FINAL BASIC ASSESSMENT PROCESS FOR COPPER MINE ON FARM

536 SPRINGBOK

FINAL BASIC ASSESSMENT REPORT

DMR REFERENCE NUMBERS:

NCS 30/5/1/3/3/2/1 (10728) MP

PREPARED FOR:

XWENA COPPER PTY LTD

May 2019
 BASIC ASSESSMENT REPORT
AND
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

SUBMITTED FOR ENVIRONMENTAL AUTHORIZATIONS IN TERMS OF THE NATIONAL

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

NAME OF APPLICANT: Xwena Copper Pty Ltd

TEL NO: 074 872 2277

FAX NO: 086 520 3958

POSTAL ADDRESS: Postnet Suite 1027, Private Bag X2, Century City 7441
PHYSICAL ADDRESS: The Business Centre, Nr. 1 Bridgeways Road, Century City 7441

FILE REFERENCE NUMBER SAMRAD: NCS 30/5/1/3/3/2/1 (10728) MP

 Table of Contents
1. IMPORTANT NOTICE ............................................................................................... 5
2. OBJECTIVE OF THE BASIC ASSESSMENT PROCESS ......................................... 6
3. PART A: SCOPE OF ASSSSMENT AND BASIC ASSESSMENTREPORT .............. 7
A. Details of Environmental Assessment Practitioner ........................................................7
(a) Details of the EAP ......................................................................................................7
(b) Expertise of the EAP. ................................................................................................7
B. Location of the overall Activity: ..........................................................................................8
C. Locality map .........................................................................................................................9
D. Description of the scope of the proposed overall activity: ...........................................12
E. Listed and specified activities ..........................................................................................13
F. Description of the activities to be undertaken ...............................................................16
G. Policy and Legislative Context.........................................................................................17
H. Need and desirability of the proposed activities ...........................................................18
I. Motivation for the overall preferred site, activities and technology alternative ........21
J. Full description of the process followed to reach the proposed preferred
alternatives within the site. ...............................................................................................21
K. Details of the development footprint alternatives considered. ....................................21
L. Details of the Public Participation Process Followed ...................................................23
M. Summary of issues raised by I&APs ..............................................................................24
N. The Environmental attributes associated with the alternatives. .................................26
O. Assessment of each identified potentially significant impact and risk .......................41
P. Summary of specialist reports .........................................................................................42
Q. Environmental impact statement .....................................................................................45
R. Proposed impact management objectives and the impact management outcomes
for inclusion in the EMPr; .................................................................................................46
i. Aspects for inclusion as conditions of Authorisation ..........................................46
ii. Description of any assumptions, uncertainties and gaps in knowledge ..........46
iii. Reasoned opinion as to whether the proposed activity should or should not
be authorised ............................................................................................................46
iv. Reasons why the activity should be authorized or not .......................................47
v. Conditions that must be included in the authorisation .......................................47
vi. Period for which the Environmental Authorisation is required ..........................47
vii. Undertaking ...............................................................................................................47
S. Financial Provision ............................................................................................................48
i. Explain how the aforesaid amount was derived. .................................................48
ii. Confirm that this amount can be provided for from operating expenditure. ...48
T. Specific Information required by the competent Authority: .........................................49
3
 i. Impact on the socio-economic conditions of any directly affected person ......49
ii. Impact on any national estate referred to in section 3(2) of the National
Heritage Resources Act. .........................................................................................49
iii. Other matters required in terms of sections 24(4)(a) and (b) of the Act. ........49
4. PART B: ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT ................ 50
U. DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME. ..................................50
i) Details of the EAP, ...................................................................................................50
ii) Description of the Aspects of the Activity .............................................................50
iii) Composite Map ........................................................................................................50
iv) Description of Impact management objectives including management
statements .................................................................................................................51
(a) Determination of closure objectives ......................................................................51
(b) Volumes and rate of water use required for the operation. ...............................52
(c) Has a water use licence has been applied for? ..................................................52
v) Impacts to be mitigated in their respective phases.............................................53
Measures to rehabilitate the environment affected by the undertaking of any
listed activity ..............................................................................................................53
vi) Impact Management Outcomes .............................................................................54
vii) Impact Management Actions ..................................................................................56
V. Financial Provision ............................................................................................................58
W. Mechanisms for monitoring compliance with and performance assessment against
the environmental management programme and reporting thereon, including .......62
i) The frequency of the submission of the performance
assessment/environmental audit report ...............................................................64
X. Environmental Awareness Plan ......................................................................................65
i) Manner in which the applicant intends to inform his or her employees of any
environmental risk which may result from their work .........................................65
ii) Manner in which risks will be dealt with in order to avoid pollution or the
degradation of the environment .............................................................................65
Y. Specific information required by the Competent Authority ..........................................66
5. UNDERTAKING ...................................................................................................... 67

4
 1. IMPORTANT NOTICE

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

Unless an Environmental Authorisation can be granted following the evaluation of

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

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

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

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

It is furthermore an instruction that the Environmental Assessment Practitioner

must process and interpret his/her research and analysis and use the findings
thereof to compile the information required herein. (Unprocessed supporting
information may be attached as appendices). The EAP must ensure that the
information required is placed correctly in the relevant sections of the Report, in the
order, and under the provided headings as set out below, and ensure that the report

5
 is not cluttered with un-interpreted information and that it unambiguously represents
the interpretation of the applicant.

2. OBJECTIVE OF THE BASIC ASSESSMENT PROCESS

The objective of the basic assessment process is to, through a consultative process─
(a) determine the policy and legislative context within which the proposed activity is
located and how the activity complies with and responds to the policy and legislative
context;

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

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

(d) through the undertaking of an impact and risk assessment process inclusive of
cumulative impacts which focused on determining the geographical, physical,
biological, social, economic, heritage, and cultural sensitivity of the sites and locations
within sites and the risk of impact of the proposed activity and technology alternatives
on these aspects to determine:

(i) the nature, significance, consequence, extent, duration, and probability of the
impacts occurring to; and
(ii) the degree to which these impacts—
(aa) can be reversed;
(bb) may cause irreplaceable loss of resources; and
(cc) can be managed, avoided or mitigated;

(e) through a ranking of the site sensitivities and possible impacts the activity and
technology alternatives will impose on the sites and location identified through the life
of the activity to—
(i) identify and motivate a preferred site, activity and technology alternative;
(ii) identify suitable measures to manage, avoid or mitigate identified impacts; and
(iii) identify residual risks that need to be managed and monitored.

6
3. PART A: SCOPE OF ASSSSMENT AND BASIC ASSESSMENTREPORT

CONTACT PERSON AND CORRESPONDENCE ADDRESS:

A. Details of Environmental Assessment Practitioner

(a) Details of the EAP

Name of The Practitioner: Lee-Ann Viona Pretorius
Tel No.: 082 302 0039
Fax No. : 086 672 8399
e-mail address: [email protected]

(b) Expertise of the EAP.

The qualifications of the EAP, including Curriculum Vitae

Baccalaureus Technologiae in Environmental Management
International Association for Impact Assessment (Registration No – 5187)

Summary of the EAP’s past experience.

Lee-Ann Fielies is a qualified Environmental Assessment Practitioner (EAP) who holds
a Baccalaureus Technologiae in Environmental Management which she obtained from
the Cape Peninsula University of Technology in 2013.

She has 6 years’ experience in the Environmental Impact Assessment (EIA) and Basic
Assessment (BA) procedures and processes. She has been the lead Environmental
Practitioner on the Roads Project for the Provincial Transport Department and has
obtained many environmental authorisations in various districts. She has also been
involved in the implementation of numerous environmental management programmes,
environmental impacts for environmental authorisations and mining permits.

She is also actively involved as an Environmental Control Officer (ECO) and assisted
on the Pelican Park Residential Development. She was the project manager on the
Bergrivier Family and Lifestyle Facility in Laaiplek and managed the EIA processes.

She is currently actively involved in the NEMA Mining process for Uitkyk Diggers
Caledon, Heidelberg Quarries, Annev Construction, MOCA Granite and Xwena Copper
conducting their mining, prospecting permit process and ECO duties.
(Refer to Appendix A for CV)

7
B. Location of the overall Activity:

Farm Name: Springbok Farm 536

Application area (Ha) 4.9 Ha
Magisterial district: Springbok
Distance and
direction from The proposed development is located 500 m from
the nearest town which is Springbok.
nearest town
21-digit Surveyor
General Code for C05300110000053600000
each farm portion

8
C. Locality map and Site Plan

9
10
 Mining Blocks
Stable
Face

Already
mined area

11
D. Description of the scope of the proposed overall activity:
The mining permit operation will be run as an open cast mining operation for copper. As the
copper is unconsolidated it will be removed by excavator, loader and jack hammer.

The operation will follow the modus operandi:

The white area (See Annexure C Site Plan) is the already mined area where the Copper
Mineral has been extracted by previous mining Occupants. The northern side/boundary
consist of a 10-meter-high stable face which is to be left in current state. Mining will occur
on the blocks (blue squares). No blasting will occur, and blocks will be drilled by a low noise,
low vibrating drill up to a depth of 6 meters. Atlas Copco has introduced a handheld low
noise, low vibration drill which will be used to drill 20mm holes up to a depth of 6 meters
within the copper Oxide Mineral. Crackem, a Product of Samchem, is a non-explosive,
expansive and silent cracking agent that uses a powder composition for stone breaking.
Crackem is mixed with clean water and poured into pre-drilled holes in rock or concrete. It
then swells and exerts a significant expansive force on the hole-wall, fracturing the material
and splitting the rock. This demolition has an advantage over conventional explosives
because there is no noise, no toxic gases, no flying rocks, no explosions and no vibration.
The Oxidized state of the Secondary Carbonate/ Oxide minerals within the permit area will
be ideal for this mining method.

12
 E. Listed and specified activities

NAME OF ACTIVITY AERIAL LISTED APPLICABLE

EXTENT OF ACTIVITY LISTING
THE NOTICE
ACTIVITY
Mining - During the mining process 4.9 Ha Listing Activity 21 LN 1 in GN R327
the activities that will take place will Any activity
be excavation, stockpiling, loading, including the
hauling and trucks for transport off operation of that
site. There will be no processing activity which
plant on site. The only infrastructure requires a mining
should be solar powered lightning, a permit in
small temporary office building and terms of section 27
the rental ablution facility. of the Mineral and
Petroleum
Resources
Development Act,
2002 (Act No. 28 of
2002), including —

(a) associated
infrastructure,
structures and
earthworks directly
related to the
extraction of a
mineral resource; or
[including activities
for which an
exemption has been
issued in terms of
section 106 of the
Mineral and
Petroleum
Resources
Development Act,
2002 (Act No. 28 of
2002)]

(b) the primary

processing of a
mineral resource
including winning,
extraction,
classifying,
concentrating,

13
 crushing, screening
or washing;
but excluding the
secondary
processing of a
mineral resource,
including the
smelting,
beneficiation,
reduction, refining,
calcining or
gasification of the
mineral resource in
which case activity
6 in Listing Notice 2
applies.

Mine closure - The 4.9 Ha Listing Activity 22 LN 1 in GN R327

decommissioning of the 4.9 Ha The
area. The mine must be operated decommissioning of
so that once the mine is closed, the any activity
site can be used again. requiring –

(i) a closure
certificate in terms
of section 43 of the
Mineral and
Petroleum
Resources
Development Act,
2002 (Act No. 28 of
2002); or

(ii) a prospecting
right, mining right,
mining permit,
production right or
exploration
right, where the
throughput of the
activity has reduced
by 90% or more
over a period of 5
years excluding
where the
competent authority
has in writing
agreed

14
that such reduction
in throughput does
not constitute
closure;
but excluding the
decommissioning of
an activity relating
to the secondary
processing
of a –

(a) mineral
resource, including
the smelting,
beneficiation,
reduction, refining,
calcining or
gasification of the
mineral resource; or

(b) petroleum
resource, including
the refining of gas,
beneficiation, oil or
petroleum
products; –
in which case
activity 31 in this
Notice applies.

15
F. Description of the activities to be undertaken

The operation will follow the modus operandi:

The white area (See Annexure C Site Plan) is the already mined area where the Copper
Mineral has been extracted by previous mining Occupants. The northern side/boundary
consist of a 10-meter-high stable face which is to be left in current state. Mining will occur
on the blocks (blue squares). No blasting will occur, and blocks will be drilled by a low noise,
low vibrating drill up to a depth of 6 meters. Atlas Copco has introduced a handheld low
noise, low vibration drill which will be used to drill 20mm holes up to a depth of 6 meters
within the copper Oxide Mineral. Crackem, a Product of Samchem, is a non-explosive,
expansive and silent cracking agent that uses a powder composition for stone breaking.
Crackem is mixed with clean water and poured into pre-drilled holes in rock or concrete. It
then swells and exerts a significant expansive force on the hole-wall, fracturing the material
and splitting the rock. This demolition has an advantage over conventional explosives
because there is no noise, no toxic gases, no flying rocks, no explosions and no vibration.
The Oxidized state of the Secondary Carbonate/ Oxide minerals within the permit area will
be ideal for this mining method.

Transport:
Loaded trucks will avoid major roads during peak hours which are usually at the beginning
and end of business days, long weekends as well as end of month. The R 355 is an
alternative route that connects Springbok with Okiep via Nababeep. This Detour can be
used should it be recommended by the DMR and it is not a busy route since the De Beers
Namaqualand mines are closed.

Decommissioning:

The Applicant will create an attraction that will include a centre which the community will be
able to visit the history of the Blue Mine, the role it played in developing mining in the area,
the role of the Khoi San in Copper Mining etc. An amusement park will also be developed
for the children of the community as a way of creating a better environment for the people
of Springbok.

16
G. Policy and Legislative Context

REFERENCE HOW DOES THIS

APPLICABLE LEGISLATION AND DEVELOPMENT COMPLIY WITH
GUIDELINES USED TO COMPILE THE WHERE AND RESPOND TO THE
REPORT APPLIED LEGISLATION AND POLICY
CONTEXT?
National Environmental Management Act Current NEMA requirement as per
(NEMA) (Act 107 of1998) Document protocol.
Environmental Impact Assessment
Current NEMA requirement as per
Regulations (Government Notice R982,
Document protocol.
R983, R984, R985)
National Environmental Management: There are no critical
Section 10.3
Biodiversity Act, 2004 (Act 10 of 2004) biodiversity areas on the site.
Section 10.4
National Environmental Management: Air Dust Control measures are
Section 17.10
Quality Act, 2004 (Act 39 of 2004) discussed in the document.
Section 18.2
Section 10.4
National Dust Control Regulations (GN R827 Dust Control measures are
Section 17.10
of November 2013) discussed in the document.
Section 18.2
A heritage assessment is
National Heritage Resources Act, 1999 (Act
Section 10.7 being conducted for
25 of 1999)
submission to SAHRA.
The application for a mining
permit was submitted to
DMR in terms of Section 27
Mineral and Petroleum Resources
Section 3 of the MPRDA. Protocol
Development Act, 2008 (Act 28 of 2008)
establishes DMR as the
competent authority for the
NEMA application.
The health and safety of all
Section 8.3
Mine Health and Safety Act, 1996 (Act 29 of workers on the mine falls
Section 10.4
1999) under the MHSA and must
Section 10.5
be implemented.
Decision by Governs to conduct of the
Promotion of Administrative Justice Act, 2000
Competent authority under the
(Act 3 of 2000)
Authority Constitution.
“Need and Desirability” of the
Nama Khoi Local Municipality, Draft
Section F project is described
Integrated Development Plan 2018/2019.
regarding the IDP
Spatial Planning and Land Use Management Zoning related issues are
Section 5
Act, 2013 (Act 16 of 2013) addressed.
DEA Guidelines e.g. Alternatives, Using The relevant guidelines were
Current
Specialists, Needs & Desirability and Public used to guide the process
document
Participation and compile this document.

17
 H. Need and desirability of the proposed activities
The following section is based on the “Needs and Desirability” questionnaire as used
by the Western Cape Provincial Department of Environmental Affairs & Development
Planning (DEA&DP).

1. Is the activity The land is currently zoned as open space 1.

permitted in terms of the
YES NO
property’s existing land
use rights?
2. Will the activity be in line with the following?
(a) Provincial Spatial According to the IDP and PSDF there is a concentration of
Development minerals around the Springbok area, as well as in a broad
Framework (PSDF) band along the south of the Orange River. Although many of
these sources have been depleted, there are still plenty
occurrences that can be exploited, and this should be
YES NO considered for small scale mining. The Industrial mining
corridor as indicated in the PSDF must be investigated for
opportunities and exploited where possible. To solve the
disputes and issues related to mining rights and to investigate
the possibility for local communities to gain access and limited
mining rights in areas to be identified for this.
(b) Urban edge / Edge The proposed mine site falls within an urban edge. (Please
of Built environment for YES NO see Annexure C for Site Plan).
the area
(c) Integrated According to the IDP and PSDF there is a concentration of
Development Plan and minerals around the Springbok area, as well as in a broad
Spatial Development band along the south of the Orange River. Although many of
Framework of the Local these sources have been depleted, there are still plenty
Municipality (e.g. would occurrences that can be exploited, and this should be
the approval of this YES NO considered for small scale mining. The Industrial mining
application compromise corridor as indicated in the PSDF must be investigated for
the integrity of the opportunities and exploited where possible. To solve the
existing approved and disputes and issues related to mining rights and to investigate
credible municipal IDP the possibility for local communities to gain access and limited
and SDF?). mining rights in areas to be identified for this.
(d) Approved Structure Unable to source a Structure Plan for Springbok.
YES NO
Plan of the Municipality
(e) An Environmental No, the approval of this mining permit will in no way
Management compromise the integrity of the Environmental Management
Framework (EMF) priorities.
adopted by the
Municipality (e.g. Would
the approval of this
application compromise
YES NO
the integrity of the
existing environmental
management priorities
for the area and if so,
can it be justified in
terms of sustainability
considerations?)
(f) Any other Plans (e.g. No other plans exist for the area.
YES NO
Guide Plan)
3. Is the land use According to the IDP and PSDF there is a concentration of
(associated with the minerals around the Springbok area, as well as in a broad
activity being applied band along the south of the Orange River. Although many of
for) considered within these sources have been depleted, there are still plenty
YES NO
the timeframe intended occurrences that can be exploited, and this should be
by the existing approved considered for small scale mining. The Industrial mining
Spatial Development corridor as indicated in the PSDF must be investigated for
Framework (SDF) opportunities and exploited where possible. To solve the

18
agreed to by the disputes and issues related to mining rights and to investigate
relevant environmental the possibility for local communities to gain access and limited
authority (i.e. is the mining rights in areas to be identified for this.
proposed development
in line with the projects
and programmes
identified as priorities
within the credible IDP)?
5. Does the Because of the down turn in the economy there is a massive
community/area need need to support local economies and initiative for growth. This
the activity and the mining venture can contribute to the local economy and to
associated land use better the poor circumstances of the local communities.
concerned (is it a
societal priority)? (This
refers to the strategic as YES NO
well as local level (e.g.
development is a
national priority, but
within a specific local
context it could be
inappropriate.)
6. Are the necessary Services are not to be provided by the municipality. All
services with adequate services will be self-supplied and contained on the mining
capacity currently area.
available (at the time of
application), or must
additional capacity be
created to cater for the
YES NO
development?
(Confirmation by the
relevant Municipality in
this regard must be
attached to the final
Basic Assessment
Report as Appendix E.)
7. Is this development The site falls outside of the municipal area. There is no
provided for in the additional pressure on municipal infrastructure.
infrastructure planning
of the municipality, and
if not, what will the
implication be on the
infrastructure planning
of the municipality
(priority and placement YES NO
of services and
opportunity costs)?
(Comment by the
relevant Municipality in
this regard must be
attached to the final
Basic Assessment
Report as Appendix E.)
8. Is this project part of Other than job creation this is a purely private business
a national programme to decision.
address an issue of YES NO
national concern or
importance?
Do location factors favor Copper resources occur where they were deposited through
this land use geological time.
(associated with the YES NO
activity applied for) at
this place? (This relates

19
to the contextualization
of the proposed land
use on this site within its
broader context.)
10. How will the activity There will be no impact on the cultural areas nor sensitive
or the land use natural areas.
associated with the
activity applied for,
impact on sensitive YES NO
natural and cultural
areas (built and
rural/natural
environment)?
11. How will the The mining will be temporary with measures in place to prevent
development impact on any impact on the surrounding population.
people’s health and
wellbeing (e.g. in terms YES NO
of noise, odors, visual
character and sense of
place, etc.)?
12. Will the proposed No. Currently the land is not in use.
activity or the land use
associated with the
YES NO
activity applied for,
result in unacceptable
opportunity costs?
13. What will the There are no cumulative impacts other than possible dust
cumulative impacts pollution associated with this mine. The dust will be managed
(positive and negative) via the approved EMPR based on the mining area being so
YES NO
of the proposed land close to the community.
use associated with the
activity applied for, be?
14. Is the development Mining will be a low impact activity and mitigation measure will
the best practicable be put in place to prevent any and all possible pollution
YES NO
environmental option for impacts.
this land/site?
15. What will the benefits be to There are jobs created and services and supplies bought from local
society in general and to the businesses. It will therefore stimulate the local economy and contribute
local communities? to the national focus through tax and levies.
16. Any other need and No.
desirability considerations
related to the proposed activity?

20
I. Motivation for the overall preferred site, activities and technology
alternative

The following factors played a role in the determination of the site.

1. The site has proven resources.

2. The site belongs to a private person.
3. The site is 500m from the town and associated activities.
4. The site is not environmentally sensitive.
5. The site is not close to any tourist routes.
6. The site is not visually sensitive.
7. The site does not contain natural vegetation.
The benefits of the project can be divided into social and economic classifications. The
mine will provide direct employment to local persons. The operation further creates
indirect employment opportunities in equipment supply industries, transport and
construction environment. The site is layout is restricted to 4.9 Ha as this is the footprint
under the MPRDA, 2002.

J. Full description of the process followed to reach the proposed preferred

alternatives within the site.

The layout and location of the proposed site is dictated by the location of the resources.
It is a section available for mining without significantly impacting on farming /
surrounding activities. These facts preclude the identification of alternative layout or
location options.

K. Details of the development footprint alternatives considered.

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

activity;

The site has been tested for copper and has been found to contain viable volumes of
the resource. Neighbouring properties were not considered because there is no data
available regarding the copper resource.

(b) the type of activity to be undertaken;

The piece of land under application is the only section of land that contains
economically viable volumes for mining. As Xwena Copper Pty Ltd are not the owners
of the land it cannot propose alternative activities such as housing or commercial
developments.

21
(c) the design or layout of the activity;

For the venture to be economically viable, the entire 4.9 Ha needs to be mined.
Furthermore, the application area constitutes the only viable area on the farm with
minimal interference to the other agricultural activities.

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

The technology chosen for this operation is taking cognisance of the fact that water is
a scares commodity and therefore no processing will take place on the site.

(e) the operational aspects of the activity; and

The small size of the application area negates most operational alternatives. A section
of the site will be subject to mining (See Annexure C for the Site Plan). The only
alternative therefore will be to either start the mining from the northern side/boundary
consisting of a 10-meter-high stable face which is to be left in current state. Mining will
occur on the blocks (blue squares) (See Annexure C for the Site Plan). No blasting
will occur, and blocks will be drilled by a low noise, low vibrating drill up to a depth of 6
meters. Atlas Copco has introduced a handheld low noise, low vibration drill which will
be used to drill 20mm holes up to a depth of 6 meters within the copper Oxide Mineral.
Crackem, a Product of Samchem, is a non-explosive, expansive and silent cracking
agent that uses a powder composition for stone breaking. Crackem is mixed with clean
water and poured into pre-drilled holes in rock or concrete. It then swells and exerts a
significant expansive force on the hole-wall, fracturing the material and splitting the
rock. This demolition has an advantage over conventional explosives because there is
no noise, no toxic gases, no flying rocks, no explosions and no vibration. The Oxidized
state of the Secondary Carbonate/ Oxide minerals within the permit area will be ideal
for this mining method.

(f) the option of not implementing the activity.

The no-go option is at play with this application. However, considering the positive
benefits garnered from the operation and its very limited negative impact on the land
and surrounding community. The local community will benefit in the sense of job
creation by using the local community members during the mining operations.

22
L. Details of the Public Participation Process Followed

The public participation that is followed is being conducted according to the

requirements prescribed in Regulation 40 to 44 of the EIA Regulations (GN R326). The
following modus operandi is followed:

• The land owner was consulted during the application phase.

• The surrounding/adjacent landowners were consulted during the public
participation phase.
• Notices and Background Information Documents (BIDs) will be supplied to all
identified Interested and Affected Parties (I&APs).
• A notice was placed in the local newspaper (Die Plattelander)
• A site notice was placed on the Library Notice Board and Municipal Office.
• Notices were placed in the public library and the Municipal building notice board.
• A copy of the Draft BAR & EMPr will be placed in the Municipal Public Library.

23
 M. Summary of issues raised by I&APs

Interested and Affected Parties Date Issues raised EAPs response to issues as mandated by Section and
Comments the applicant paragraph
List the names of persons consulted in Received reference in
this column, and this report
Mark with an X where those who must where the
be consulted were in fact issues and or
consulted. response were
incorporated.
AFFECTED PARTIES
Landowner/s X
Namakwaland Toerisme Courier
Ontwikkelingsmaatskappy DBAR for
comment

Lawful occupier/s of the land

Landowners or lawful occupiers X

on adjacent properties

Municipal Managers X
Municipality X
Organs of state (Responsible for
infrastructure that may be
affected Roads Department,
Eskom, Telkom, DWA

24
Communities

Dept. Land Affairs

Traditional Leaders

Dept. Environmental Affairs

Other Competent Authorities

affected
Environment and Nature
Conservation
Department of Agriculture

OTHER AFFECTED PARTIES

Namakwa District Municipality
Nama Khoi Local Municipality

INTERESTED PARTIES
WESSA Northern Cape

25
N. The Environmental attributes associated with the alternatives.

Baseline Environment

i. Type of environment affected by the proposed activity

Geographical Environment:

The site is in the magisterial district of Springbok in the Western Cape Province. Springbok falls
under the Nama Khoi Local Municipality and the Namakwa District Municipality.

Physical Environment:

Climate:

Springbok had dry periods throughout the year with temperatures reaching over 30 degrees Celsius.
The month of May is said to be the wettest month in the area and January the driest month.

Topography, Soils, Geology:

Water Resources:

There are no water resources located close to the proposed development.

Biological Environment:
The Nama Khoi Local Municipality is a unique and diverse environment owing in large part to the
presence of four distinct biogeographical regions within its boundaries. The Orange River valley lies
to the north and is characterized by very dry desert conditions. In the west the Local Municipality is
composed of coastal plains which transition into granite hills that straddle the escarpment, before
transforming into low lying Bushmanland plains to the East of Springbok. Thus, rainfall patterns
range from consistent winter rainfall in the west to more unreliable summer rainfall to the east with a
variability of between 50 mm to 350 mm between the low-lying areas and the less arid peaks.

26
Animal Life:

Because of the intensive farming practices and constant human traffic there is no animals expected
on the site other than transient species

Air and Noise Quality

Xwena Copper will appoint an environmental Company to install Dust Collection Probes as well as
Noise measuring devices at strategic points around the permit area 1 month prior to operation
commencement. This will give us a good idea of the current/background dust and noise pollution of
the surrounding area. This will give us a standard with which we can compare should mining
commence keeping in mind the local statutory threshold. Very little noise is anticipated due to
mining and dust will be suppressed by water during loading should the need arise.

Socio-economic Environment:

Springbok should be promoted as the highest order settlement in the Municipality and its image
should subsequently be improved as an attractive tourist town, retail and light industry and transport
service centre. Springbok can therefore be the economic heartbeat of the municipal area.

The Provincial SDF identified Springbok as a growth area with high urban potential which implies
that infrastructure investment and spending should ideally focus on these areas with potential. It is
proposed that Springbok should form part of functional rural region 3 (including Springbok, Bergsig,
Okiep, Matjieskloof, Nababeep, Bulletrap, Concordia and Carolusberg).

In order to steer development and growth, it is essential to prepare and implement an Urban Design
and landscaping framework for Springbok and surrounds that address amongst others: Building
appearance (protecting and where necessary reinstating historic buildings,); Street furniture;
Sidewalks; Cycle lanes; Parks, squares and street markets; Public transport interchanges; and Tree
planting and landscaping.

The Urban Design Framework should also include (as proposed in the Provincial Spatial
Development Framework):
• The CBD, Voortrekker, Inry and Sinagoge Streets and should be linked;
• Bergsig via Inry, Dr Izak van Niekerk, Klip Streets, back over the neck to the Hospital, along
Sinagoge Street to Voortrekker Street;
• The mission area at Matjieskloof should also be investigated to see if it has tourism appeal
like missions on the Western Cape mission route such as Genadendal, Mamre and Elim.

Inry Street should be upgraded and a sectoral Spatial Development Plan (SDP) prepared to enable
it to develop as an activity street linking Bergsig and the CBD separately from the N7.

There should be an investigation of the potential link between Bergsig and the CBD via extensions
of Klip Street (Bergsig) and Sinagoge Street CBD including a Sectoral SDP. If viable these areas
should be planned as an integrated CBD/Tourism precinct. If this investigation suggests that
strengthening these links is feasible this project should be motivated for a National Treasury
Neighbourhood Development Program Grant (NDPG).

Land for housing that may be required to address backlogs and future growth should be located in
infill land that promotes the compaction and integration of the settlement.

27
The diamond and copper beneficiation priority and tourism skills institute projects identified in the
LED strategy (2007) would be best located in Springbok. The Industrial area precinct should be
investigated as a suitable location for these activities.

Pedestrian sidewalks, cycle lanes where appropriate and tree planting should be installed along the
roads linking Matjieskloof and Bergsig to the CBD to investigate the hosting of a major town festival
in Springbok or Steinkopf such as art, culture and music during the peak flower season, as well as
regular monthly festivals to provide recreation and entertainment to local residents and also to attract
visitors to the area.

Additional high-quality educational facilities (and employment of teachers and trainers) should be
expanded and developed as a key priority. This can insure a proper educational opportunity to all
people provided that affordable and safe accessibility and accommodation for learners in the region
is provided. The feasibility of a tertiary educational facility should also be investigated.

The upgrading of the existing airport in Springbok can potentially increase the regional, national and
international accessibility of the area. Infill and densification should hence be promoted surrounding
the upgraded airport. Potentially high wind energy generation zones have been identified around
Springbok. These areas should be investigated for the development of wind farms.

In granting the mining permit for the proposed area the Applicant may be able to assist in some of
the urgent needs of the area/ town as indicated by the Nama Khoi Local Municipality.

Heritage / Cultural Environment:

The historical significance of the Springbok area which indicates that before the Blue Mine in
Springbok there was previously mined in South Africa. We therefore question the acknowledgment
and that it should be enjoyed as an inheritance area, as it is only the first Post-Colonial commercial
mine in South Africa but not the first. According to research and correspondence from SAHRA the
proposed development was never formally been earmarked as a heritage site.

However, the Applicant is comfortable linking themselves to a range of conditions to ensure that
through the proposed mining activities, they will:

• Create an attraction that will include a centre that the community will be able to visit the
history of the Blue Mine, the role it played in developing mining in the area, the role of the
Khoi San in Copper Mining etc.
• A tourism attraction will be after we have stopped mining activities.
• The Applicant will not be using explosives or equipment that will make noise as the
community is close to the mine area.
• Use mining materials that are environmentally friendly.
• Children's amusement park or other activities can be developed that can be utilized by the
surrounding communities after mining has stopped.

The area is currently looking unpleasant and is dangerous for the people of the town as well as
tourism who want to visit it. The Applicant will appoint a Landscape Architect to make suggestions
that can be considered and recommended by the various stakeholders, which will then be used as
a guideline in the area of mine and rehabilitation so that it will eventually look better and much more

28
functional as it currently looks. By the nature of the case we will allocate an amount to make the
above possible.

The granting of the Permit will create jobs in an area where it is very scarce. Not only at the proposed
mine but also at the Plant in Okiep. The Applicant is minimizing the use of machinery to create the
maximum number of jobs and minimize noise and inconvenience to any party. Their interests as a
previously disadvantaged Klein Myner Company's interests should also be considered. The socio-
economic impact our operations will have in the larger Nama Khoi area will also support the viability
of the other small mine permit areas we also applied for.

The Applicant is further prepared if their proposals are not sufficient to engage with the relevant
Heritage Representatives as well as the owners of the land to discuss a consensus win - win
agreement for all.

ii. Description of the current land uses:

The application site is currently not used. The mine area is from a mountainous nature and therefore
not used for any particular purpose hence the application for a mining permit to make use of the area
and provide work and give back to community.

iii. Description of specific environmental features and infrastructure on the site

The mine area is from a mountainous nature and therefore not used for any particular purpose hence
the application for a mining permit to make use of the area and provide work and give back to
community. The proposed mine area falls within an urban edge.

29
iv. Environmental and current land use map.

Already mined area

Mining Blocks Stable Face

30
Impacts and risks identified including the nature, significance, consequence, extent, duration and
probability of the impacts, including the degree to which these impacts

(Provide a list of the potential impacts identified of the activities described in the initial site layout that will be
undertaken, as informed by both the typical known impacts of such activities, and as informed by the
consultations with affected parties together with the significance, probability, and duration of the impacts.
Please indicate the extent to which they can be reversed, the extent to which they may cause irreplaceable
loss of resources, and can be avoided, managed or mitigated).

The following table will discuss the potential impacts of the mining operation and the
applicable mitigation measures.

Aspect Potential Impact Mitigation Measures

Construction Phase
Topography • Changing the • No mitigation.
topographical profile
Soils • Loss of land capability • Due to the nature of the copper mineral
• No topsoil there will be no topsoil to remove. The
Applicant will enforce any rehabilitation
measures as indicated by the
Department of Mineral Resources.
Land Use • Impact on land use. • The land was previously mined but is
currently vacant and not used by the
landowner.

Vegetation • No natural vegetation • There is no vegetation to remove.

on site. Other measures of rehabilitation will be
• Dust pollution implemented.
potential. • Shade netting and covering the mineral
to limit dust pollution.
Surface Water • Contamination of • Cut-off drains will be in dug on the
surface water sources. borders of the mine site to prevent
• Potential erosion. water from entering the site.
• The cut-off trenches will linkup with
natural drainage features.
• All cut-off trenches will be equipped
with flow arrestors.
• No servicing of vehicles on site unless
in the case of an emergency and then
with appropriate measures.
Ground Water • Contamination of • No groundwater abstraction will take
groundwater. place.
• Reduction of
groundwater levels.
Air Quality – Dust • Potential dust • Shade netting and covering the mineral
pollution. to limit dust pollution.
• Vehicle traffic must be limited to a
minimum.
Air Quality – Emissions • Potential air pollution. • All vehicles must be regularly serviced
and maintained.
Archaeological • Potential loss of • Any archaeological finds must be
archaeological finds. reported to SAHRA with immediate
effect.
Visual Aspects • Negative visual • The visual aspect will be temporary
impact. and can unfortunately not be mitigated.

31
Socio-economic • Positive impact • Workforce members will be employed.
• The workforce will reside in Springbok.
Interested & Affected • Positive relations. • Regular meetings with the land owner
Parties will take place to discuss the operation.
Noise • Potential noise • The construction vehicles must only be
pollution. working a certain time of the day to
avoid disturbance of the local
community.
• Work hours will be restricted.
Operational Phase
Topography • Changing the • The local topography of the site will be
topographical profile slightly disturbed during the mining
operations. It will however be rectified
during rehabilitation.
Soils • Loss of land capability • Due to the nature of the copper mineral
• No top soil there will be no topsoil to remove. The
Applicant will enforce any rehabilitation
measures as indicated by the
Department of Mineral Resources.
Land Use • Impact on land use. • The land was previously mined but is
currently vacant and not used by the
landowner.
Vegetation • There is no natural • There is no vegetation to remove.
vegetation. Other measures of rehabilitation will be
• Dust pollution implemented.
potential. • Shade netting and covering the mineral
to limit dust pollution.
Surface Water • Contamination of • Cut-off drains will be dug on the
surface water sources. borders of the mine site to prevent
• Potential erosion. water from entering the site.
• The cut-off trenches will linkup with
natural drainage features.
• All cut-off trenches will be equipped
with flow arrestors.
Ground Water • Contamination of • No groundwater abstraction will take
groundwater. place.
• Reduction of
groundwater levels.
Air Quality – Dust • Potential dust • Shade netting and covering the mineral
pollution. to limit dust pollution.
• Vehicle traffic must be limited to a
minimum.
Air Quality – Emissions • Potential air pollution. • All vehicles must be regularly serviced
and maintained.
Archaeological • Potential loss of • Any archaeological finds must be
archaeological finds. reported to SAHRA with immediate
effect.
Visual Aspects • Negative visual • The visual aspect will be temporary
impact. and can unfortunately not be mitigated.
Socio-economic • Positive impact. • Workforce members will be employed.
• The workforce will reside in Springbok.
Interested & Affected • Positive relations. • Regular meetings with the land owner
Parties will take place to discuss the operation.

32
Noise • Potential noise • The construction vehicles must only be
pollution. working a certain time of the day to
avoid disturbance of the local
community.
• Work hours will be restricted.
Decommissioning Phase
Topography • Changing the • The site will be rehabilitated as per the
topographical profile recommendations from the Department
of Mineral Resources.
Soils • Loss of land capability • All the soil taken out of the geological
• Loss of top soil profile will be returned other than the
rock fraction.
• There is no topsoil to remove and use
during the rehabilitation phase. The
applicant will have to rehabilitate the
area as recommended from the
Department of Mineral Resources.
Land Use Positive impact on land • Create an attraction that will include a
use after mining is centre that the community will be able to
completed. visit the history of the Blue Mine, the role
it played in developing mining in the
area, the role of the Khoi San in Copper
Mining etc.
• Children’s amusement park or other
activities can be developed that can be
utilized by the surrounding communities
after mining is completed.

Vegetation • No natural vegetation. • There is no vegetation to remove.

• Dust pollution Other measures of rehabilitation will be
potential. implemented.
• Shade netting and covering the mineral
to limit dust pollution.
Surface Water • Contamination of • No surface water will be contaminated.
surface water sources. • The cut-off trenches will be removed to
• Potential erosion. allow natural drainage patterns to
resume.
Ground Water • Contamination of • Groundwater will not be impacted
groundwater. because the entire geological profile
• Reduction of will be replaced.
groundwater levels.
Air Quality – Dust • Potential dust • Dust will be combated during
pollution. rehabilitation by shade netting or
covering material that is not yet
transported off site.
Air Quality – Emissions • Potential air pollution. • All vehicles will be removed from the
site.
• The rehabilitation vehicles will be fitted
with SABS standard silencers to
combat noise.
Archaeological • Potential loss of • Not applicable.
archaeological finds.

33
Visual Aspects • Positive visual impact. • As indicated by the Applicant the site
will be developed into a tourist
attraction with emphasis on the
Historical background of the town
Springbok and creating amusement
park for children to enjoy.
Socio-economic • Positive impact • The work force will be absorbed into
other projects post mining.
Interested & Affected • Negative relations. • The I&Aps will be informed of the
Parties closure process.
Noise • Potential noise • The only noise will be from the
pollution. rehabilitation vehicles and that will
cease with handover to the farmer.

34
 i. Methodology used in determining and ranking the nature, significance,
consequences, extent, duration and probability of potential
environmental impacts and risks;
(Describe how the significance, probability, and duration of the aforesaid identified impacts that were
identified through the consultation process were determined in order to decide the extent to which the
initial site layout needs revision).

Impact Assessment Methodology

The following generic criteria will be used to describe magnitude and significance of
impacts in a systematic manner. The criteria are:

• extent or spatial scale of the impact;

• intensity or severity of the impact;
• duration of the impact;
• mitigation potential;
• acceptability;
• degree of certainty;
• status of the impact; and
• legal requirements.

Ratings are assigned for each criterion. The significance of impacts of the proposed project
is assessed both with and without mitigation action.

Table 1: Categories for the rating of impact magnitude and significance

Impact Magnitude and Significance Rating

Of the highest order possible within the bounds of impacts that could occur. In the case of
adverse impacts, there is no possible mitigation that could offset the impact, or mitigation
is difficult, expensive, time-consuming or some combination of these. Social, cultural and
High:
economic activities of communities are disrupted to such an extent that these come to a
halt. In the case of beneficial impacts, the impact is of a substantial order within the
bounds of impacts that could occur.
Impact is real, but not substantial in relation to other impacts that might take effect within
the bounds of those that could occur. In the case of adverse impacts, mitigation is both
feasible and fairly easily possible. Social, cultural and economic activities of communities
Medium:
are changed, but can be continued (albeit in a different form). Modification of the project
design or alternative action may be required. In the case of beneficial impacts, other
means of achieving this benefit are about equal in time, cost and effort.
Impact is of a low order and therefore likely to have little real effect. In the case of adverse
impacts, mitigation is either easily achieved or little will be required, or both. Social,
Low: cultural and economic activities of communities can continue unchanged. In the case of
beneficial impacts, alternative means of achieving this benefit are likely to be easier,
cheaper, more effective and less time-consuming.
No Zero impact.
impact:

Extent and Spatial Scale

Extent or spatial scale of the impact description will be provided as to whether impacts are
either limited in extent or affect a wide area or group of people.

35
Table 2: Criteria for rating the extent or spatial scale of impacts

Rating
Widespread.
Far beyond site boundary.
High:
Regional /national
/international scale.
Beyond site boundary.
Medium:
Local area.
Low: Within site boundary.

Intensity or Severity of Impacts

A description will be provided as to whether the intensity of the impact is high, medium, low
or has no impact in terms of its potential for causing negative or positive effects.

Table 3: Criteria for rating the intensity or severity of impacts

Rating
Disturbance of pristine areas that have important conservation value.
High:
Destruction of rare or endangered species.
Disturbance of areas that have potential conservation value or are of use as resources.
Medium:
Complete change in species occurrence or variety.
Disturbance of degraded areas, which have little conservation value.
Low:
Minor change in species occurrence or variety

Duration of the impact

The duration of the impact will be classified as short term (0 to 5 years), medium term (5 to
15 years), long term (more than 15 years, with the impact ceasing after the operational life
of the development) or considered permanent.

Table 4: Criteria for rating the duration of impacts

Rating
Permanent.
High (Long term: Beyond decommissioning.
Long term (More than 15 years).
Reversible over time.
Medium (Medium term): Lifespan of the project.
Medium term (5 - 15 years)
Quickly reversible.
Low (Short term): Less than the project lifespan.
Short term (0 - 5 years)

36
Mitigation potential

The potential to mitigate the negative impacts and enhance the positive impacts is
determined in the specialist reports. For each identified impact, mitigation objectives that
would result in a measurable reduction in impact should be provided. Management actions
that could enhance the condition of the environment (i.e. potential positive impacts of the
proposed project) will be identified. Performance criteria for reviewing or tracking the
effectiveness of the proposed mitigation action will be provided where appropriate.

Table 5: Criteria for rating the mitigation potential of impacts

Rating
High: High potential to mitigate negative impacts to the level of insignificant effects.
Potential to mitigate negative impacts. However, the implementation of mitigation
Medium:
measures may still not prevent some negative effects.
Low: Little or no mechanism to mitigate negative impacts.

Acceptability

The level of acceptability often depends on the stakeholders, particularly those directly
affected by the proposed project, legal limits, guidelines and industry standards.

Table 6: Criteria for rating the acceptability of impacts

Rating
Abandon project in part or in its entirety. Redesign project to remove or
High (Unacceptable):
avoid impact.
Medium
With regulatory controls. With project proponent's commitments.
(Manageable):
Low (Acceptable): No risk to public health

Degree of certainty

A description is to be provided of the degree of certainty of the impact actually occurring as

unsure, possible, probable, or definite (impact will occur regardless of prevention
measures).

Table 7: Criteria for rating the degree of certainty of impacts

Rating
More than 90% sure of a particular fact. Substantial supportive data exist to verify the
Definite:
assessment.
Probable: Over 70% sure of a particular factor of the likelihood of that impact occurring.
Possible: Only over 40% sure of a particular factor of the likelihood of an impact occurring.
Less than 40% sure of a particular fact or the likelihood of an impact occurring. No risk
Unsure:
to public health

37
 ii. The positive and negative impacts that the proposed activity (in terms of
the initial site layout) and alternatives will have on the environment and
the community that may be affected
(Provide a discussion in terms of advantages and disadvantages of the initial site layout compared to
alternative layout options to accommodate concerns raised by affected parties)

Positive Impacts Negative Impacts

Creating job opportunities. Life of mine visual impact.
Supporting local Life of mine potential dust
businesses. pollution.
Contributing to the national
focus through tax and Life of mine noise pollution.
royalties.
Recreational development
(Creating a Heritage
No natural vegetation
beacon for Springbok
therefore no negative
community and creating
impact.
amusement park for
children to enjoy etc.)

iii. The possible mitigation measures that could be applied and the level of
risk
(With regard to the issues and concerns raised by affected parties provide a list of the issues raised and
an assessment/ discussion of the mitigations or site layout alternatives available to accommodate or
address their concerns, together with an assessment of the impacts or risks associated with the
mitigation or alternatives considered).

The level of risk with all three the identified potential impacts are low. Two of the
impacts (dust and noise) are manageable and can be controlled to the point that it
will not be a factor.

Proposed Mine Plan and Mitigation Measures for the Springbok Mine.

Xwena Copper (PTY) Ltd has applied for a small scal mining Permit on the Blue
Mine, Springbok.

The rate of mining will be in the vicinity of 15 000 ton per quarter. The Company is
fully aware of all applicable laws and Regulations and is committed to adhere to all
Statutory Requirements. The Company has done extensive research in the most
applicable routes to economically extract the mineral while minimizing all impacts
related to Safety, Health, Environmental and Quality.

Mining Method

The white area (Map) is the already mined area where the Copper Mineral has been
extracted by previous mining Occupants. The northern side/boundary consist of a 10
meter high stable face which is to be left in current state. Mining will occur on the
blocks (blue squares). No blasting will occur and blocks will be drilled by a low
noise, low vibrating drill up to a depth of 6 meters. Atlas Copco has introduced a
handheld low noise, low vibration drill which will be used to drill 20mm holes up to a
depth of 6 meters within the copper Oxide Mineral. Crackem, a Product of
Samchem, is a non-explosive, expansive and silent cracking agent that uses a
powder composition for stone breaking. Crackem is mixed with clean water and
poured into pre-drilled holes in rock or concrete. It then swells and exerts a

38
significant expansive force on the hole-wall, fracturing the material and splitting the
rock. This demolition has an advantage over conventional explosives because there
is no noise, no toxic gases, no flying rocks, no explosions and no vibration. The
Oxidized state of the Secondary Carbonate/ Oxide minerals within the permit area
will be ideal for this mining method.

Air and Noise Quality

Xwena Copper will appoint an environmental Company to install Dust Collection

Probes as well as Noise measuring devices at strategic points around the permit
area 1 month prior to operation commencement. This will give us a good idea of the
current/background dust and noise pollution of the surrounding area. This will give
us a standard with which we can compare should mining commence keeping in
mind the local statutory threshold. Very little noise is anticipated due to mining and
dust will be suppressed by water during loading should the need arise.

Transport Routes

Loaded trucks will avoid major roads during peak hours which are usually at the
beginning and end of business days, long weekends as well as end of month. The R
355 is an alternative route that connects Springbok with Okiep via Nababeep. This
Detour can be used should it be recommended by the DMR and it is not a busy
route since the De Beers Namaqualand mines are closed.

Access Control

Access to the mine site will be controlled by a registered Security Company 24

hours per day and fencing will be repaired to avoid unauthorized entrance.

Heavy Machinery

At any given time will only one truck, one Loader and one excavator be allowed on
the premises. This machinery will be parked at the mined-out area (white area on
map) where loading will take place. The mined-out area (white) is a well-covered
area which is not easily visible.

Offices and Ablution

Two temporary (containerized) offices will be used to be mounted on concrete

stands and one ablution facility. The ablution facility will be contracted out to a
chemical company. Water for personal use and dust suppression will be supplied
from a 10 000 L Jo Jo tank which will be filled by water truck from the plant area
(Okiep)

39
 Stable Face

Already
mined area

Mining Blocks

iv. Motivation where no alternative sites were considered

Alternative sites could not be considered because of the following reasons:

• Mineral deposits occur where they occur in the geological profile. Alternative
sites will not exhibit the same mineralisation or geological occurrence. You
have to mine where the mineral occurs in economic quantities.
• The layout and use pattern of the farm is such that this is the only minable
block which will not impact on other surrounding areas besides the community
which is in proximity.
• The resource has been identified through third-party prospecting confirming
the occurrence of rock.
• The site features easy access to the copper with little to no overburden.

v. Statement motivating the alternative development location within the

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

Because the site is so small 4.9 Ha all of it will be mined. The primary processing
plant will not be located on the site. There can therefore be no alternative
development location within the overall site.

Full description of the process undertaken to identify, assess and rank the
impacts and risks the activity will impose on the preferred site (In respect of
the final site layout plan) through the life of the activity.
(Including (i) a description of all environmental issues and risks that were identified during the environmental impact
assessment process and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which
the issue and risk could be avoided or addressed by the adoption of mitigation measures.)

The risk assessment and impact analysis done for the mine was based on a combination of
desktop studies, prior experience in this field, consultation with interested and affected parties
and specialist input. Site visits to assess the situation on the ground was done. Each potential
impact was then evaluated according to the methodology as described.

40
 O. Assessment of each identified potentially significant impact and risk
(This section of the report must consider all the known typical impacts of each of the activities (including those that could or should have been identified by knowledgeable persons)
and not only those that were raised by registered interested and affected parties).
NAME OF ACTIVITY POTENTIAL ASPECTS PHASE SIGNIFICANCE MITIGATION TYPE SIGNIFICANCE
IMPACT AFFECTED In which impact is if not mitigated if mitigated
(E.g. For prospecting - drill site, (Including the anticipated
site camp, ablution facility, potential impacts for
accommodation, equipment cumulative impacts)
storage, sample storage, site (modify, remedy, control, or stop)
office, access route through
etc…etc…etc (e.g. noise control measures, storm-
water control, dust control,
E.g. For mining - excavations, (e.g. dust, noise, rehabilitation, design measures,
(e.g. Construction,
blasting, stockpiles, discard drainage surface blasting controls, avoidance,
commissioning,
dumps or dams, Loading, disturbance, fly rock, relocation, alternative activity etc. etc)
operational
hauling and transport, Water surface water Decommissioning,
supply dams and boreholes, contamination, E.g.
closure, post-closure)
accommodation, offices, groundwater Modify through alternative method.
ablution, stores, workshops, contamination, air Control through noise control
processing plant, storm water pollution etc) Control through management and
control, berms, roads, pipelines, monitoring through rehabilitation.
power lines, conveyors,
etc…etc…etc.)
Vegetation clearing • Clearing of Environmental Construction Very Low (No Topsoil Management. Low Negative
vegetation Social Operational natural Dust Control.
from the vegetation)
site.
• Potential
dust
pollution.
Mining • Dust Environment Operational Moderate Dust Control. Low Negative
pollution. Social Negative Vehicle and Plant
• Noise Maintenance.
Pollution.
• Visual
Impact.
Decommissioning & • Dust Environment Mine Closure Moderate Dust Control. Low Negative
Rehabilitation pollution. Social Positive Vehicle Maintenance.
• Noise
pollution.
The supporting impact assessment conducted by the EAP must be attached as an appendix, marked Appendix B

41
 P. Summary of specialist reports
(This summary must be completed if any specialist reports informed the impact assessment and final site layout process and must be in the following tabular form) -
SPECIALIST REFERENCE TO
RECOMMENDATIO APPLICABLE
NS THAT HAVE SECTION OF
LIST OF BEEN INCLUDED IN REPORT WHERE
RECOMMENDATIONS OF SPECIALIST REPORTS
STUDIES UNDERTAKEN THE EIA REPORT SPECIALIST
(Mark with an X RECOMMENDATIO
where applicable) NS HAVE BEEN
INCLUDED.
Heritage The historical significance of the Springbok area which indicates that
before the Blue Mine in Springbok there was previously mined in
South Africa. We therefore question the acknowledgment and that it
should be enjoyed as an inheritance area, as it is only the first Post-
Colonial commercial mine in South Africa but not the first. According
to research and correspondence from SAHRA the proposed
development was never formally been earmarked as a heritage site.

However, the Applicant is comfortable linking themselves to a range

of conditions to ensure that through the proposed mining activities,
they will:
• Create an attraction that will include a centre that the
community will be able to visit the history of the Blue Mine,
the role it played in developing mining in the area, the role of
the Khoi San in Copper Mining etc.
• A tourism attraction after mining activities have ceased.
• The Applicant will not be using explosives or equipment that
will make noise as the community is close to the mine area.
• Use mining materials that are environmentally friendly.

42
 • Children's amusement park or other activities can be
developed that can be utilized by the surrounding
communities after mining has stopped.

The area is currently looking unpleasant and is dangerous for the

people of the town as well as tourism who want to visit it. The
Applicant will appoint a Landscape Architect to make suggestions
that can be considered and recommended by the various
stakeholders, which will then be used as a guideline in the area of
mine and rehabilitation so that it will eventually look better and much
more functional as it currently looks. By the nature of the case we
will allocate an amount to make the above possible.

The granting of the Permit will create jobs in an area where it is very
scarce. Not only at the proposed mine but also at the Plant in Okiep.
The Applicant is minimizing the use of machinery to create the
maximum number of jobs and minimize noise and inconvenience to
any party. Their interests as a previously disadvantaged Klein Myner
Company's interests should also be considered. The socio-economic
impact our operations will have in the larger Nama Khoi area will also
support the viability of the other small mine permit areas we also
applied for.

Botanical No natural or critical vegetation on site

43
The following factors negate the use of specialists to inform the process:

• The site is small in extent.

• The mining method is very simple with limited impacts. There will be no impact on natural
vegetation.
• Enough information exists to enable informed decision making.
• There are no sub surface groundwater structures that can be impacted. The functionality
of rehabilitated subsurface geology will not be compromised.

44
 Q. Environmental impact statement

i. Summary of the key findings of the environmental impact assessment;

Three impacts were identified as relevant with regard to the proposed operation:

• Potential Dust Pollution – Dust pollution is the major impact that must be
managed on the site. The area is near the Springbok town and therefore shade
netting or covering materials are one of the necessary mitigation measures.
• Potential Noise Pollution. – Noise pollution is a significant factor as the
construction vehicles will enter and leave the site. Mining vehicles will only be
allowed a certain time to work to minimize disturbance.
• Visual Impact – The area is will be visual to the landowner and people accessing
the property as well as people using the R355.
• No natural vegetation – The mining activity will have no impact on the natural or
critically endangered vegetation.

ii. Final Site Map

Provide a map at an appropriate scale which superimposes the proposed overall activity and its
associated structures and infrastructure on the environmental sensitivities of the preferred site indicating
any areas that should be avoided, including buffers. Attach as Appendix A

Please see Appendix C for the formal mine plan.

Mining sequence

Stable
Face

Already mined
area

Mining blocks

The mining blocks will be mined in this sequence please see image above. Each block
will be rehabilitated prior to moving to the next block.

45
iii. Summary of the positive and negative impacts and risks of the proposed
activity and identified alternatives;

Positive Impacts Negative Impacts

Creating job opportunities. Life of mine visual impact.
Supporting local Life of mine potential dust
businesses. pollution.
Contributing to the national
focus through tax and Life of mine noise pollution.
royalties.
Recreational development
(Creating a Heritage
No natural vegetation
beacon for Springbok
therefore no negative
community and creating
impact.
amusement park for
children to enjoy etc.)
R. Proposed impact management objectives and the impact management
outcomes for inclusion in the EMPr;
Based on the assessment and where applicable the recommendations from specialist reports, the
recording of proposed impact management objectives, and the impact management outcomes for the
development for inclusion in the EMPr as well as for inclusion as conditions of authorisation.

i. Aspects for inclusion as conditions of Authorisation

Any aspects which must be made conditions of the Environmental Authorisation

Dust Control and Monitoring:

• Dust abatement by covering exposed areas and tracks or introducing
shade netting.
• Vehicles will stay on the approved or available tracks as far as practically
possible.
• Low speed limits will be set to avoid the creation of dust (20km/hr.).
• Any complaints or claims emanating from the dust pollution shall be
attended to immediately by the Mine Manager.

Noise Control and Management:

Xwena Copper will appoint an environmental Company to install Dust Collection
Probes as well as Noise measuring devices at strategic points around the permit
area 1 month prior to operation commencement. This will give us a good idea of
the current/background dust and noise pollution of the surrounding area. This will
give us a standard with which we can compare should mining commence keeping
in mind the local statutory threshold. Very little noise is anticipated due to mining
and dust will be suppressed by water during loading should the need arise.

ii. Description of any assumptions, uncertainties and gaps in knowledge

(Which relate to the assessment and mitigation measures proposed?)

The only inferred assumption is the occurrence of the copper ore across the entire
site based on limited test hole results.

iii. Reasoned opinion as to whether the proposed activity should or

should not be authorised
The proposed activity should be authorized.

46
iv. Reasons why the activity should be authorized or not

The activity does not pose any significant negative impacts. The minor impacts can
be mitigated and managed so to remove the impact through low technology means.
The Applicant will also give back to the community to better the livelihood and
create a type to sanctuary to commemorate the History of Springbok.

v. Conditions that must be included in the authorisation

The dust control management strategy must be implemented and monitored.

vi. Period for which the Environmental Authorisation is required

Authorization is required for the duration of the mining permit.

vii. Undertaking
Confirm that the undertaking required to meet the requirements of this section is provided at
the end of the EMPr and is applicable to both the Basic assessment report and the
Environmental Management Programme report.

The requirements of the section will be addressed in the EMPr in Part B.

47
S. Financial Provision
State the amount that is required to both manage and rehabilitate the environment in respect of
rehabilitation.

i. Explain how the aforesaid amount was derived.

The “Guideline Document for the Evaluation of the Quantum of Closure-Related
Financial Provision provided by a Mine”, the “Official guideline as contemplated in
Regulation 54(1) to the Mineral and Petroleum Resources Development Act, 2002 (Act
28 of 2002), Revision 1.6 (7th September 2004)” was used to guide the calculation of
the financial provision.

The proposed operation is classified as a Class C mine. Therefore, the minimum rate
for Class C mines are established as R20 000-00 per hectare as per the guideline
(Section 4.5) with a minimum amount of R10 000-00.

With a compound 6% escalation calculated from 2004 on the master rate as

recommended by DMR, the amount comes to R37965.97/Ha.

The financial provision is therefore calculated as:

Financial
Mine Area Sensitivity Rate / Ha
Provision
Xwena Copper Pty Ltd 4.9 Ha Low R38 000/Ha R186200-00

ii. Confirm that this amount can be provided for from operating expenditure.
(Confirm that the amount, is anticipated to be an operating cost and is provided for as
such in the Mining work programme, Financial and Technical Competence Report or
Prospecting Work Programme as the case may be ).

The Rehabilitation Fund will be provided as a Bank Guarantee by Xwena Copper Pty
Ltd

48
T. Specific Information required by the competent Authority:

Compliance with the provisions of sections 24(4)(a) and (b) read with
section 24 (3) (a) and (7) of the National Environmental Management Act
(Act 107 of 1998). the EIA report must include the: -

i. Impact on the socio-economic conditions of any directly affected

person. (Provide the results ofInvestigation, assessment, and evaluation of the impact of the
mining, bulk sampling or alluvial diamond prospecting on any directly affected person including the
landowner, lawful occupier, or, where applicable, potential beneficiaries of any land restitution claim,
attach the investigation report as an Appendix.

The landowner was involved from the onset of the application. As a successful
tourism business, they may also benefit after mining is completed as the Applicant
will transform the area and attract tourists. The landowner will be compensated for
the use of this land.

ii. Impact on any national estate referred to in section 3(2) of the National
Heritage Resources Act. (Provide the results ofInvestigation, assessment, and evaluation
of the impact of the mining, bulk sampling or alluvial diamond prospecting on any national estate
referred to in section 3(2) of the National Heritage Resources Act, 1999 (Act No. 25 of 1999) with the
exception of the national estate contemplated in section 3(2)(i)(vi) and (vii) of that Act, attach the
investigation report as Appendix 2.19.2 and confirm that the applicable mitigation is reflected in 2.5.3;
2.11.6.and 2.12.herein).

The landowner has been subject to tourism for more than 20 years. It is extremely
unlikely that any heritage artefacts will be present on the site. However, cognisance
is taken of the National Heritage Resources Act (1999) and an assessment of the
site will be done by a specialist.

iii. Other matters required in terms of sections 24(4)(a) and (b) of the Act.
(the EAP managing the application must provide the competent authority with detailed, written proof
of an investigation as required by section 24(4)(b)(i) of the Act and motivation if no reasonable or
feasible alternatives, as contemplated in sub-regulation 22(2)(h), exist. The EAP must attach such
motivation as Appendix 4).

The issue of alternatives for the proposed operation has been discussed under
Section O (iv) & (v) (page 29).

49
 4. PART B: ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

U. DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME.

i) Details of the EAP,

(Confirm that the requirement for the provision of the details and expertise of the EAP are already included in PART
A, section 1(a) herein as required).

The details and expertise of the EAP is presented in Part A, Section 1(a).

ii) Description of the Aspects of the Activity

(Confirm that the requirement to describe the aspects of the activity that are covered by the draft environmental
management programme is already included in PART A, section (1)(h) herein as required).

The aspects are presented in Part A, Section (1)(h).

iii) Composite Map

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

50
 Stable Face

Already
mined area

Mining Blocks

iv) Description of Impact management objectives including management

statements

(a) Determination of closure objectives

(ensure that the closure objectives are informed by the type of environment described)

The closure objectives for the proposed mine is to leave it as a functional piece of land
to be used by the land owner and community of Springbok.

Objective 1: To ensure the effective rehabilitation of the mining permit area.

▪ The site is to be landscaped for use as recreational area.
▪ Soil to be replaced across the entire area.

Objective 2: To minimize pollution or degradation of the environment.

▪ Provision of chemical toilets for workers.
▪ Ensure that no fuel or oil spills occur in the mining area.
▪ Ensure that no solid waste or rubble is dumped on the site.

Objective 3: To minimize the social impacts of the mine.

▪ Operate only normal working hours.
▪ Minimize dust and noise pollution.
▪ Ensure that mine workers stay within the mining area
▪ Pro-actively communicate with I&APs.
▪ To respond immediately to any complaints.

51
(b) Volumes and rate of water use required for the operation.

Dust management such as covering material that is transported off site, shade netting
that may help limit dust blown to the traffic and community areas will be implemented
as and when needed. Water for personal use and dust suppression will be supplied
from a 10 000 L Jo Jo tank which will be filled by water truck from the plant area (Okiep).

Two temporary (containerized) offices will be used to be mounted on concrete stands

and one ablution facility. The ablution facility will be contracted out to a chemical
company.

(c) Has a water use licence has been applied for?

A water use license has not been applied for by Xwena Copper Pty Ltd. There are no
water resources located close to the proposed mining area.

52
 v) Impacts to be mitigated in their respective phases

Measures to rehabilitate the environment affected by the undertaking of any listed activity
ACTIVITIES PHASE SIZE AND MITIGATION MEASURES COMPLIANCE WITH TIME PERIOD FOR
SCALE of STANDARDS IMPLEMENTATION
(E.g. For prospecting - drill site, disturbance
site camp, ablution facility, (of operation in (describe how each of the
(volumes, Describe the time period when the
accommodation, equipment which activity will recommendations in herein will remedy
tonnages and measures in the environmental
storage, sample storage, site take place. the cause of pollution or degradation (A description of how each of the
hectares or m²) management programme must be
office, access route and migration of pollutants) recommendations herein will comply implemented Measures must be
etc…etc…etc State; with any prescribed environmental implemented when required.
Planning and management standards or practices With regard to Rehabilitation
E.g. For mining,- excavations, design, that have been identified by specifically this must take place at the
blasting, stockpiles, discard Pre-Construction’ Competent Authorities) earliest opportunity. With regard to
dumps or dams, Loading, hauling Construction, Rehabilitation, therefore state either: -
and transport, Water supply Operational, Upon cessation of the individual
dams and boreholes, Rehabilitation, activity
accommodation, offices, Closure, Post or.
ablution, stores, workshops, closure). Upon the cessation of mining, bulk
processing plant, storm water
sampling or alluvial diamond
control, berms, roads, pipelines,
prospecting as the case may be.
power lines, conveyors,
etc…etc…etc.)
No natural vegetation Topsoil Management.
Construction 4.9 Ha Total Industry Best Practice Ongoing
clearing Dust Control.
Dust Control.
Mining Operational 4.9Ha Total Industry Best Practice Ongoing
Vehicle Maintenance.
Decommissioning & Dust Control. Ongoing until Closure
Operational 4.9Ha Total Industry Best Practice
Rehabilitation Vehicle Maintenance. Certificate is issued.

53
 vi) Impact Management Outcomes
(A description of impact management outcomes, identifying the standard of impact management required for the aspects contemplated in paragraph ();

ACTIVITY POTENTIAL ASPECTS PHASE MITIGATION STANDARD TO BE

(Whether listed or not listed). IMPACT AFFECTED In which impact is TYPE ACHIEVED
anticipated
(E.g. Excavations, blasting,
stockpiles, discard dumps or (E.g. dust, noise, (modify, remedy, control, or stop) (Impact avoided, noise levels,
(e.g. Construction,
dams, Loading, hauling and drainage surface through dust levels, rehabilitation
commissioning,
transport, Water supply dams disturbance, fly (e.g. noise control measures, storm- standards, end use objectives)
operational
and boreholes, rock, surface water water control, dust control, rehabilitation, etc.
Decommissioning,
accommodation, offices, contamination, design measures, blasting controls,
closure, post-
ablution, stores, workshops, groundwater avoidance, relocation, alternative activity
closure)
processing plant, storm water contamination, air etc. etc)
control, berms, roads, pollution etc….
pipelines, power lines, etc…) E.g.
conveyors, etc…etc…etc.). • Modify through alternative method.
• Control through noise control
• Control through management and
monitoring
• Remedy through rehabilitation.
• Clearing of Environmental Construction / Control through management Industry best standards:
vegetation Social (Land Operational and monitoring. Impact reduced to
from the owners / negligible level.
site. neighbours)
No natural vegetation
clearing • Potential For dust: adhere to Air
dust Quality Act.
pollution. For Noise: Adhere to
Noise Regulations (SANS
10103)
• Dust Environmental Operational Control through management Industry best standards:
pollution. Social (Land and monitoring. Impact reduced to
• Noise owners / negligible level.
Pollution. neighbours)
Mining • Visual For dust: adhere to Air
Impact. Quality Act.
For Noise: Adhere to
Noise Regulations (SANS
10103)
Decommissioning & • Dust Environmental Operational Control through management Industry best standards:
Rehabilitation pollution. and monitoring.

54
• Noise Social (Land Impact reduced to
pollution. owners / negligible level.
neighbours)
For dust: adhere to Air
Quality Act.
For Noise: Adhere to
Noise Regulations (SANS
10103)

55
 vii) Impact Management Actions
(A description of impact management actions, identifying the manner in which the impact management objectives and outcomes contemplated in paragraphs (c)
and (d)will be achieved).

ACTIVITY POTENTIAL IMPACT MITIGATION TIME PERIOD FOR COMPLIANCE WITH STANDARDS
whether listed or not TYPE IMPLEMENTATION
listed. (e.g. dust, noise, drainage
(E.g. Excavations, blasting, surface disturbance, fly rock, (modify, remedy, control, or stop)
surface water contamination, Describe the time period when the (A description of how each of the
stockpiles, discard dumps or through
groundwater contamination, measures in the environmental recommendations in 2.11.6 read with
dams, Loading, hauling and (e.g. noise control measures, storm-
air pollution etc….etc…) 2.12 and 2.15.2 herein will comply with
transport, Water supply dams water control, dust control, management programme must be any prescribed environmental
and boreholes, rehabilitation, design measures,
implemented Measures must be management standards or practices that
accommodation, offices, blasting controls, avoidance,
have been identified by Competent
ablution, stores, workshops, relocation, alternative activity etc. implemented when required. Authorities)
processing plant, storm water etc)
control, berms, roads, With regard to Rehabilitation
pipelines, power lines, E.g. specifically this must take place at the
conveyors, etc…etc…etc.). • Modify through alternative
method. earliest opportunity. With regard to
• Control through noise control Rehabilitation, therefore state either:
• Control through management
and monitoring -
Remedy through rehabilitation. Upon cessation of the individual
activity
or.
Upon the cessation of mining,
bulk sampling or alluvial diamond
prospecting as the case may be.
• Clearing of Control through Throughout the life of the Industry best standards:
vegetation from management and mine with immediate
No natural vegetation the site. monitoring. implementation. For dust: adhere to Air
clearing • Potential dust Remedy thorough Quality Act.
pollution from Rehabilitation. For Noise: Adhere to Noise
denuded areas. Regulations (SANS 10103)
• Dust pollution due Control through Throughout the life of the Industry best standards:
to vehicular management and mine with immediate
Mining movement monitoring. implementation For dust: adhere to Air
Remedy thorough Quality Act.
Rehabilitation.
56
 • Noise Pollution For Noise: Adhere to Noise
from vehicles. Regulations (SANS 10103)
• Visual Impact
mining operation.
• Dust pollution Control through Throughout the life of the Industry best standards:
from vehicles. management and mine with immediate
Decommissioning & • Noise pollution monitoring. implementation For dust: adhere to Air
Rehabilitation from vehicles. Remedy thorough Quality Act.
Rehabilitation. For Noise: Adhere to Noise
Regulations (SANS 10103)

57
 V. Financial Provision

Determination of the amount of Financial Provision

i. Describe the closure objectives and the extent to which they have been aligned
to the baseline environment described under the Regulation.

The closure objectives for the proposed mine is to leave it as a functional piece of land to be
used by the land owner for intensive crop production as requested by him.

Objective 1: To ensure the effective rehabilitation of the mining permit area.

▪ The site is to be landscaped for use as crop production area.
▪ Topsoil to be replaced across the entire area.

Objective 2: To minimize pollution or degradation of the environment.

▪ Provision of chemical toilets for workers.
▪ Ensure that no fuel or oil spills occur in the mining area.
▪ Ensure that no solid waste or rubble is dumped on the site.

Objective 3: To minimize the social impacts of the mine.

▪ Operate only normal working hours.
▪ Minimize dust and noise pollution.
▪ Ensure that mine workers stay within the mining area.
▪ Pro-actively communicate with I&APs.
▪ To respond immediately to any complaints.

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

The landowner was consulted.

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

58
 Stable Face

Already mined
area

Mining Blocks

The site will be mined in sequence from Blocks as shown in the second image. As
mining progresses the rehabilitation of the mined-out area will follow concurrently. The
sequence will repeat with the other blocks.

59
 Soil Management

Topsoil Management
The process followed for topsoil stripping:
There is no topsoil to remove from the mined area. The Applicant will use different method to
rehabilitate the area and request the recommendations/assistance from the Department of
Mineral Resources in this regard.

All areas to be impacted by mining or related activities will be cleared.

Mulching

There is no natural vegetation, excluding the vegetation targeted for removal, will be
removed and act as mulch. The removal of vegetation (small trees / alien and invasive
plants) will take place prior to removal of material.

Seeding and seed mixtures

Any type of soil that was removed contains the organic nutrients and seed required to
facilitate plant growth and no artificial fertilizer will be added.

Soil Erosion Management

• Cut-off drains will be in dug on the borders of the mine site to prevent water from
entering the site.
• The cut-off trenches will linkup with natural drainage features.
• All cut-off trenches will be equipped with flow arrestors.

General Rehabilitation

Implement the site clearance strategy. Implement the Monitoring and Reporting Protocols as
per the Rehabilitation Plan.

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

The rehabilitation plan was written to give execution to obtain the closure objectives. The
closure objectives therefore inform and guide the plan to achieve the set goals. The two are
interlinked and cannot operate separately from each other.

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

The “Guideline Document for the Evaluation of the Quantum of Closure-Related Financial
Provision provided by a Mine”, the “Official guideline as contemplated in Regulation 54(1) to
the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002), Revision 1.6
(7th September 2004)” was used to guide the calculation of the financial provision.

The proposed operation is classified as a Class C mine. Therefore, the minimum rate for Class
C mines are established as R20 000-00 per hectare as per the guideline (Section 4.5) with a
minimum amount of R10 000-00 with a compound 6% escalation calculated from 2004 on the
master rate as recommended by DMR, the amount comes to R37 965.97/Ha.

60
 The financial provision is therefore calculated as:

Financial
Mine Area Sensitivity Rate / Ha
Provision
Xwena Copper Pty Ltd 4.9 Ha Low R38 000/Ha R186200-00

vi. Confirm that the financial provision will be provided as determined.

The financial provision will be provided as a bank guarantee by Xwena Copper Pty Ltd.

61
 W. Mechanisms for monitoring compliance with and performance assessment against the environmental management
programme and reporting thereon, including
Monitoring of Impact Management Actions
Monitoring and reporting frequency
Responsible persons
Time period for implementing impact management actions
Mechanism for monitoring compliance

SOURCE ACTIVITY IMPACTS REQUIRING FUNCTIONAL REQUIREMENTS FOR ROLES AND RESPONSIBILITIES MONITORING AND REPORTING
MONITORING MONITORING (FOR THE EXECUTION OF THE MONITORING FREQUENCY and TIME PERIODS
PROGRAMMES)
PROGRAMMES FOR IMPLEMENTING IMPACT
MANAGEMENT ACTIONS

1) Removal and 1) Monitor that all the topsoil is 1) Ongoing

stockpile of removed and stockpiled 2) Monthly
topsoil. correctly. 3) Ongoing during
2) Erosion of topsoil 2) Monitor erosion of the topsoil rehabilitation.
Soil stockpile. stockpile. Mine Manager
3) Replacement of 3) Test the depth of topsoil
topsoil on replacement to ensure
rehabilitated uniform coverage.
sections.
1) Water 1) Monitor water accumulation 1) After rain events.
accumulation on points on the mine site. 2) Quarterly.
the mine site 2) Monitor erosion on the mine 3) After rain events.
may cause site.
erosion through 3) Monitor run-off during rain
overflow. events.
Water
2) Erosion of the
Mine Manager
mining area and
rehabilitation
sections.
3) Run-off water
with high silt
content indicates
erosion.

62
 1) Excessive dust 1) All equipment operators must
pollution. do daily visual inspections to
2) Dust effect on check for dust pollution.
land owner and 2) Severe dust conditions must
Air neighbours. immediately be reported to All employees / Mine Manager Continual.
the Mine Manager for action.
3) Severe dust episodes must be
reported in the Incident
Reporting Book.
1) Check for re- 1) Monitor for good nurse crop
vegetation plant densities to combat wind
success on erosion.
rehabilitated 2) Monitor the occurrence of
Vegetation areas. alien and invasive species for Mine Manager Quarterly.
2) Alien and action.
invasive species
must be
eradicated.
1) Noise levels on 1) Monitor noise on the site,
site. specifically with regard to
2) Noise effect on wind direction.
Noise
land owner and 2) Consult regularly with the land Mine Manager Continually
neighbours. owner and neighbours.
3) All noise complaints must
reported in the Incident
Reporting Book.
1) Occurrence of Monitor on weekly basis for the
litter and rubble. occurrence of litter, rubble or oil
Pollution spills. Mine Manager Continually
2) Occurrence of oil
spills.

63
i) The frequency of the submission of the performance
assessment/environmental audit report

The Performance Assessment Report must be submitted annually to the DMR.

64
X. Environmental Awareness Plan

i) Manner in which the applicant intends to inform his or her employees of any
environmental risk which may result from their work

Induction training will be held for all employees before commencing work on the site.
Weekly “toolbox talks” will be held by the mine manager. The following subjects will be
covered:

• The environmental management goals on the mine site.

• Rehabilitation goals.
• The environmental monitoring protocols.
• Waste management on site.
• Dealing with spills and soil contamination.
• Dealing with environmental risks pertinent to the site.

ii) Manner in which risks will be dealt with in order to avoid pollution or the
degradation of the environment

All relevant mitigation and management measures pertaining to environmental risks should
be discussed during induction training. Compliance to these procedures by all personnel
must be monitored by the mine manager.

65
Y. Specific information required by the Competent Authority
(Among others, confirm that the financial provision will be reviewed annually).

No specific information was requested by the authorities.

66
 5. UNDERTAKING

The EAP herewith confirms

• the correctness of the information provided in the reports √

• the inclusion of comments and inputs from stakeholders and I&APs ;√

• the inclusion of inputs and recommendations from the specialist reports where
relevant; √ and

• that the information provided by the EAP to interested and affected parties and
any responses by the EAP to comments or inputs made by interested and
affected parties are correctly reflected herein.√

Signature of the environmental assessment practitioner:

Grasaro (Pty) Ltd.

Name of company:

06 May 2019
Date:

-END-

67
Physical and chemical components

The following components are evaluated: Geology

Air Quality – Dust
Air Quality – Emissions
Groundwater
Visual Aspects
Surface Water
Topography

Impact on the physical and chemical components

Impact
Spatial Scale of Impact Severity / Duration of Mitigation Acceptability Certainty of
Magnitude &
impact Intensity impact potential of impacts impacts
Significance

Geology Low Low Low Medium High Low Definite

Air Quality -
Low Medium Low Medium High Medium Possible
Dust
Air Quality -
Low Low Low Medium High Low Probable
Emissions
Groundwater Low Medium Low Medium High Low Probable
Visual Aspects Low Medium Low Medium Medium Low Probable
Surface Water Low Low Low Medium High Low Probable
Topography Low Low Low Medium High Low Definite

68
Sociological and cultural components

The following components are evaluated: Interested and Affected Parties

Archaeological Artefacts
Noise

Impact on sociological and cultural components

Impact
Spatial Scale of Impact Severity / Duration of Mitigation Acceptability of Certainty of
Magnitude &
impact Intensity impact potential impacts impacts
Significance
Interested and
Low Medium Low Medium High Low Probable
Affected Parties

Archaeological
Low Low Low High High Medium Possible
Artefacts

Noise Low Medium Low Low High Low Probable

Economical and operational components

The following components are evaluated: Regional Socio-Economic Structure

Impact on economical and operational components
Impact Magnitude Spatial Scale Impact Severity / Duration of Mitigation Acceptability Certainty of
& Significance of impact Intensity impact potential of impacts impacts
Regional Socio-
Economic Low (Positive) Low Low Medium High High Definite
Structure

69
70