IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND...

23
From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC, 10025MRC, 512MRC AND 513MRC Date: 16 August 2017 11:28:06 AM Attachments: image003.png image004.png image007.png image008.png image009.png Provincial Contacts for EIA- related enquiries_June 2017.docx CONTACTS FOR DMR REGIONAL OFFICES_2016.docx Dear Mandy Kindly remove the address for the Interpretation Queries Helpdesk from your circulation list, as this address is exclusively used for dealing with queries on the interpretation of the National Environmental Management Act and the EIA Regulations. Should you have to inform competent authority of any process, kindly do so directly to them. Attached, please find the contact details of the DMR and the 9 provincial departments responsible for environmental affairs. Should the competent authority be the national Department of Environmental Affairs, kindly use [email protected] to reach the Chief Directorate: Integrated Environmental Authorisations. Kind regards Chantal Engelbrecht From: Mandy Kula [mailto:[email protected]] Sent: Wednesday, August 16, 2017 10:55 AM To: Mandy Kula Subject: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC, 10025MRC, 512MRC AND 513MRC Dear Sir / Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPR amendment and public participation process. The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marine Mining Rights, and SLR Environmental (South Africa), in association with Placer Resource Management, has been appointed to undertake the EMPR amendment and public participation process. Notice is hereby given that the attached Background Information Document (BID) is available for a 30-day review and comment period from 16 August to 15 September 2017. Should you have any queries in this regard please do not hesitate to contact Jeremy Blood or myself.

Transcript of IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND...

Page 1: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From IQTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 112806 AMAttachments image003png

image004pngimage007pngimage008pngimage009pngProvincial Contacts for EIA- related enquiries_June 2017docxCONTACTS FOR DMR REGIONAL OFFICES_2016docx

Dear Mandy Kindly remove the address for the Interpretation Queries Helpdesk from your circulation list asthis address is exclusively used for dealing with queries on the interpretation of the NationalEnvironmental Management Act and the EIA Regulations Should you have to inform competent authority of any process kindly do so directly to them Attached please find the contact details of the DMR and the 9 provincial departmentsresponsible for environmental affairs Should the competent authority be the nationalDepartment of Environmental Affairs kindly use EIAadminenvironmentgovza to reach theChief Directorate Integrated Environmental Authorisations Kind regardsChantal Engelbrecht

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

PROVINCIAL COMPETENT AUTHORITIES CONTACT PERSONS (NEMA and EIA Regulations)

COMPETENT AUTHORITY

image1png

DMR REGIONAL OFFICE CONTACTS

REGIONAL OFFICES

From Johannes NematataniTo Mandy Kula Natasha SmythCc Kgaudi Shapo Vincent MuilaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 112554 AMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimageae71f0PNGimageffee86PNGimageeb495ePNGimage6a47b5PNGimage8a11c2PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Good day Please note that the project manager for all amendments (previously known as section 102) isMr Kgaudi Shapo You can contact Mr Shapo on email KgaudiShapodmrcoza Telephone053 807 1778 and cellphone 083 270 4734 You may also need to copy the head of the section Mine Environmental Management MrVincent Muila Who is contactable by email Vincentmuiladmrgovza Telephone 053 8071716 and by cellphone on 072 635 5079 Please kindly liaise with the above mentioned officials regarding this email

Johannes NematataniMineral RegulationTel 053 807 1773Email JohannesNematatanidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

REGION

REGIONAL MANAGER amp PA

TELEPHONE NUMBER

POSTAL ADDRESS

Physical address

NORTHERN REGIONS

Limpopo

Mr Aaron Kharivhe

(Regional Manager)

PA Tebogo Mangaba

Mr Thivhulawi Kolani

Deputy Director Environment

Tel 015 287 4703

Fax 015 287 4706

Private Bag x 9467

Polokwane

0700

101 Dorp Street Polokwane

0700

Mpumalanga

Mr Aubrey Tshivhandekano

Regional Manager

PA Lydia Maphopha

Matshilele Ramovha

Acting Deputy Director Environment

Tel 013 653 0500

Fax 013 653

Private Bag x7279

Witbank

1035

Receiver of Revenue Building

Cn Paul Kruger amp Botha

Emalahleni 1035

WESTERN REGIONS

Gauteng

Mr Dimakatso Ledwaba

Acting Regional Manager

PA Carol Khanyile

Rudzani Mabogo

Acting Deputy Director

011 358 9700

Fax 011 339 2423

Private Bag x5

Braamfontein

2017

79 Mineralia Building Cnr De korte and De beer Str Braamfontein

North West

Mr Peter Swart

Regional Manager

PA Ipeleng Wesi

Phumudzo Nethwadzi

Deputy Director Environment

Tel 018 487 9830 Ext 9834

Fax 086 710 1228 018487 9831

Private Bag A 1

Klerksdorp

2571

Vaal University of Technology cnr Voortrekker amp Magaretha Prinsloo Str Klerksdorp 2570

CENTRAL REGIONS

Free State

Mr Ndlelenhle Zindela

Regional Manager

PA Tshepo Makgoba

Meshack Mudau

Deputy Director Environment

Tel 057 391 1300

Fax 057 357 6003

Private Bag x 33

Welkom

9460

The Strip 314

Stateway amp Bok Str

Welkom

Northern Cape

Springbok Satellite office

Mr Sunday Mabaso

Regional Manager

PA Brenda Monnapula

Ntsundeni Ravhugoni

Deputy Director Environment

Jasper Niewoudt

PA Ms Chrizelle Farmerf

Tel 053 807 1700

Fax 053 832 5631

Tel 027 712 8160

Fax027 712 1959

Private Bag x 6093

Kimberley

8300

Cnr Reibeck Str 1st Floor

Van Der Stel Str Springbok

Liberty Corner

Building 29 ndash 31 Currey Str Kimberly

COASTAL REGIONS

Western Cape

Ms Sibongile Kunene

Regional Manager

PA Busisiwe Magazi

Jan Briers

Deputy Director Environment

JanBriersdmrgovza

021 427 1000

Fax 021 427 10501046

Private Bag x 9

Roggebaai

8012

Eastern Cape

Mr Azwihangwisi Mulaudzi

Regional Manager

Azwihangwisimulaudzi

PA Zimkita Tyala

Deidre Thompson (nee Watkins)

Deputy Director Environment

DeidreWatkinsdmrgovza

041 396 3900

Fax 086 503 6992

Crispin Hall 690

Cnr Mount and Diaz Road

Port Elizabeth

KZN

Nqobile Njoko

Regional Manager

PA Nandipha Qwalela

Karoon Moodley

Deputy Director Environment

Tel 031 355 9600

Fax 031 301 56950

Durban Bay House

333 Smith Street

Durban

North-West

Department of Rural Environment and Agricultural (READ)

Portia Krisjan

018 389 5929

Ellis Thebe

018 389 5099

Motshabi Mohlalisi

014 597 35978

Robert Nemanashi

018 299 6696

CONTACT PERSON

Telephone Mobile number

E-mail address

Eastern Cape

Department of Economic Development and Environmental Affairs (DEDEA)

Cecilia Gyan

043 605 7099 or 071 875 0022

Free State

Department of Economic Development Tourism and Environmental Affairs (DETEA)

Grace Mkhosana

0711482434 or 051 400 4817

Gauteng

Department of Agriculture and Rural Development (GDARD)

Boniswa Belot

011 355 1212

Limpopo Department Economic Development Environment and Tourism (LEDET)

Enquiries Vusi Maluleke

015 290 7167 015 290 7138

082 947 7755

Victor Mongwe

015 290 7090 015 290 7091

Tlhagala Ngoasheng

015 290 7058 082 041 3223

Rhulani Mthombeni

015 290 7057 071 558 1187

Mpumalanga

Department of Agriculture Rural Development Land amp Environmental Affairs (DARDLEA)

Provincial Head Office

Selby Hlatshwayo

013 759 4000 or 072 281 1751

Ehlanzeni District

Robyn Luyt

013 759 4000 or 082 672 7868

Gert Sibande District

Surgeon Marebane

079 841 9582

Nkangala District

Dineo Tswai

076 644 1707

Northern Cape

Department of Environment and Nature Conservation (DENC)

B Fischer

053 807 7470

Dineo Moleko

053 807 7467

North-West

Department of Rural Environment and Agricultural (READ)

Portia Krisjan

018 389 5929

Ellis Thebe

018 389 5099

Motshabi Mohlalisi

014 597 35978

Robert Nemanashi

018 299 6696

Western Cape

Department of Environmental Affairs and Development Planning (DEADP)

Director Planning and Policy Coordination

Paul Hardcastle

021 483 5687

Director Development Management Region 1

Zaahir Toefy

021 4832700

Central Karoo amp Eden District

Danie Swanepoel

044 805 8602

Cape Winelands and Overberg District

Mare-Liez Oosthuizen

021 483 5756

West Coast District and City of Cape Town

Eldon van Boom

021 483 2877

West Coast District and City of Cape Town

Alvan Gabriel

021 483 2742

KWAZULU NATAL

Department of Economic Development Tourism and and Environmental Affairs (EDTEA)

Discipline Leader Impact Management

Dr Peter Kuyler

034 - 299 9664 or 079 897 1969

peterkuylerkzndardgovza

SOUTH REGION Regional Office Hilton Pietermaritzburg

Senior Manager South

Mr Sibusiso Mthembu

033 - 343 8330

eThekwini (Durban)(

Yugeshni Govender

Natasha Brijlal

031 382 9368 or 082 921 9340

031 328 9328 or 079 898 0491

Ugu (Port Shepstone)

Melissa Packree

039 682 2045 or 0829219406

Pietermaritzburg (uMgungundlovu)

Reka Kallicharan

033 347 1820 or 082 922 0859

rekakallicharankznedteagovza

Ladysmith (PUthukela)

Dumisane Gwede

036 634 6300 or 0829218924

Stanger (iLembe)

Malcolm Moses

032 437 7527 or082 461 8303

kznedteagovza

Ixopo (Harry Gwala)

Ndumiso Masuku

039 - 834 7600

NORTH REGION Regional Office Richards Bay

Acting General Manager Environmental Management

Dr William Mngoma

035 780 6706 or 082 461 8013

Dundee (Umzinyathi)

Gerald Willis-Smith

034 299 9671 or 082 461 8674

GeraldWillisSmithkznedteagovza

Newcastle (Amajuba)

Poovi Moodley

034 315 3936 or 082 719 9907

pooveymoodleykznedteagovza

Ulundi (Zululand)

Sibusiso Ndwandwe

035 874 3296 or082 719 9883

Ndwandwsbkznedteagovza

Mtubatuba (Umkhanyakude)

Dayalin Naidoo

035 550 0210 or 079 496 8002

Richards Bay (Uthungulu)

Muziwandile Mdamba

035 780 6844 or 082 822 2582

Page 2: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Johannes NematataniTo Mandy Kula Natasha SmythCc Kgaudi Shapo Vincent MuilaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 112554 AMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimageae71f0PNGimageffee86PNGimageeb495ePNGimage6a47b5PNGimage8a11c2PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Good day Please note that the project manager for all amendments (previously known as section 102) isMr Kgaudi Shapo You can contact Mr Shapo on email KgaudiShapodmrcoza Telephone053 807 1778 and cellphone 083 270 4734 You may also need to copy the head of the section Mine Environmental Management MrVincent Muila Who is contactable by email Vincentmuiladmrgovza Telephone 053 8071716 and by cellphone on 072 635 5079 Please kindly liaise with the above mentioned officials regarding this email

Johannes NematataniMineral RegulationTel 053 807 1773Email JohannesNematatanidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 3: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 4: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

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PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 5: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 6: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 7: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 8: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 9: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 10: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 11: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 12: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 13: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 14: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Takalani KhorombiTo Linda NjemlaCc Mandy KulaSubject FW ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 16 August 2017 120122 PMAttachments image417cdbPNG

imaged782bePNGimageda795bPNGimaged13518PNGimagea9cd61PNGimagecf2dd3PNGimage543f2aPNGimaged1670fPNGimage187175PNGimage3fbef8PNGAlexkor Let IampAPs - BID Rev 1 (Aug 2017) - EnglishpdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - AfrikaanspdfAlexkor_BID_FINAL_14Aug17pdf

Dear Linda Kindly receive the attached documents for your attention RegardsTakalani

Takalani KhorombiMineral RegulationsTel 053 807 1748Email TakalaniKhorombidmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer Resource

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 15: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

Project Reference 720010870001 File Ref Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRC

This letter provides formal notification of an EMPR amendment and public participation process in terms of

bull Section 37 of the Environmental Impact Assessment (EIA) Regulations 2014 as amended promulgated in

terms of Sections 24(5) and 44 of the National Environmental Management Act 1998 (No 107 of 1998)

(NEMA) as amended and

bull Section 102 of the Mineral and Petroleum Resources Development Act 2002 (No 28 of 2002) (MPRDA)

as amended

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as ldquoPSJVrdquo) holds an onshore and various marine

Mining Rights on and off the West Coast of South Africa These Mining Rights are roughly located between the

Orange River in the north and Kleinzee (a point some 5 km north of the town) in the south Mining activities are

currently undertaken in terms of three approved EMPRs as amended The PSJV is in the process of amending

its EMPRs for the marine Mining Rights in order to comply with the current requirements of NEMA and the EIA

Regulations 2014 and to ensure alignment with each other all new legislation environmental standards as well

as internal PSJV Performance Assessment Reports The EMPR for the onshore Mining Right 550MRC which

was approved in April 2017 is not being amended as part of this process

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association with Placer Resource Management

(Pty) Ltd (ldquoPRMrdquo) has been appointed by the PSJV to undertake the EMPR amendment and public participation

process

Notice is hereby given that a Background Information Document (BID) is available for a 30-day review and

comment period from 16 August to 15 September 2017 A copy of the BID is attached for your information

If you or your organisation would like to register as an interested and affected party (IampAP) andor wish to raise

any initial issues or concerns regarding the proposed project please make use of the attached Registration and

Response Form and forward it to our Ms Mandy Kula (E-mail mkulaslrconsultingcom) by no later than

15 September 2017

Should you have any queries in this regard please do not hesitate to contact Ms Kula or the undersigned

Yours sincerely

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl

PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 16: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

Verwysings nommer 720010870001 Verwysing Alexkor Let IampAPs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

ALEXKOR RMC POOLING AND SHARING JV ndash WYSIGING VAN OMGEWINGSBESTUURSPROGRAM (OBP)

VIR MYNREGTE 554MRC 10025MRC 512MRC EN 513MRC

Hierdie skrywe dien as die formele kennisgewing van wysiging van die OBP en die publieke deelnameproses in

terme van

bull Seksie 37 van die Omgewings Impak Assessering (EIA) Regulasies 2014 soos gewysig promulgeer in

terme van Seksie 24(5) en 44 van die Nasionale Ongewingsbestuurswet 1998 (No 107 van 1998)

(NEMA) soos gewysig en

bull Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling 2002 (No 28 van 2002)

(MPRDA) soos gewysig

Die ldquoAlexkor RMC Pooling and Sharing JVrdquo (verder ldquoPSJVrdquo) is die houer van verskeie aanlandige en mariene

Mynregte langs die Weskus van Suid-Afrika Hierdie Mynregte is geleeuml tussen die mond van die Oranjerivier in die

noorde en lsquon baken ongeveer 5 kilometer noord van die dorp Kleinzee in die suide Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBPrsquos Die PSJV is tans besig met die wysiging van die OBPrsquos van die verskeie

mariene Mynregte om te voldoen aan die huidige vereistes van NEMA en die EIA Regulasies 2014 Ook om

sodoende te verseker dat almal ooreenstem ten opsigte van alle nuwe regulasies omgewingsbestuurstandaarde

asook interne PSJV Prestasie Assesseringsverslae Die OBP vir die aanlandige Mynregte 550MRC soos

goedgekeur in April 2017 word nie hersien en of gewysig as deel van die huidige prosesnie

SLR Environmental Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in samewerking met Placer Resource

Management (Pty) Ltd (ldquoPRMrdquo) is aangestel deur die PSJV om die OBPrsquos te hersien en te wysig asook om die

publieke deelnameproses te behartig

Hierdie skrywe dien as kennisgewing dat lsquon Agtergrondinligtingsdokument vrygestel en beskibaar is vir oorsig en

kommentaar vir lsquon periode van 30 dae vanaf 16 Augustus tot 15 September 2017 lsquon Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting

Indien u of u maatskappy wil registreer as n belanghebbende en geaffekteerde party (BGP) en of u enige vertoeuml

wil rig aangaande die voorgestelde proses en of projek voltooi asseblief die aangehegte vorm ldquoRegistration and

Response Formrdquo en stuur dit aan Me Mandy Kula (E-pos mkulaslrconsultingcom) teen nie later as

15 September 2017

Indien U enige verdere vrae het skakel gerus vir Me Kula of die ondergetekende

Vriendelike groete

Jeremy Blood PrSciNat CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl PJobsAle01empCorresp OutpublicBIDAlexkor Let IampAPs - BID Rev 1 (Aug 2017)docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 17: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

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PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 18: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 19: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 20: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 21: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 22: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 23: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 24: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 25: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 26: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Linda NjemlaTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 17 August 2017 114027 AMAttachments image002png

image003pngimage005pngimage006pngimage007pngimage4d3acfPNGimage086e82PNGimaged3a2b9PNGimaged14132PNGimage8bc14ePNG

Noted

Linda NjemlaMineral RegulationTel 027 712 8177Email LindaNjemladmrgovzaWebsite

From Mandy Kula [mailtomkulaslrconsultingcom] Sent 16 August 2017 1055 AMTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND513MRC Dear Sir Madam This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participationprocess Notice is hereby given that the attached Background Information Document (BID) is available fora 30-day review and comment period from 16 August to 15 September 2017 Should you have any queries in this regard please do not hesitate to contact Jeremy Blood ormyself

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 27: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Cloete JulienTo Mandy KulaCc Witbooi UrsulaSubject Registration as IampAP for Alexkor EMP amendmentDate 17 August 2017 111613 AMAttachments 20170817123041388pdf

Good morningPlease find attached the registration form for Namdeb Thanks Julien MB CloeteEnvironmental Management Coordinator ndash Rehabilitation Namdeb Diamond CorporationMineral Resource DepartmentEnvironmental SectionOranjemundNAMIBIA Tel +264 63 239665Fax +264 63 239603 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 28: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Gregor CalderwoodTo Mandy KulaSubject Notice of EMPR Amendment and PPP - AlexkorDate 21 August 2017 025024 PM

Dear Mandy Kula

I am currently registered for my BSc Honours degree in environmentalmanagement and one of our modules requires us to register as an interested andaffected party in an upcoming public participation process

I would be very grateful if you could register me as an interested and affectedparty for the upcoming process for the Amendments to the EMPR for Alexcor Myinvolvement would purely be for academic purposes

Should you have any questions please do not hesitate to contact me

Kind Regards

Gregor Calderwood+27 (0)78 337 6991

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 29: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Briege WilliamsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs)

FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 22 August 2017 100233 AM

Dear Mandy

SAHRA would like to register as an IampAP for the above project For us to be able to comment on theamended EMPRs you need to create a case on SAHRIS and upload all the relevant documents when theybecome available Both the inshore and off shore work is quite invasive so it is important to look at theimpacts it may have on any maritime and underwater cultural heritage

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed herehttpmailsahraorgzadisclaimerhtml

Break The Corruption Chain

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 30: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Briege WilliamsTo Jeremy BloodCc Mandy KulaSubject Re ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES

(EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 074418 AMAttachments image527d3cPNG

image44480cPNGimageb976b1PNGimaged34e2ePNGimage8b3f68PNGimage21baafPNGimage001pngimage002png

Dear Mandy and Jeremy

Thanks for your emails sorry I havent replied sooner we had problems at our end receiving incomingmessages and as such I have only received them now

Jeremy is correct in that it is the EMPRs that we will need to comment on and they will therefore need to beuploaded onto SAHRIS when they are complete the BID does not need to be uploaded

I hope this clears things up

Regards

Briege

Briege WilliamsHeritage Officer Maritime and Underwater Cultural Heritage Unit

South African Heritage Resources Agency- A nation united through heritage -

T 021 202 8688| C| F021 462 4509E bwilliamssahraorgza | 111 Harrington Street | Cape Town | 8001

wwwsahraorgzaSAHRA Logo

SAHRA Values

From Jeremy Blood ltjbloodslrconsultingcomgtTo Mandy Kula ltmkulaslrconsultingcomgt Briege WilliamsltbwilliamssahraorgzagtSent Tuesday 22 August 2017 111101 AMSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512MRC AND 513MRC

Mandy

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 31: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From craig matthewsTo Mandy KulaSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 011215 PMAttachments RMC Letter Head 2017doc

Dear Ms Kula

I refer to the Notice dated 16 August 2017 which was issued by SLR regardingthe subject matter

The Richtersveld Mining Company (Pty) Ltd (RMC) as represented by myself hasno record of receiving the Notice despite being an affected party with materialinterests in the Pooling and Sharing JV and the matter

It may have been an oversight on your part and I request that you direct aformal Notice to me so that the RMC can formally respond

I enclose a blank letter head from which you can extract the address and contactdetails for the RMC

You may contact me at 079 5216315 or matthewscraig1969gmailcom

I look forward to your response

RegardsCraig MatthewsDirector Richtersveld Mining Company (Pty) Ltd

Richtersveld Mining Company

PO Box 64 Alexander Bay 8290

Richtersveld Mining Company

Frikkie Snyman 7th Avenue Alexander Bay 8290

David Austen ndash Vice Chairperson

Craig Matthews

image1jpg

Page 32: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Grant SmithTo Mandy KulaSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 24 August 2017 110048 AMAttachments image005png

image006pngimage009pngimage010pngimage011pngimage001pngAlexkor_EWT_Registrationpdf

Dear Mandy

Our registration as an IAP is attached

Kind regards

Grant SmithEstuary Projects CoordinatorSource to Sea Programme

Endangered Wildlife TrustW + 27 21 799 8458 | C + 27 84 3281001Email grantsewtorgza | Web wwwewtorgza | Skype itisgrantORM Project Overview httpewtorgzaSOURCETSEAOrange20Senqu20River20Basinhtml

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRCAND 513MRC

Dear Sir Madam

This email and attached letters (in English and Afrikaans) provide formal notification of an EMPRamendment and public participation process

The Alexkor RMC Pooling and Sharing JV is in the process of amending its EMPRs for its marineMining Rights and SLR Environmental (South Africa) in association with Placer ResourceManagement has been appointed to undertake the EMPR amendment and public participation

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 33: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1 BACKGROUND

In 2011 Alexkor SOC Limited (Alexkor) and the Richtersveld

Mining Company (Pty) Ltd (RMC) formed a Pooling and Sharing

Joint Venture (hereafter referred to as ldquoPSJVrdquo) as per the 2007

Deed of Settlement in order to oversee all current and future

mining activities Alexkor and RMC hold 51 and 49 interest

in the joint venture respectively

The PSJV holds an onshore and various marine Mining Rights

on and off the West Coast of South Africa These Mining Rights

are roughly located between the Orange River in the north and

Kleinzee (a point some 5 km north of the town) in the south

(see Figure 1) The mining methods currently employed in

these areas include

bull Conventional open cast terrestrial mining

bull Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as ldquowalpomprdquo)

bull Boat-based diver assisted mining

bull Coffer dam mining and

bull Large vessel mining using airlift or bottom deployed

remotely operated mining systems

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs)

as amended

The PSJV is in the process of amending its EMPRs for the

marine Mining Rights (see Box 1) in order to comply with the

current requirements of the National Environmental

Management Act 1998 (No 108 of 1998) (NEMA) and the

Environmental Impact Assessment (EIA) Regulations 2014 as

amended and to ensure alignment with each other all new

legislation environmental standards as well as internal PSJV

Performance Assessment Reports The EMPR for the onshore

Mining Right 550MRC which was approved in April 2017 is not

being amended as part of this process

SLR Consulting (South Africa) (Pty) Ltd (ldquoSLRrdquo) in association

with Placer Resource Management (Pty) Ltd (ldquoPRMrdquo) has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC 10025MRC 512MRC and 513MRC

and undertake the associated public participation process

2 PURPOSE OF THIS DOCUMENT

This document provides information on

bull PSJVrsquos intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds

bull the current Mining Works Programme

bull the EMPR amendment and public participation process

and

bull how you can register as an interested and affected party

(IampAP) and submit initial comments

3 KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below

31 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT 2002

Section 102 of the Mineral and Petroleum Resources

Development Act 2002 (No 28 of 2002) (MPRDA) as

amended requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority)

Box 1 Alexkor RMC JVrsquos Marine Mining Rights

bull Mining Right 554MRC comprising

gt Centre line of the Orange River to the bank of along

the following properties Corridor-Wes (Farm No 2)

Portion 17 (a portion of Portion 8) Portion 16

(a portion of Portion 9) Portion 15 (a portion of

Portion 10) Arrisdrift (Farm No 616) Farm No 1 and

Farm Brandkaros (Farm No 517)

gt Surf zone along Farm No 1 and Farm No 155

gt Sea Concession 1a

gt Sea Concession 1b

gt Sea Concession 2a and

gt Sea Concession 3a

bull Mining Right 10025MR comprising Sea Concession 1c

bull Mining Right 512MRC comprising Sea Concession 4a

and

bull Mining Right 513MRC comprising Sea Concession 4b

REGISTER AS AN INTERESTED AND AFFECTED PARTY

Please complete the enclosed registration comment form or contact SLR to register as an IampAP

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 34: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

2

Figure 1 Location map of PSJVrsquos exiting Mining Rights on and off the West Coast of South Africa

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

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The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 35: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

3

Although DMR no longer has the statutory power in terms

of the MPRDA to approve an amendment to an EMPR

prepared in terms of the MPRDA (due to the repeal of

Section 39(6) of the MPRDA) it does have the authority to

approve an amendment to an EMPR prepared in terms of

NEMA

The effect of Section 12(4) of the National Environmental

Management Amendment Act 2008 (No 62 of 2008) is

that an EMPR prepared in terms of the MPRDA enforced

as at 8 December 2014 is deemed to be an EMPR

approved in terms of Section 24N of NEMA Therefore

any amendment of an EMPR (prepared in terms of either

NEMA or the MPRDA) after 8 December 2014 should take

place in accordance with NEMA and the EIA Regulations

2014 (see Section 32 below)

32 NATIONAL ENVIRONMENTAL MANAGEMENT

ACT 1998 AND EIA REGULATIONS 2014

Clause 24N(6) of NEMA provides for the amendment of an

EMPR The requirements of an EMPR amendment

process are defined in Clause 37 of the EIA Regulations

2014

The current EMPR amendment process is thus being

undertaken in compliance with this legislation The

amended EMPR will also comply with the content

requirements listed in Appendix 4 of the EIA Regulations

2014

4 CURRENT MINING WORKS PROGRAMME

In line with the current amendment of the marine EMPRs

the PSJV has recently updated its Mining Works

Programme (MWP) which has been submitted to DMR for

approval

The updated MWP provides details on the location and

extent of known and probable diamond bearing gravels

occurring within the five Mining Right areas which extend

from the land (above the high water mark) through the

surf zone to the various sea concessions (a b and c)

(see Figure 2)

Since the current amendment process only deals with the

marine Mining Rights only these areas and the associated

activities are discussed further below

41 MARINE PROSPECTING AND MINING

The marine prospecting and mining operations occur in

Mining Rights 554MRC 512MRC 513MRC and 10025MR

(see Box 1 and Figure 1) which incorporates the Orange

River estuary the surf zone and Sea Concessions 1a 1b

1c 2a 3a 4a and 4b (see Figures 1 and 2) Historical and

potential future mining areas associated with the marine

Mining Rights are indicated in Figure 3

Similar to the onshore operations the PSJV outsources

the majority of the marine mining operations to

contractors The current and potential future prospecting

and mining methods are described in the sections below

411 Marine prospecting

4111 Geophysical Surveys

Geophysical data acquisition commonly includes multi-

beam bathymetry (swath bathymetry) high resolution

shallow penetration seismics and side scan sonar surveys

Survey equipment can either be mounted on or towed

behind the vessel Survey vessels can be small ski boats

fishing vessels or larger purpose modified vessels

for offshore surveying Remote Autonomous Operated

Vehicles (ROVAUV) can also be used for geophysical

surveys

Figure 2 Schematic cross section of the mining concession areas

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

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PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 36: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

4

Figure 3 Historical and future marine mining locations

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 37: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

5

4112 Sampling

Vibrocore sampling is commonly used during early

prospecting for geophysical ground truthing Cores

typically comprise of a 10-15 cm diameter sample up to 5

meters in length

Sediment sampling a similar operation to that of mining is

where a discrete sample is dredged from the seafloor

Samples typically range from 1ndash10 m2 and up to 10 meters

in depth depending on the sampling tool used

412 Marine mining

4121 Boat- and shore-based diver assisted mining

Shallow water (or nearshore) mining operations utilise

either a vessel to support operations or shore-based

support to run the dredge pump and supply air to the

divers These methods are described below

Boat-based diver assisted mining

The diver operations commonly operate in water depths of

less than 12 m A boat-based operation typically consists

of a 10 - 12 m vessel (see Figure 4) with 6 to 8 operational

personnel These vessels are small enough to operate out

of Alexander Bay or Port Nolloth There are currently

approximately 40 vessel-based contractors operating in

the PSJV shallow water concession areas

The dredging operations are typically conducted using

vessel mounted suction pumps and hoses which are

guided by divers into gullies potholes and bedrock

depressions to retrieve the diamond-bearing gravel The

divers operate via a surface supplied airline with air

generated from a vessel based air compressor

The gravel is pumped up through the hose gravel pump

system to the on-board screening system (trommel) Fine

material (lt2 mm) and oversized material (gt20 mm)

discharged from the screening unit washes directly back

into the sea The diamond-bearing gravel is bagged and

transported to the onshore processing plants for further

processing

Figure 4 Typical boat used for boat-based

diver assisted mining

Shore-based diver assisted mining

Mining in the surf zone to water depths of up to 12 m can

also be shore-based and locally referred to as ldquoWalpomprdquo

(beach pumping units) There are currently at least 30

shore-based units operating in the surf zone area

These mining operations are typically confined to small

trap sites The submerged target gravels are mined by at

least two diver-guided suction hoses The hoses are

connected to a tractor that is modified to drive a centripetal

pump (see Figure 5) which feeds the gravel into a rotary

classifier (Trommel) The classifier screens the pumped

material and extracts the size fraction of interest (2 to

20 mm) The large size fraction tailings (gt20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach) while the fine tailings (lt2 mm) are returned directly

to the sea as a sediment slurry

The diamond-bearing gravel is bagged and transported to

the nearest processing facility for diamond recovery

Figure 5 ldquoWalpomprdquo (beach pumping) mining method

A modified tractor drives the pump

4122 Coffer dam mining

Beach and surf zone mining using coffer dams occurs from

the high-water mark up to approximately 150 m seaward of

the low water mark (see Figure 6)

Figure 6 coffer dam mining

This type of mining involves the removal of beach sand

overburden with heavy machinery to access target gravels

overlying the bedrock The submerged bedrock below the

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 38: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

6

beach sand is often below mean sea level which causes

flooding of the excavated area during mining operations

Coffer dams are an efficient mining method for accessing

diamondiferous gravels located below the low water mark

The material used to construct these breakwaters typically

consists of underlying core of quarried material which gets

progressively coarser towards the outside and is covered

by an outer layer of large armour rock Coffer dams are

constantly maintained to restrict the inflow of sea water

into the active mining block When sea water ingresses

into the mining area it is pumped back into the sea

Operations in the beach and surf zone commonly screen

the excavated ore near the mining area and transport the

screened gravel to the nearest processing facility

Coffer dams are commonly in operation for up to three

years after which a large proportion of the berm is

removed the sea naturally reclaims the mined area

4123 Inter-tidal beach mining using mobile pump

units

An alternative mining technique deployed in the surf zone

is a dredging unit mounted on an excavator or on a jack-up

rig (see Figures 7 and 8) Both systems make use of a

remotely operated articulated dredging arm which scours

dredges the seafloor

Areas with generally lower grade larger volumes of gravel

and thicker sand overburden are optimally mined using

these methods

Figure 7 Dredging unit mounted on an excavator

Figure 8 Jack-up rig

Material is pumped from the seafloor and screened

through a classifier which is normally mounted on-board

the mining platform or mobile unit The screened material

is pumped ashore into storage bins which are transported

to the onshore processing plants for diamond recovery

4124 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c 1b amp 4b A variety of methods are used

to mine these marine diamonds deposits depending on the

water depth and topography of the sea floor

Mid- and deep-water remote crawler mining

The PSJV currently has a contract with International

Mining and Dredging Holding Ltd (IMDH) utilising the MV

Ya Toivo mining vessel which uses a remotely operated

crawler to mine in water depths greater than 30 m (see

Figure 9)

The mining vessel operates on a 4-point mooring spread

with dynamic positioning to assist the crawler mining

operations Prior to the launching of the seabed crawler

the vessel anchors over a planned mining area The

crawler is then lowered to the seabed by a winch system

over the stern of the vessel

The seabed crawler is track-driven and is equipped with a

dredge pump system hydraulic power pack and a jet-

water system to facilitate the agitation and suction of

unconsolidated surficial sediments up to the mining vessel

The seabed crawler can remove seabed sediments to a

depth of up to 5 m in a set path within the mine target

area

As the sediment is removed from the seabed it is pumped

to the surface for on-board screening and processing

Unwanted material is discarded overboard The mining

and processing operation is fully self-contained on the

mining vessel with final recovery of diamonds taking place

on the vessel

Figure 9 Illustration of remote crawler mining

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 39: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

7

Mid-water airlift mining

The vessel operations process plant and shore-based

support requirements are similar to that of crawler based

system described above The main difference in

operations is in the mining technology and sediment

mining volumes

The airlift mining system typically comprises a suspended

steel mining tool suction hoses and on-board air

compressors to supply the air chamber at the digging head

see Figure 10) The mining tool itself consists of a steel

pipe fitted with a digging head which is an opening fitted

with rdquogrizzlyrdquo bars to allow sized gravel to pass through

and prevent blockages in the delivery hose The digging

head can be fitted with high pressure water jetting nozzles

which agitates the gravel on the seabed The mining tool

is suspended from davits (cranes) situated along the side

of the vessel On-board screening and processing is self-

contained with final recovery of diamonds taking pace on

the vessel

Figure 10 Illustration of airlift mining

Mid-to-shallow water remote dredge pump mining

This mining operation use vessel mounted pumps to

dredge sediments from the seabed via hoses and a

digging head These vessels are typically smaller than

those described above and can operate out of Port Nolloth

and Alexander Bay The mining system is typically

restricted to water depths of less than 30 m

The mining system comprises of a suspended steel mining

tool suction hoses and an on-board dredge pump (see

Figure 11) The mining tool consists of a steel pipe fitted

with a digging head which can also be fitted with high

pressure water jetting nozzles to agitate the gravel on the

seabed The mining tool is suspended over the side from

the aft or along either side of the vessel

On-board screening and processing is self-contained with

final recovery of diamonds taking pace on the vessel

4125 Orange River estuary mining

Although the PSJV has a right to prospect and mine in the

Orange River no prospecting or mining activities are being

considered for inclusion in the amendment of the EMPR for

554MRC However measures may be required to be

implemented to manage the estuary in light of the proposal

by the Department of Environmental Affairs to declare it a

protected area in terms of the National Environmental

Management Protected Areas Act 2003 (No 57 of 2003)

Figure 11 Illustration of remote dredge pump mining

5 EMPR AMENDMENT AND PUBLIC

PARTICIPATION PROCESS

The EMPR amendment process is summarised in

Figure 12 The anticipated tasks steps in the process are

outlined below

51 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that IampAPs are to be

afforded an opportunity to be involved in and submit

comments on a proposed EMPR amendment

The objective of the public participation process for this

project is to

bull ensure that IampAPs are notified of the intension to

amend the existing EMPRs

bull provide a reasonable opportunity for IampAPs to register

on the project database and

bull provide an opportunity to comment on the proposed

amendments

The key steps in the process where you can participate and

provide input include

bull Distribution of this Background Information Document

for a 30-day comment and registration period and

bull Distribution of the draft EMPR amendment for a 30-day

comment period

Comments received will inform the compilation of the EMPR

and specialist studies

52 SPECIALIST STUDIES

A large amount of information currently exists especially for

onshore mining and rehabilitation activities However

additional specialist input is considered necessary for the

marine and estuarine riverine areas in order to determine

where management measures are lacking and what

additional mitigation measures are required to be included in

the amended EMPR The following two specialist studies

will be undertaken

bull Marine Ecological Study This study will focus on the

shore and surf zone for Sea Concessions 1a 2a 3a

4a 1b 4b and 1c and

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 40: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

8

bull Estuarine Riparian Study This study will focus on the

Orange River estuary and river and the management

thereof

53 COMPILATION AND REVIEW OF AMENDED EMPRs

The findings of the specialist studies and other existing

information will be used to inform the compilation of the

amendment EMPRs for the four Mining Right areas The

intention is to prepare separate EMPRs (or volumes) for

each Mining Right However information applicable to all

Mining Right areas will be incorporated into a single

supporting document (or volume) The amendment process

will thus consist of five volumes namely

bull Volume 1 This volume will include all supporting

information that is applicable to all marine Mining Right

areas eg public participation process (including

Comments and Responses Report) specialist studies

baseline description and other generic documents

bull Volume 2 This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC

bull Volume 3 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (ie Sea Concession 1c)

bull Volume 4 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (ie Sea Concession 4a)

bull Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (ie Sea Concession 4b)

6 INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registrationcomment form or

contact SLR to register as an IampAP

For comments to be included in the draft EMPR addendum

they must reach SLR by no later than 15 September 2017

Figure 12 EMPR amendment process

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 41: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME

ORGANISATION

POSTAL ADDRESS

POSTAL CODE FAX NUMBER

TELEPHONE NUMBER CELL PHONE NUMBER

E-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 42: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

9

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAMEORGANISATIONPOSTAL ADDRESS

POSTAL CODE FAX NUMBERTELEPHONE NUMBER CELL PHONE NUMBERE-MAIL

DATE SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipPLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLRAttention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

Grant Smith

The Endangered Wildlife Trust

Private Bag X11

Modderfontein Gauteng

1645

021 799 8458 084 328 1001

grantsewtorgza

24 August 2017

Sarah Frazee Conservation South Africa (CSA) Email sfrazeeconservationorg

Rehabilitation and management of the Orange River Mouth

As we have had some involvement at the ORM we would like to be kept up to date and included where possiblein the Orange River and Estuary specialist study Estuarine Riparian Study

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 43: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

1

Jeremy Blood

From Gavin J Craythorne ltgavinjohnoutlookcomgt

Sent 06 September 2017 1200 PM

To Jeremy Blood

Cc Jeremy Midgley (jeremymidgleyuctacza) Andrea Pulfrich tyhilekamgmailcom

rpurdon2010 (rpurdon2010gmailcom) Johanna Edwards

(johniedwardsemailcoza) T Madubela (tmadubelaparliamentgovza) Adv

Nicolette de Kock (Ndekockenvironmentgovza)

Subject RE SEAWALL MINING

Hi Jeremy

In terms of Schedule 3 of the NEMWASTE ACT the material used for seawalls is classified as a CATEGORY A

Hazardous Waste while in terms of section 1 of ICMA the building of seawalls is classified as ldquodumping at seardquo in

that seawall material is not ldquofrom the seabed or subsoil of coastal watersrdquo it is quarried on land and transported to

the coast before being dumped into the sea consequently it cannot be excluded from the definition of dumping at

sea in section 1 of ICMA

Seawalls therefore require a dumping permit from the Minister of Environmental Affairs in terms of Section 71 of

ICMA and the building thereof cannot be authorised by the Minister of Minerals nor can it be upheld as legal under

Alexkorrsquos legacy EMPRrsquos

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 44: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

2

I think it is time for this abhorrent method of mining to brought to an abrupt halt permanently before it destroys my

industry and our littoral environment Was the land not enough

Furthermore it is illegal and is punishable by a jail sentence

Kind regards

Gavin Craythorne

(Cell 083 630 1380)

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 45: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From AsiJiKi Development cc Construction amp EngineeringTo Mandy KulaSubject ALEXKOR RMC JV BID FINALDate 13 September 2017 102403 AM

Good day Mandy

Please can you add our company on your database for update We are interestedin tendering as a contractor to mine for Alexkor RMC JV when the opportunitycomesPlease let me know if you need anything from our side

Kind Regards Ben Mokoena Chief Executive OfficerM 082 225 1225 083 505 1250F 086 666 1250E ajkdevelopmentccgmailcom

SERVICES

Dust Suppression- Surface amp Underground

Mechanical Labour Support- Fitter Boilermaker Electricians Auto ElectriciansDiesel Mechanic Instrumentation Semi-Skilled

Piping Supply amp Installation- HDPE PVC Rubber Galvanized Steel

Construction- General

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

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helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 46: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Roos LesleyTo Mandy KulaCc Kruse Michele Valbom Domingos Mahlatsi AbnerSubject Registration as Interested Party in terms of Alexkor BIDDate 15 September 2017 031709 PMAttachments Form Alexkor_BID_Registration DeBeersMarinepdf

Dear Mandy Please find attached De Beers Marinersquo registration as an Interested and Affected Party in terms of Alexkorrsquos BID ndashAmendment of Environmental Management Programmes for Mining Rights 554MRC 10025MRC 512MRC AND 513MRC Kind regardsLesley Lesley RoosEnvironmental Manager The De Beers Group of CompaniesDe Beers Marine (Pty) LtdDBM Gardens Golf Park 2 Raapenberg Road Pinelands 7405PO Box 87 Cape Town 8000 Tel +27 (0) 21 658 3194Mobile +27 (0) 84 240 5543 wwwdebeersgroupcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 47: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse

ORGANISATION De Beers Marine

POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER

TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543

E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE

15 Sep 2017 SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR

Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN

Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 48: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES FOR MINING RIGHTS

554MRC 10025MRC 512MRC AND 513MRC

REGISTRATION AND COMMENT FORM

NAME Lesley Roos and Michele Kruse ORGANISATION De Beers Marine POSTAL ADDRESS PO Box 87 Cape Town

POSTAL CODE 8000 FAX NUMBER TELEPHONE NUMBER 021-658-3194 CELL PHONE NUMBER 0842405543 E-MAIL LesleyRoosdebeersgroupcom MicheleKrusedebeersgroupcom

DATE 15 Sep 2017

SIGNATURE

DETAILS OF OTHER STAKEHOLDERS YOU FEEL SHOULD BE INFORMED

helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT

De Beers Marine operates offshore prospecting rights in South African Sea Areas 2c 3c 4c 5c 6c 7c 8c 9c and 10c PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE

De Beers Marine wishes to register as an Interested and Affected Party We have no comments at this stage helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (use additional pages if required)

Please return completed forms to SLR Attention Mandy Kula

PO Box 10145 Caledon Square 7905 CAPE TOWN Tel 021 461 1118 Fax 021 461 1120

E-mail mkulaslrconsultingcom

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 49: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Patrick ObiesTo Mandy KulaCc Lemson Betha pobies36gmailcomSubject RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC AND 513MRCDate 15 September 2017 071147 PMAttachments image003png

image004pngimage007pngimage008pngimage009png

The DirectorSLR ConsultingATT Mr Jeremy Blood Mrs Mandy KulaEmail mkulaslrconsultingcom Dear Mr Jeremy Blood amp Mrs Mandy Kula RE ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC 10025MRC 512 MRC AND 513MRC WESSA (the Wildlife and Environment Society of South Africa) has long been anactive champion for the South African environment performing an environmentalwatchdog role for the general public for the past 91 years In response to your noticereferenced Alexkor Let IampAPs - BID Rev 1 (Aug 2017) of 16 August 2017 WESSAwould like to be registered as an Interested and Affected party in the publicparticipation process for this amendment application process We note this applicationis an attempt to consolidate and standardise the EMPR framework for the miningactivities on the various concession areas and we make the following preliminarycomments WESSA is currently the implementing agent of the EPWP Working for the CoastProgramme Northern Cape Section (WftCNC) responsible for the coastline betweenthe Orange River mouth and Hondeklipbaai Through our activities to clean restoreand educate on this section of coastline we have become concerned about the impactthat the diamond mining is having on this coastline specifically that efforts torehabilitate the mined areas appear inadequate and not to the full extent provided for inthe current EMPRs This is opinioned on the basis of observed previously minedsections of coastline In terms of our Constitution everyone has the right to have the environment protectedfor the benefit of present and future generations through reasonable legislative andother measures that-prevent pollution and ecological degradation promote conservation and secureecologically sustainable development and use of natural resources while promotingjustifiable economic and social development In determining what is lsquosustainabledevelopmentrsquo Section 4(a) of the Principles of NEMA require that persons impactingon the environment consider all relevant factors including the following

(i) That the disturbance of ecosystems and loss of biological diversity areavoided or where they cannot be altogether avoided are minimised andremedied

(ii) that pollution and degradation of the environment are avoided or wherethey cannot be altogether avoided are minimised and remedied

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 50: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

(vii) that a risk-averse and cautious approach is applied which takes intoaccount the limits of current knowledge about the consequences of decisionsand actions and

(viii) that negative impacts on the environment and on peoples environmentalrights be anticipated and prevented and where they cannot be altogetherprevented are minimised and remedied

NEMA Principle 4 (r) specifically cautions persons impacting on sensitive vulnerablehighly dynamic or stressed ecosystems such as coastal shores estuaries wetlandsand similar systems that they require specific attention in their management andplanning procedures especially where they are subject to significant human resourceusage and development pressure such as by mining activities WESSA is particularlyconcerned about the planned mining into the Orange River estuary section (concessionarea 554 MRC-1a) We hold that appropriately qualified and experience marineestuary specialists be consulted to

1 determine the physical border to which mining must be excluded to protectthe ecological integrity of the estuaryriver mouth zone

2 provide mitigation remedial and other rehabilitation measures required forthe estuarine areas to be mined outside the above exclusion area

3 provide parameters for the EMPR environmental monitoring programme forthe estuary areas falling within any of the PSJV concessions

From our observations of the current mining operations WESSA is off the opinion thatthe mitigation and rehabilitation measures are inadequate and we are concerned thatthey are not being undertaken to the full extent proposed by the current EMPRs Wepropose that appropriately qualified marine or coastal specialists with experience inbest-practice rehabilitation be consulted in the revision of this EMPR With theexperience gained from working along this section of coastline under the WftCNCcontract amongst others WESSA offers to share our insights with such appointedspecialists WESSA has experience in been long-standing active members of various EMCs suchas the Coega IDZ EMC WESSA WftCNC also offers to work with the PSJV SHEQteam in monitoring the implementation of the new EMPR acting as an environmentalrepresentative to the affected communities between Alexander Bay andHondeklipbaai WESSA looks forward to further engaging with SLR Consulting and PSJV in this EMPRamendment process and over the implementation of the consolidated EMPR Yours is sustainable development Patrick Obies0810658880

From Mandy Kula [mailtomkulaslrconsultingcom] Sent Wednesday August 16 2017 1055 AMTo Mandy Kula ltmkulaslrconsultingcomgtSubject ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC 10025MRC 512MRC

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 51: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

From Van Eck GaryTo Mandy KulaSubject STAKEHOLDER REGISTRATIONDate 19 September 2017 065505 AMAttachments DBCM-CTN-APP-01_DBM-GP-PRJ-5235_4265_001pdf

Please see attached GARY VAN ECKOffshore Portfolio ManagerNamdeb Diamond Corporation (Pty) Ltd Tel +27 (0)21 658 3239 (w)Mobile +27 (0)83 995 1220 wwwnamdebcom

The information contained in this e-mail is confidential and may be subject to legal privilegeIf you are not the intended recipient you must not use copy distribute or disclose the e-mailor any part of its contents or take any action in reliance on it If you have received this e-mailin error please e-mail the sender by replying to this message All reasonable precautionshave been taken to ensure no viruses are present in this e-mail and the sender cannot acceptresponsibility for loss or damage arising from the use of this e-mail or attachments

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 52: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

1

Jeremy Blood

Subject FW Alexkor - Requirement for a dumping permit

From Feroza Albertus [mailtoFAlbertusenvironmentgovza]

Sent 12 October 2017 1032 AM To Jeremy Blood

Subject RE Alexkor - Requirement for a dumping permit

Dear Jeremy

Apologies for the delay in my response

We do not consider this activity requiring a dumping permit per the Integrated Coastal Management Act (24 of

2008)

However please note that mine tailings may be regulated in future legislation

Regards

Feroza

From Jeremy Blood

Sent 10 October 2017 1204 PM

To falbertusenvironmentgovza Subject Alexkor - Requirement for a dumping permit

Dear Feroza

Our discussion earlier this morning refers

As you are aware one of the mining methods used at Alexkor is coffer dam mining

Coffer dams occurs from the high-water mark potential up plusmn 300 m seaward (see Figure 1) The material used to

construct the sea walls typically consists of underlying core of quarried material which gets progressively coarser

towards the outside and is covered by an outer layer of large armour rock (see Figure 2) Coffer dams are constantly

maintained to restrict the inflow of sea water into the active mining block When sea water ingresses into the

mining area it is pumped back into the sea Coffer dams are typically in operation for up to three years after which a

large proportion of the berm is removed the sea then naturally under wave action remediates the former mined

area

As part of the EMPR amendment process there has been a query regarding whether or not coffer dam mining

requires a Dumping Permit in terms of National Environmental Management Integrated Coastal Management Act

2008 (No 24 of 2008) and associated Dumping at Sea Regulations There appears to be some ambiguity in the

legalisation with regard to the definitions

It would be appreciated of you could indicate whether or not DEA (Brach Oceans and Coasts) requires a Dumping

Permit for coffer dam mining

I look forward to hearing from you Let me know if you have any queries in this regard

Many thanks

Jeremy Blood

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-

Page 53: IQ Mandy Kula - SLR Consulting · From: IQ To: Mandy Kula Subject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS

2

Figure 1 Example of coffer dam mining operations

Figure 2 Coffer dam construction showing quarried rock being dumped into the sea

Jeremy Blood Senior Environmental Consultant-

+27 21 461 1118

jbloodslrconsultingcom -

SLR Consulting SLR Consulting (Cape Town office)

Unit 39 Roeland Square

Cnr Roeland Street and Drury Lane Cape Town Western Cape 8001-