GLENCORE OPERATIONS SOUTH AFRICA (PTY) LTD: RIETVLY MINE. GN 704 Audit Report. Project No: GLE-RIE

Transcription

1 GLENCORE OPERATIONS SOUTH AFRICA (PTY) LTD: RIETVLY MINE GN 704 Audit Report Project No: GLE-RIE April 2016

2 GLENCORE OPERATIONS SOUTH AFRICA (PTY) LTD: RIETVLY MINE GN 704 Audit Report Project No: GLE-RIE April 2016 Unit C8 Nature 472 Botterklapper Street Pretoria Office: + 27 (0) Fax: +27 (0)

3 PROJECT DETAILS Project Title: Glencore Operations South Africa (Pty) Ltd: Rietvly Mine Project Number: GLE-RIE Compiled by: Dawie Maree Date: April 2016 Technical Reviewer: Brian Hayes RB Hayes (Pr.Eng.) Person received Document version Date Annah Ngope Rietvly GN704 Draft Lynette Tungwane Annah Ngope Lynette Tungwane Rietvly GN704 Final

4 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 4 of 32 EXECUTIVE SUMMARY Glencore Operations South Africa (Pty) Ltd: Rietvly Mine commissioned Shangoni Management Services to carry out an audit at the mine, specifically on the requirements of Regulation GN704 of 4 June 1999, National Water Act, 1998 (Act 36 of 1998). The audit was performed on the 8th of March 2016, with the purpose to assess the status of compliance against the requirements of the relevant schedules of GN 704. The main concerns against each of the GN704 Schedules are summarised under the requirement of the Regulation: The following lists the main concerns identified against the relevant Schedules: Schedule 4: Restrictions on locality Of concern is the current location of the product stockpiles that are located within a horizontal distance of 100 metres of the Penzhorn dam (clean surface water dam) and the Legadigadi natural drainage line. Concerns with respect to siltation of the dam and the Legadigadi stream were noted during the audit. No 1:100-year flood lines were available during the audit to confirm the status of compliance. Schedule 6: Capacity requirements of clean and dirty water systems Of concern is the possibility that clean surface water runoff, generated from the access road during rainfall events, may enter the tailings storage facility (dirty water containment). Silt traps is constructed below the washing plant and contain silt laden runoff generated from the area. Of concern is the capacity of the silt traps, which result in overflow during heavy rainfall events. Overflow may enter the Penzhorn dam located downstream. The silt traps are fitted with pumping infrastructure for re-use of process water and level control. Schedule 7: Protection of water resources Currently there are no measures implemented to contain silt carried by runoff generated upslope of the trench into the Legadigadi stream. Evidence of erosion were noted within the trench which results in the generation of silt laden runoff during rainfall events. Silt is then carried by runoff towards the adjacent natural clean water drainage line.

5 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 5 of 32 TABLE OF CONTENTS EXECUTIVE SUMMARY... 4 TABLE OF CONTENTS... 5 REFERENCES INTRODUCTION AND BACKGROUND DESCRIPTION Introduction Background Description of the Mine Study Area AUDIT PROCESS Audit Approach Audit Documentation SITE AUDIT... 14

6 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 6 of 32 REFERENCES CHEMC Environmental Glencore Alloys Environmental Management Programme Report Update Environmental Management Programme Report for the Glencore Rietvly Silica Mine. Department of Water Affairs and Forestry, 1996: South African Water Quality Guidelines. 2nd Edition. Volume 1: Domestic Use. Department of Water Affairs and Forestry, 2000: Guideline for the implementation of Regulations on use of water for mining and related activities aimed at the protection of water resources: Operational Guideline No. M6.1. 2nd edition. Department of Water Affairs and Forestry, 2000: Water Use Authorisation Process (Individual Applications). Edition 1: Final draft for implementation and use, Revision 3. Department of Water Affairs and Forestry, 2004: Best Practice Guideline No Water Re-use and Reclamation. Department of Water Affairs and Forestry, 2004: Best Practice Guideline No Storm Water Management. Draft Copy 8. Department of Water Affairs and Forestry, 2004: Best Practice Guideline No Integrated Mine Water and Waste Management. Final Draft. General Authorisations GN 399, Revision of General Authorisations in terms of Section 39 Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002). Mineral and Petroleum Resources Development Regulations. Government Notice R.527. Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002). Minerals Act, 1991 (Act 50 of 1991). National Water Act, 1998 (Act 36 of 1998). Regulation GN 704, 4 June 1999: Regulations on use of water for mining and related activities aimed at the protection of water resources, dated June 1999, under the National Water Act, 1998, (Act 36 of 1998).

7 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 7 of 32 ABBREVIATIONS DWS Department of Water Affairs and Sanitation EAP Environmental Assessment Practitioner ECA Environmental Conservation Act of 1989 EMP Environmental Management Programme FRD Fine Residue Deposit GN Government Notice NEMA National Environmental Management Act, Act 107 of 1998 as amended NWA National Water Act, Act 36 of 1998 TSF Tailings Storage Facility R Regulation

8 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 8 of INTRODUCTION AND BACKGROUND DESCRIPTION 1.1 Introduction The Glencore Operations: Rietvly Silica Mine use an opencast mining method (bench mining) to mine different fractions of 98% pure silica. The pit is being developed into a prominent quartzite ridge striking almost north-south. The ore is hauled down to the treatment plant where the ore is crushed into various size fractions. The main aim of the operation is to produce silica ore for the ferrochrome furnaces of Glencore, situated in the Rustenburg area (EMPR, 2009). The mineral processing plant at Rietvly Silica Mine is used to process ore from the open pit. The plant comprises of a series of crushers and screens, as well as a wash plant. The mineral processing plant is designed to treat approximately tons per month (EMPR, 2009). 1.2 Background Description of the Mine The mine area itself is at the foot slopes of the Magaliesberg and adjacent to the Magaliesberg Natural Protected Environment. The mine is flanked on three sides (west, north and east) by peaks of the Magaliesberg. Mine surface infrastructure is located at an altitude of between 1 280m and 1 240m amsl. There are two peaks/koppies on the mine property itself. These koppies lie at an altitude of 1 435m and 1 366m above mean sea level (amsl). The lower western parts, the top and eastern slopes of these koppies are currently being bench mined by the mine. The non perennial Legadigadi stream passes the mine (at an altitude of approximately 1 260m amsl) on the western side and flows north east towards the Elands River (EMPR, 2009). Mined ore (run-of-mine) is discharged via truck into a run-of-mine receiving bin. From the bin, ore is fed through a series of crushers and screens until the correct grade (size) silica is obtained. A return circuit exists for oversized material. The weightometer, located on the main plant feed conveyor, is used to calculate the tons of feed material. Fines from the crushing and screening circuit are either conveyed to a stockpile or fed directly into the washing plant. Quartz product is conveyed to separate stockpiles depending on the grade/size (i.e. a large lump stockpile - 90x50mm product and a small lump stockpile - 50x20mm product). From the stockpiles, the quartz is loaded onto trucks and transported to Glencore s furnace operations in Rustenburg, Boshoek and Wonderkop for use as a flux in the chrome smelting operation or sold to platinum mines. Chips (<20mm) from the circuit are treated as waste and is stockpiled separately. From the stockpile, the chips will be used for backfilling. Process water is used for dust suppression.

9 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 9 of 32 Fines from the crushing and screening circuit are fed via conveyor to the washing plant. The washing plant washes the fines to produce a sand material. The material is screened and various grades of silica are conveyed to separate stockpiles a small chips stockpile (<2mm product) and a large chips stockpile (20x10mm product). Fines from the screening process are washed with process water to remove the ultrafines. The material is then dewatered fines are sent to a fines stockpile while the slurry is sent to a thickener. Any spillages from the stockpile areas are recycled back to the thickener. Slimes from the thickener is deposited on a slimes dam. From the stockpiles, the quartz is loaded onto trucks and transported to smelters in Rustenburg. Water used in the process is recycled. Due to the nature of the geology and the minimal surface soil cover, no overburden will be generated. In addition, no waste rock will be generated. All material mined will be processed through the mineral processing plant. Slimes from the processing operation will be deposited on a slimes dam. 1.3 Study Area Rietvly silica mine has the following surface infrastructure: Transport, power and water supply networks; Open pit; An explosives magazine; Mineral processing plant (crushing and screening circuit and a washing plant); Stockpile areas for product; Slimes dams; Water management infrastructure including storm water management infrastructure and Pentzhorn Dam; Ericson s Dams Buildings including offices, an ablution block, a workshop, brake test shop, a store and an onsite industrial waste site (including a salvage yard); and A diesel storage area (adjacent to the workshop). Land immediately surrounding the site is either being mined or used by Rietvly Silica Mine, or is being used by private individuals for residential, agricultural or tourism use. Further away from the mine, land is occupied by the Magaliesberg or sections of Phokeng community. There are several private individuals (landowners/farmers) located on properties to the west, north and east of the mine. Some of the properties are used for residential purposes, grazing livestock and small scale farming. To the south of Rietvly Silica Mine, lies the Magaliesberg Natural Protected Environment, approximately 1km south of the mining areas. The Magaliesberg mountain range was declared a Natural Heritage Site in The Magaliesberg stretches 125km from east to west and spans an elevation of m amsl. It forms a divide between the lower lying, hot bushveld to the north and the cooler highveld

10 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 10 of 32 to the south. Flora and fauna distinct to both regions merge along the range and therefore the Magaliesberg harbours a diversity of indigenous species. To the North West and west, lie the foothills of the Magaliesberg comprising of eight hills in the vicinity of Rietvly Silica Mine. The foothills range in altitude from 1 300m amsl (at the base) to 1 593m amsl (highest point). The side slopes of two of the hills are currently being mined by the mine. The nearest community to the mine is Phokeng which falls under the jurisdiction of the Royal Bafokeng Nation. The nearest sections/zones of Phokeng to the proposed project lie to the north east of the mine and include: Magokgwane (± 2.5km), Masosobane (± 3.5km), Ga Kgale (± 3.5km), Dithabaneng (± 4km), and Tshufi (± 2km).

11 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 11 of 32 Figure 1: Rietvly Silica Mine - Layout

12 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 12 of AUDIT PROCESS 2.1 Audit Approach Document Review A document review was undertaken to familiarise auditors with the operation, risk areas, to identify all applicable authorisations, monitoring/performance records and operational standards Site Audit The site audit focused predominantly on the water and waste management infrastructure, with specific guidance (but not limited to) as set out in GN704: Schedule 2: Information and Notification Schedule 3: Exemption from requirements of regulations Schedule 4: Restriction on locality of reservoirs, deposits, dams, underground and opencast mining, prospecting and related activities Schedule 5: Restriction on use of material Schedule 6: Capacity requirements of clean and dirty water systems Schedule 7: Protection of water resources Schedule 8: Security and additional measures Schedule 9: Temporary or permanent cessation of mine or activity Schedule 12: Technical investigation and monitoring Schedule 13: General Mine Surface Infrastructure Main area and infrastructure covered during the audit are reflected below. Main Area Bench mining on hill Product stockpile areas Offices and workshops Plant area Tailings Storage Facility Main infrastructure covered during audit Mining area on top of the hill, safety berms and access roads. Product stockpiles and access roads. Fuel storage, workshop, ericson dams, septic tank, contractors workshop / salvage area and oil skimmer. Crushing plant and washing plant Salvage yard, return water dam and failings storage facility

13 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 13 of Audit Documentation Recording of Findings and Observations Concerns raised against each of the schedules of Regulation GN 704 of 4 June 1999 were recorded in event where non-compliances were observed. Observations were also recorded describing effective operation, or actions currently in progress for addressing areas of non-conformance, or situations that may result in a finding if not further investigated. Due to the nature and intent of this audit, emphasis is on the identification of areas of non-compliance, and not to record the areas or activities where effective and good practices were observed Rating of Compliance The level of compliance for each applicable schedule is categorised in accordance with the following: Full Compliance No evidence of non-compliance was observed Partial Compliance Evidence of non-compliance was observed. Strategies have been developed with evidence of implementation to address concern. Non-Compliance Non-compliance within a specific area/activity/operation was observed, with no planned measures to address.

14 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 14 of SITE AUDIT The following contains a detail description of the areas of non-compliance against the various Schedules of Regulation GN 704 of 4 June Where photographic evidence is attached, location reference is provided in Figure 4: Photo locations taken during GN704 audit. DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES 2. Information and notification (1) Any person intending to operate a new Mine or conduct any new activity must notify the Department of such intention not less than 14 days before the start of such operation or activity. (2) Submit a copy of all amendments of their environmental management programme to the Department (3) Notify DWA in writing 14 days prior to temporary or permanent cessation of operation, or resumption of operation (4) Notify DWA by fastest means possible of any emergency incident or potential emergency incident involving a water resource (5) Within 14 days after the date of an incident, inform the Department in writing of measures taken to correct and prevent a recurrence of such incident. Compliance Status Full Compliance Schedule 2(1), 2(2), 2(3) and 2(4). Schedule 2(1): Operate new mine or activity, must notify the Department not less than 14 days before Observation: Information and notification The mine must take note of the requirements for notification to the Department, 14 days prior to the commencement of any new activity. Schedule 2(2): Submit copy of all amendment to environmental management programme to Department Observation: The mine takes note of Schedule 2(2). Schedule 2(3): Notify the Department with 14 days prior to temporary or permanent cessation of operation, or resumption of operation Observation: Cessation of mining activities The mine must take note of the requirements for notification to the Department, 14 days prior to the temporary or permanent cessation of mining activities. Schedule 2(4): Notify DWA by fastest means of any emergency incident or potential emergency incident

15 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 15 of 32 Reference: Schedule 2(4) Observation: Emergency Incidents Incidents that may cause water pollution are recorded as per the Incident Management Procedure in Isometrix and if required reported to the DWS. It was indicated by Glencore Rietvly that no reportable incidents were recorded during the audit period. Corrective Actions: 1. Ensure that incidents are recorded in a manner to assess the extent and significance thereof (such detail in terms of quantities, impact on receiving environment to be document, e.g. within the incident register or investigation report). 2. Ensure that incidents that may lead to an emergency or potential emergency incident are reported to the DWS, as per the Incident Management Procedure, and records of such incident reporting kept. It is further recommended that the mine provides a guide on the scale and significance of incidents that warrant external reporting. DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES 3. Exemption from requirements of regulations The Minister may in writing authorise an exemption from the requirements of regulations 4, 5, 6, 7, 8,10 or 11 on his or her own initiative or on application, subject to such conditions as the Minister may determine. Compliance Schedule 3 Observation: Compliance Status The mine received a draft water use license document from the DWS dated 3 October 2007 which included the preliminary exemptions from Regulation GN. 704 for the Rietvly mine. The exemptions are not granted as the water use license application has not yet been approved. The following preliminary exemptions are listed in the draft document applicable to Rietvly mine: Regulation Property description GPS co-ordinate Description 4(a) Rietvly 271 JQ, Ptn 98 E: S: Earth Dam built in water course 6(d) Rietvly 271 JQ, Ptn 145 E: S: (d) Rietvly 271 JQ, Ptn 90 E: S: None of the dirty water containment systems are designed to contain the 1:50 year flood.

16 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 16 of 32 6(d) Rietvly 271 JQ, Ptn 98 E: S: (f) Rietvly 271 JQ, Ptn 98 E: Applicable discharge permits are included in this application Main catchment dam S: (f) Rietvly 271 JQ, Ptn 98 E: Rietvly earth dam S: (f) Rietvly 271 JQ, Ptn 98 E: Rietvly storage dam 1 S: (f) Rietvly 271 JQ, Ptn 98 E: Rietvly storage dam 2 S: (f) Rietvly 271 JQ, Ptn 98 E: Rietvly storage dam 3 S: (f) Rietvly 271 JQ, Ptn 98 E: Rietvly Tailings Dam S: Corrective Actions: 1. Follow-up with the DWS with respect to progress on issuing of the water use license. Ensure that records of all such correspondences are kept. 2. Undertake a comprehensive review of all existing water use activities, and ensure that all such activities are covered within the current water use licence applications. Furthermore, for those activities requiring exemption to the requirements of GN704, ensure that all such activities are still relevant and include such applications within either the existing water use license application or within a separate application. DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES 4. Restrictions on locality. No person in control of a Mine or activity may - (a) Locate or place any residue deposit, dam, reservoir, together with any associated structure or any other facility within the 1:100 year flood-line or within a horizontal distance of 100 metres from any watercourse or estuary, borehole or well, excluding boreholes or wells drilled specifically to monitor the pollution of groundwater, or on water-logged ground, or on ground likely to become water- logged, undermined, unstable or cracked; (b) Except in relation to a matter contemplated in regulation 10, carry on any underground or opencast mining, prospecting or any other operation or activity under or within the 1:50 year flood-line or within a horizontal distance of 100 metres from any watercourse or estuary, whichever is the greatest;

17 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 17 of 32 (c) Place or dispose of any residue or substance which causes or is likely to cause pollution of a water resource, in the workings of any underground or opencast mine excavation, prospecting diggings, pit or any other excavation; or (d) Use any area or locate any sanitary convenience, fuel depots, reservoir or depots for any substance which causes or is likely to cause pollution within the 1:50 year flood line of any watercourse or estuary. Compliance Status Full Compliance Non-Compliance Schedule 4(c) & (d). Schedule 4(a) & (b) Schedule 4(a): Locate residue deposit, dam, reservoir outside the 1:100 year flood-line Location: Product stockpiles surrounding washing plant Finding: Of concern is the current location of the product stockpiles that are located within a horizontal distance of 100 metres of the Penzhorn dam (clean surface water dam) and the Legadigadi natural drainage line. Concerns with respect to siltation of the dam and the Legadigadi stream were noted during the audit. No 1:100-year flood lines were available during the audit to confirm compliance. Stockpiles near the washing plant located in close proximity of the Penzhorn dam and the Legadigadi stream. Photo Reference: 03/08 10:32

18 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 18 of 32 Penzhorn dam Legadigadi stream Aerial view of product stockpiles within a distance of 100 m of the Penzhorn dam and the Legadigadi stream. Product stockpiles at washing plant Schedule 4(b): Carry on any opencast mining within the 1:50 year flood-line or within 100m from a watercourse Location: Product stockpiles surrounding washing plant Finding: Please refer to the discussion under Schedule 4(a) above. As mentioned previously, no flood line maps were available at the time of the audit. Schedule 4(c): Place or dispose of any residue or substance which causes or is likely to cause pollution Observation: No concerns were identified during the audit. Schedule 4(d): Use any area or locate any sanitary convenience, fuel depots, reservoir or depots for any substance which causes or is likely to cause pollution outside the 1:50 year flood line of any watercourse or estuary Observation: No concerns were identified during the audit. Corrective Actions: 1. The mine should develop flood line maps (1:50 & 1:100 year) for the Legadigadi stream to support compliance with the locality requirements. 2. As previously discussed, exemption to the location of product stockpiles in close proximity of a water resource (Penzhorn dam and Legadigadi stream), need to be applied for. Such exemption can be applied for as a separate application or included within the current water use license application. In support of such exemption application, it is recommended to conduct leachate tests on the product stockpiles to support that this activity is of low risk to the surrounding clean water environment.

19 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 19 of 32 DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES 5. Restrictions on use of material No person in control of a mine or activity may use any residue or substance which causes or is likely to cause pollution of a water resource for the construction of any dam or other impoundment or any embankment, road or railway, or for any other purpose which is likely to cause pollution of a water resource. Compliance Schedule 5 Location: Rietvly Silica Mine vicinity Compliance Status Observation: During the site audit, no material that is likely to cause pollution was used for road construction, construction of dams or other impoundments.

20 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 20 of 32 DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES 6. Capacity requirements of clean and dirty water systems. Every person in control of a Mine or activity must - (a) confine any unpolluted water to a clean water system, away from any dirty area; (b) design, construct, maintain and operate any clean water system at the mine or activity so that it is not likely to spill into any dirty water system more than once in 50 years; (c) collect the water arising within any dirty area, including water seeping from mining operations, outcrops or any other activity, into a dirty water system; (d) design, construct, maintain and operate any dirty water system at the mine or activity so that it is not likely to spill into any clean water system more than once in 50 years; and (e) Design, construct, maintain and operate any dam or tailings dam that forms part of a dirty water system to have a minimum freeboard of 0.8 metres above full supply level, unless otherwise specified in terms of Chapter 12 of the Act. (f) Design, construct and maintain all water systems in such a manner as to guarantee the serviceability of such conveyances for flows up to and including those arising as a result of the maximum flood with an average period of recurrence of once in 50 years. Compliance Status Full Compliance Partial Compliance Non-Compliance Schedule 6(b), (c), (e) & (f) Schedule 6(d) Schedule 6(a), Schedule 6(a): Confine any unpolluted water to clean water system Location: Tailings storage facility Finding: Of concern is the possibility that clean surface water runoff, generated from the access road during rainfall events, may enter the tailings storage facility (TSF).

21 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 21 of 32 Entrance of clean runoff into TSF Possibility of clean surface runoff entering the tailings storage facility. Photo Reference: 03/08 11:27 Schedule 6(b): Design and operate clean water system not likely to spill into any dirty water system more than once in 50 years Observation: No concerns were identified during the audit. Clean water is stored within the two Ericson dams located next to the workshop. Ericson Dam 1 receives clean water from Bafokeng and overflows into Ericson Dam 2 which is fitted with a level control system (float-valve). Schedule 6(c): Collect the water arising within any dirty area Location: Trench past washing plant Finding: Currently there are no measures implemented to contain silt carried by runoff generated upslope of the trench into the Legadigadi stream. Please refer to Schedule 7(e) below. Schedule 6(d): Design, construct, maintain and operate any dirty water system Location: Washing Plant Observation: Silt traps is constructed below the washing plant and contain silt laden runoff generated from the area. Of concern is the capacity of the silt traps which results in overflow during heavy rainfall events where overflow may enter the Penzhorn dam. The silt traps are fitted with pumping infrastructure for re-use of process water and level control.

22 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 22 of 32 Silt traps below washing plant that experience overflow during heavy rainfall events. Silt traps below washing plant Photo Reference: 03/08 10:22 Schedule 6(e): Design, construct, maintain and operate dam to have a minimum freeboard of 0.8 metres Location: Main process water dam Observation: Site observations did not reveal any concerns with respect to management of the dam, with current water levels being managed by level control below a 0.8 m freeboard. Any possible overflow from the washing plant and the main process water dam is contained within the silt traps located approximately 20 m downstream and re-used within the process. The water observed around the main process water dam is as a result of sand washing activities at the washing plant. The water is conveyed towards the silt trap facilities. Main process water dam Current levels are below 0.8 m freeboard. Photo Reference: 03/08-10:51

23 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 23 of 32 Water generated from sand washing activities conveyed past the main process water dam towards silt traps. Photo reference: 03/08 10:39 Trench towards silt traps Conveyance of water past the main process water dam. Photo reference: 03/08 10:40 Location: Tailings storage facility Observation: No concerns were noted during the audit. Mine personnel confirmed that most of the water evaporates in the tailings storage facility. Excess water (when available) is pumped to the return water dam for re-use in the process. Any overflow will be intercepted by a channel and conveyed towards the return water dam. Tailings storage facility Tailings storage facility Photo Reference: 03/08 11:26

24 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 24 of 32 Return water dam Return water dam situated downstream of the tailings storage facility. Photo Reference: 03/08 11:30 Schedule 6(f): Design, construct and maintain all water systems to guarantee the serviceability Observation: No concerns in terms of the serviceability of water conveyance systems were identified during the audit. Corrective Actions: 1. Clean storm water runoff generated upslope of the tailings storage facility (TSF) is to be diverted around the TSF where the natural slope leads towards the Penzhorn dam and the Legadigadi stream. 2. Develop planned maintenance programmes for all affected water canals and clean storm water channels and implement. Typically, such programme should include a map of all canals, indicating frequency of maintenance for each identified canal. Regular inspections should furthermore be undertaken to verify effectiveness of maintenance and to identify any malfunctions or incidents (e.g. canal collapse and the control of increased sediment loads towards natural drainage lines). 3. Redefine the clean storm water trench conveying runoff past the washing plant towards the Legadigadi stream. It is recommended to fit the trench with adequate silt traps and erosion prevention measures due to the slope of the trench. 4. Undertake regular inspections on all affected water storage dams to record levels and ensure that dams are operated below the 0.8 m freeboard. 5. Ensure the serviceability of the pumps at the silt traps to prevent any spillages during rainfall events. Investigations should be conducted to determine the feasibility of increasing the capacity of the silt traps to contain excess runoff during flood events. DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES 7. Protection of water resources. Every person in control of a Mine or activity must take reasonable measures to -

25 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 25 of 32 (a) Prevent water containing waste or any substance which causes or is likely to cause pollution of a water resource from entering any water resource, either by natural flow or by seepage, and must retain or collect such substance or water containing waste for use, re-use, evaporation or for purification and disposal in terms of the Act; (b) design, modify, locate, construct and maintain all water systems, including residue deposits, in any area so as to prevent the pollution of any water resource through the operation or use thereof and to restrict the possibility of damage to the riparian or in-stream habitat through erosion or sedimentation, or the disturbance of vegetation, or the alteration of flow characteristics; (c) cause effective measures to be taken to minimise the flow of any surface water or floodwater into mine workings, opencast workings, other workings or subterranean caverns, through cracked or fissured formations, subsided ground, sinkholes, outcrop excavations, audits, entrances or any other openings; (d) design, modify, construct, maintain and use any dam or any residue deposit or stockpile used for the disposal or storage of mineral tailings, slimes, ash or other hydraulic transported substances, so that the water or waste therein, or falling therein, will not result in the failure thereof or impair the stability thereof; (e) prevent the erosion or leaching of materials from any residue deposit or stockpile from any area and contain material or substances so eroded or leached in such area by providing suitable barrier dams, evaporation dams or any other effective measures to prevent this material or substance from entering and polluting any water resources; (f) ensure that water used in any process at a mine or activity is recycled as far as practicable, and any facility, sump, pumping installation, catchment dam or other impoundment used for recycling water, is of adequate design and capacity to prevent the spillage, seepage or release of water containing waste at any time; (g) at all times keep any water system free from any matter or obstruction which may affect the efficiency thereof; and (h) Cause all domestic waste, including wash water, which cannot be disposed of in a municipal sewage system, to be disposed of in terms of an authorisation under the Act. Compliance Status Full Compliance Partial Compliance Non-Compliance Schedule 7(c), (d), (f), (g) & (h) Schedule 7(a) Schedule 7(b), (e) Schedule 7(a): Prevent any substance which is likely to cause pollution from entering a water resource Location: Washing plant Observation: Concerns with respect to possible overflow of the silt traps into the natural drainage lines during heavy rainfall events were noted. Refer to Schedule 6(d). Schedule 7(b): Design and maintain all water systems to prevent pollution of any water resource

26 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 26 of 32 Location: Washing plant Finding: Concerns with respect to possible discharge of silt laden runoff into the natural drainage line (Legadigadi stream) during heavy rainfall events were noted. Refer to Schedule 7(e) below. Schedule 7(c): Minimise the flow of any surface water or floodwater into a mine workings Observation: No concerns were identified during the audit. Schedule 7(d): Maintain residue deposits so that the water or waste therein, will not result in failure/impair stability Observation: No concerns were identified during the audit. Schedule 7(e): Contain eroded/leached substances from entering and polluting a water resource Location: Trench past washing plant Finding: Currently there are no measures implemented to contain silt carried by runoff generated upslope of the trench into the Legadigadi stream. Evidence of erosion were noted within the trench which results in the generation of silt laden runoff during rainfall events. Silt is then carried by runoff towards the adjacent natural clean water drainage line. Evidence of erosion within the trench located near the washing plant. Photo Reference: 03/08 10:30 Erosion gullies within storm water trench

27 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 27 of 32 Storm water trench flowing towards Legadigadi stream. Penzhorn dam Main process dam Silt traps Washing plant Storm water trench Schedule 7(f): Water used within process at mine is recycled as far as practicable Location: Rietvly mine vicinity Observation: Rietvly mine is recycling water and the effectiveness is managed through a water balance. Mine personnel confirmed that the water balance is updated on an annual basis. Schedule 7(g): Keep any water system free from any matter or obstruction which may affect efficiency Location: Crushing plant, washing plant and product stockpile areas. Observation: No concerns were noted during the audit. Schedule 7(h): Domestic waste, including wash water, to be disposed of in terms of an authorisation Observation: No concerns were noted during the audit. Corrective Actions: 1. As discussed under Schedule 6, it is proposed to redefine the clean storm water trench conveying runoff past the washing plant towards the Legadigadi stream. It is recommended to fit the trench with adequate silt traps and erosion prevention measures (gabions) due to the slope of the trench. 2. As discussed under Schedule 6, investigations should be conducted to determine the feasibility of increasing the capacity of the silt traps to contain excess runoff during flood events. 3. Regular updates to the water balance should be undertaken to assess effectiveness of affected water re-use. Regular maintenance and repair of flow meters, where necessary, need to be investigated and implemented. DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES

28 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 28 of Security and additional measures. Every person in control of a Mine or activity must - (a) cause any impoundment or dam containing any poisonous, toxic or injurious substance to be effectively fenced-off so as to restrict access thereto, and must erect warning notice boards at prominent locations so as to warn persons of the hazardous contents thereof; (b) ensure access control in any area used for the stockpiling or disposal of any residue or substance which causes, has caused or is likely to cause pollution of a water resource so as to protect any measures taken in terms of these regulations; (c) not allow the area contemplated in paragraph (a) and (b) to be used for any other purpose, if such use causes or is likely to cause pollution of a water resource; and (d) Protect any existing pollution control measures or replace any existing pollution control measures deleteriously affected, damaged or destroyed by the removing or reclaiming of materials from any residue deposit or stockpile, and establish additional measures for the prevention of pollution of a water resource which might occur, is occurring or has occurred as a result of such operations. Compliance Status Full Compliance Schedule 8(a), (b), (c) & (d) Schedule 8(a): Impoundment or dam to be effectively fenced-off to restrict access and erect warning notice boards at prominent locations: Location: Tailings storage facility Observation: No concerns were noted during the audit. Access control is implemented and warning notice boards are placed at the facility. Access control implemented at the tailings storage facility. Photo Reference: 03/08 11:16 Schedule 8(b): Access control for the stockpiling or disposal of any residue or substance Location: Rietvly mine vicinity Observation: No concerns were noted during the audit. Access control is implemented at the facility entrance.

29 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 29 of 32 Schedule 8(c): Not allow the area contemplated in paragraph 8(a) and 8(b) to be used for any other purpose, if such use causes or is likely to cause pollution of a water resource Observation: No concerns were identified during the audit. Schedule 8(d): Protect any existing pollution control measures. Observation: No concerns were identified during the audit. Corrective Actions: 1. Although evident that effort and progress has been made to warn public and safeguard areas on site, it is recommended that a risk assessment be undertaken to identify all high risk areas, and to verify if current management measures are adequate.

30 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 30 of 32 DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES 9. Temporary or permanent cessation of mine or activity (1) Any person in control of a mine or activity must at either temporary or permanent cessation of operations ensure that all pollution control measures have been designed, modified constructed and maintained so as to comply with these regulations. (2) Any person in control of a mine or activity must ensure that the in-stream and riparian habitat of any water resource, which may have been affected or altered by a mine or activity, is remedied so as to comply with these regulations (b) On either temporary or permanent cessation of a mine or activity the Minister may request a copy of any surface or underground plans as required in terms of the Minerals Act, Full Compliance Schedule 9 Observation: Compliance Status No temporary or permanent cessation of mining activities has occurred (subsequent to Rietvly Silica Mine operations).

31 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 31 of 32 DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES 12. Technical Investigation and Monitoring (6) Subject to Chapter 4 of the Act, any person in control of a mine or activity must: submit plans, specifications and design reports approved by a professional engineer to the Minister, not later than 60 days prior to commencement of activities relating to- (a) (b) (c) the construction of any surface dam for the purpose of impounding waste, water containing waste or slurry, so as to prevent the pollution of a water resource; the implementation of any pollution control measures at any residue deposit or stockpile, so as to prevent the pollution of a water resource; and the implementation of any water control measures at any residue deposit or stockpile, so as to prevent the pollution of a water resource. Full Compliance Schedule 12 Observation: Compliance Status The mine will need to confirm that all submissions of plans, specifications and design reports are completed and sent to the Department for any new activity, 60 days prior to commencement of such activities. DEPARTMENT OF WATER AFFAIRS AND FORESTRY GOVERNMENT GAZETTE, 4 JUNE 1999 (VOL. 408, NO ) NATIONAL WATER ACT, 1998 (ACT 36 OF 1998) REGULATIONS ON USE OF WATER FOR MINING AND RELATED ACTIVITIES AIMED AT THE PROTECTION OF WATER RESOURCES 13. General The person in control of a mine or activity must provide the manager with the means and afford him or her every facility required to enable the manager to comply with the provisions of these regulations. Full Compliance Schedule 13 Observation: Compliance Status Take note of these requirements, as required for implementation of recommendations stemming from this GN704 Audit Report.

32 Glencore Operations South Africa (Pty) Ltd: Rietvly Silica Mine - GN 704 Audit Page 32 of 32 Figure 2: Photo locations during GN704 audit