Waste Vehicles Erosion control Placement of soil Fertilisation Erosion control Restore land function and capability Rapid growth of vegetation on the topsoil stockpiles will be promoted (e.g. by means of watering or fertilisation). The purpose of this exercise will be to encourage vegetation growth on soil stockpiles and to combat erosion by water and wind. Stockpiles will be established with storm water diversion berms to prevent run off erosion. Soil stockpiles height will be restricted to avoid compaction and damage to the underlying soils. In this regard, topsoil stockpiles should be limited to a maximum height of 5m. The stockpile side slopes should be flat enough to promote vegetation growth and reduce run-off related erosion. In addition to this, the topsoil stockpiles need to be established on a gradual slope if possible. No waste material will be placed on the soil stockpiles. Equipment movement on top of the soil stockpiles will be limited to avoid topsoil compaction and subsequent damage to the soils and seedbank. To prevent the erosion of topsoil, management actions may include one or more of the following; berms, soil traps, hessians and stormwater diversions away from areas susceptible to erosion. Once the site has been cleared on infrastructure, the area to be rehabilitated should be ripped in order to reduce soil compaction. As a general rule, a minimum layer of 50cm of topsoil will be replaced unless a soils expert advises otherwise. A few samples of stripped soils will be analysed to determine the nutrient status of the soil before rehabilitation commences. As a minimum, the following elements will be tested for cation exchange capacity, ph, and phosphate. These elements provide the basis for determining the fertility of soil. Based on the analysis, fertilisers will be applied if necessary. Erosion control measures will be implemented to ensure that the topsoil is not washed away and that erosion gulley s do not develop prior to vegetation establishment. Apply landscape function analysis and restoration interventions to areas where soil has been replaced as part of rehabilitation, but the land function and capability has not been effectively restored.

145 Page FINANCIAL PROVISION 28.1 DETERMINATION OF THE AMOUNT OF THE FINANCIAL PROVISION DESCRIPTION OF THE CLOSURE OBJECTIVES AND THE ALIGNMENT WITH THE BASELINE ENVIRONMENT The closure objectives for the project adopted from Tshipi Borwa Mine s closure objective, including how the objective will align with the baseline environment includes the following: Environmental damage caused predominantly at the pre-production stage is restored; Decommissioning of plant and infrastructure; and Maintenance and aftercare of all the rehabilitated sites CONFIRMATION THAT THE CLOSURE OBJECTIVES HAVE BEEN CONSULTED WITH LANDOWNERS AND I&APS The closure objectives are outlined in the environmental assessment report which was has been made available to I&APs, including landowners for review and comment (Section 6.2.6). To date no comments regarding the closure objectives associated with the project have been received from I&APs including landowners REHABILITATION PLAN The project components will be included in the mine s overall rehabilitation plan. As outlined in the mine s annual re-assessment completed in December 2016, the latest mine plan has been finalised, an annual rehabilitation plan for the forthcoming 12 months will be prepared in accordance with the Financial Provisioning Regulations, 2015 (GNR 1147). According to the Financial Provisioning Regulations, 2015 (GNR 1147), the objective of the annual rehabilitation plan is to: Review concurrent rehabilitation and remediation activities already implemented; Establish rehabilitation and remediation goals and outcomes for the forthcoming 12 months, which contribute to the gradual achievement of the post-mining land use, closure vision and objectives identified in the holder's final rehabilitation, decommissioning and mine closure plan; Establish a plan, schedule and budget for rehabilitation for the forthcoming 12 months; Identify and address shortcomings experienced in the preceding 12 months of rehabilitation; Evaluate and update the cost of rehabilitation for the 12 month period and for closure, for purposes of supplementing the financial provision guarantee or other financial provision instrument.

146 Page COMPATIBILITY OF THE REHABILITATION PLAN WITH THE CLOSURE OBJECTIVES It can be confirmed that the rehabilitation plan is compatible with the closure objectives given that the closure objectives were taken into account during the determination of the financial provision CALCULATE AND STATE THE QUANTUM OF THE FINANCIAL PROVISION The financial provision for the project has been incorporated into the financial provision calculations for the overall Tshipi Borwa Mine. In this regard the DMR Guideline Document for the evaluation of the Quantum of Closure-Related Financial Provision require the closure cost estimate to have an accuracy of between +25% and -15% based on the overall generic approach. The calculated quantum of financial provision as at the end of December 2016 is R92,210,210 for the Tshipi Borwa Mine, of which R1,071,351 is attributed to the diesel farm and R2,324,622 is attributed to the haul road, excluding VAT CONFIRMATION THAT THE FINANCIAL PROVISION WILL BE PROVIDED In terms of Section 41, Regulations 53 and 54 of the MPRDA, the project as part of the overall Tshipi Borwa Mine is required to make financial provision for the interim and final rehabilitation activities on the site. This provision is reviewed annually for adequacy and amended to compensate for new activities and/or inflation. During the annual review, confirmation will be provided that this amount can be provided for from operating expenditure.

147 Page MECHANISMS FOR MONITORING COMPLIANCE AND PERFORMANCE AGAINST THE EMPR Environmental impacts requiring monitoring are listed in Table 42 below. TABLE 42: MONITORING OF COMPLIANCE AND PERFORMANCE IN TERMS OF EMPR ACTIVITY Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare IMPACTS REQUIRING MONITORING Physical destruction and general disturbance of biodiversity FUNCTIONAL REQUIREMENTS FOR MONITORING Tshipi will implement an alien/invasive/weed management programme to control the spread of these plants onto and from disturbed areas. This will be achieved by active eradication and the establishment of natural species and through on-going monitoring and assessment. The use of herbicides will be limited and focussed and will only be used under strict controls. Herbicides will be selected to ensure least residual harm. Herbicides will be administered by suitably qualified people. Continued monitoring will be undertaken to ensure that the alien invasive species have been eradicated and are controlled for both controlled sites as well as rehabilitated areas. ROLES AND RESPONSIBILITIES Environmental Department MONITORING AND REPORTING FREQUENCY AND TIME PERIOD FOR MANAGEMENT ACTIONS The alien/invasive/weed management programme should be undertaken on an annual basis for the duration of the mine. This information should be made available to DAFF on request, unless otherwise specified. For each area requiring rehabilitation specific landscape functionality objectives will be set with specialist input and the associated targets and monitoring program will follow accordingly. A comprehensive monitoring programme of the protected trees within the area must be undertaken. This monitoring should be conducted on an individual tree basis as well as monitoring on a community level. After closure, repeat surveys should be carried out annually for at least the first three years postrehabilitation. Monitoring of protected trees should take place on an annual basis. The result must be submitted to DAFF on an annual basis.

148 Page 29-2 ACTIVITY Site preparation Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare IMPACTS REQUIRING MONITORING Contamination of surface water and groundwater resources FUNCTIONAL REQUIREMENTS FOR MONITORING As part of the project, the surface water and groundwater monitoring programme as per the approved EIA and EMPr will be implemented. Monitoring of surface water quality must be undertaken in the event that surface water flow is present in the Vlermuisleegte River. In this regard, samples should be taken from both upstream and downstream of the Vlermuisleegte River. The location of the groundwater monitoring boreholes are illustrated in Figure 11. Water samples must be collected according to the South African best practice guideline (boreholes purging, preservation) for each monitoring event and the samples must be analysed by an accredited laboratory in South Africa. Water quality analyses results should be classified in terms of the SANS 241 (2015) Water Quality Standards and the DWAF Target Quality Range for Livestock Watering (1996), or whichever is applicable at the time. The monitoring results should be assessed by a suitably-qualified professional registered with the South African Council for Natural Scientific Professional (SACNASP). The parameters that need to be analysed are summarised below. ph Electrical conductivity Total dissolved solids Total alkalinity as CaCO3 Carbonate as CO3 Bicarbonate as HCO3 Boron as B Nitrate as N Chloride as Cl Sulphate as SO4 Fluoride as F Calcium as Ca Magnesium as Mg Sodium as Na Potassium as K Manganese as Mn Full metal scan - Inter Coupled Plasma Scan (ICP) (via Mass Spectrometry (MS) ) ROLES AND RESPONSIBILITIES Environmental Department MONITORING AND REPORTING FREQUENCY AND TIME PERIOD FOR MANAGEMENT ACTIONS Surface water monitoring will be undertaken when the Vlermuisleegte River is in flow. Groundwater quality monitoring needs to be undertaken on a quarterly basis as stipulated in the IWUL for the duration of the mine. Monitoring reports need to be submitted to the DWS as per the conditions of the IWUL, on an annual basis. Monitoring reports need to cater for any reporting requirements stipulated in the IWUL. In the event that the integrated water use license (IWUL) for the Tshipi

149 Page 29-3 ACTIVITY Site preparation Use of haul road Diesel storage and handling General site management Demolition Rehabilitation Maintenance and aftercare IMPACTS REQUIRING MONITORING Air pollution FUNCTIONAL REQUIREMENTS FOR MONITORING Borwa Mine is amended and changes to the surface water monitoring programme as outlined in this report are made, the requirements as per the IWUL should be adhered to. As per the approved EIA and EMPr for the Tshipi Mine a monitoring network will be implemented on-site to monitor dust fallout, PM10 (including analysis for manganese concentrations over a two year period during operations), NO2 and SO2 concentrations. This monitoring network will include five dust fallout monitoring points, a PM10 ambient concentration monitoring station, three passive samplers and a meteorological station. The location of the dust fallout buckets is illustrated in Figure 11. ROLES AND RESPONSIBILITIES Environmental Department MONITORING AND REPORTING FREQUENCY AND TIME PERIOD FOR MANAGEMENT ACTIONS Monitoring reports need to be uploaded onto the National Emissions Inventory System on an annual basis. Dust fallout monitoring must be undertaken on a monthly basis. Monitoring will be undertaken for the duration of the mine. A qualified specialist needs to advise on the frequency on monitoring for the PM10 ambient monitoring station, passive samplers and the meteorological station

150 Page FREQUENCY OF PERFORMANCE ASSESSMENT REPORT Tshipi must for the period during which the environmental authorisation and the EMPr report are valid, submit environmental audit reports to the DMR every two years. These audits will focus on the mines compliance with the conditions of the environmental authorisation and the commitments in the EMPr report. These audits must be undertaken by a qualified independent person and must be compiled in accordance with the relevant NEMA EIA Regulations, 2014 (GNR982 of 2014).

151 To Hotazel/ Kuruman ± D3340 Powerline United Manganese of The Kalahari Mine Sedibeng Bulk Water Supply Point Farm Worker Residence Old Middelplaats Mine!( SO and NO R380!( NT8 PM10!( TSH02!(!( TSH06/NEX108 SO and NO TSH04 TSH03!(!(!(!( N-DW-01!( E-DW-03 Mamatwan Mine Hotazel - Ferrum 132Kv Powerline A Pyper W-DW-04!(!( TSH01!( C-DW Access to Mamatwan Train Station Dries Van Den Berg NT1!(!( S-DW-02!( SO and NO Old Railway Houses Tshipi Borwa Mine. D3457 NT15!( To Kuruman Nic Fourie Sedibeng Bulk Water Supply Point Entrance to Tshipi Borwa Mine Access to Mamatwan Mine Hotazel - Sishen Railway Line To Kathu Legend Tshipi Borwa Mine Surface Use Area Tshipi Borwa Mine Approved Mining Right Area Farm Boundaries!( Groundwater Monitoring Points!( Air Quality Sampling Points TSHIPI E' NTLE MANGANESE MINING Figure 11 Monitoring Programme Meters Scale: 1:60 A3 Projection: Transverse Mercator Datum: WGS1984, Lo23 SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) Fax: +27 (11) May 2017