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