EIA & EMP Summary, 2023

SUBMITTED FOR ENVIRONMENTAL AUTHORISATIONS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) (NEMA) AND THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT, 2014 (ACT NO. 26 OF 2014) (NEM:WA) IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (ACT NO. 28 OF 2002) (MPRDA) (AS AMENDED).

Digby Wells and Associates (South Africa) (Pty) Ltd

Company Registration: 2010/008577/07

Turnberry Office Park, Digby Wells House. 48 Grosvenor Road, Bryanston,2191

Phone: +27 (0) 11 789 9495

Fax: +27 (0) 11 789 9495

E-mail:

Website: https://www.digbywells.com

Directors: DJ Otto,

L Ratsoenyane

This document has been prepared by Digby Wells Environmental.

This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose without Digby Wells Environmental prior written consent.

IMPORTANT NOTICE

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

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

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

OBJECTIVE OF THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

The objective of the environmental impact assessment process is to, through a consultative process: -

• determine the policy and legislative context within which the activity is located and document how the proposed activity complies with and responds to the policy and legislative context;

• describe the need and desirability of the proposed activity, including the need and desirability of the activity in the context of the preferred location;

• identify the location of the development footprint within the preferred site based on an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all the identified development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects of the environment;

• determine the: -

  • nature, significance, consequence, extent, duration and probability of the impacts occurring to inform identified preferred alternatives; and

  • degree to which these impacts: -

  • can be reversed;

  • may cause irreplaceable loss of resources, and

  • can be avoided, managed, or mitigated.

• identify the most ideal location for the activity within the preferred site based on the lowest level of environmental sensitivity identified during the assessment;

• identify, assess, and rank the impacts the activity will impose on the preferred location through the life of the activity;

• identify suitable measures to manage, avoid or mitigate identified impacts; and

• identify residual risks that need to be managed and monitored.

  EXECUTIVE SUMMARY

  Introduction

  Ivanplats (Pty) Ltd. (Ivanplats) is currently developing the Platreef Project, an underground Platinum Group Metals (PGM) mine near Mokopane in the Limpopo Province. The Department of Mineral Resources and Energy (DMRE) granted Ivanplats a Mining Right (MR) (Ref. No.: LP 30/5/2/2/1/10067 MR) in 2014 for a period of thirty years for the development of the Platreef Mine on the farms Macalacaskop 243 KR and Turfspruit 241 KR.

  The first Environmental Authorisation (EA) granted to Ivanplats by the Limpopo Department of Economic Development, Environment and Tourism (LEDET) was on 27 June 2014. Since then, the following amendments have been issued:

• An amendment EA issued on 19 September 2014 (Ref. No.: 12/1/9/2-W32), authorising the following:

• Amendment to allow pipelines to cross wetlands and watercourses from the Tailing Storage Facilities (TSF);

• The inclusion of the need for an annual inspection of the conveyor belt; and

• Amendment to the wording of various authorisations.

  • An EA issued on 30 July 2015 (Ref. No.: 12/1/9/2-W32) in respect of the TSF to be located on the farm Rietfontein 2KS; and

  • An amendment EA issued on 18 June 2018 (Ref. No.: LP 30/5/1/2/3/2/1 [10067] EM) in respect to the inclusion of a second shaft and associated infrastructure, as well as the amendment of the Environmental Management Programme (EMPr).

    Since the granting of the above-mentioned authorisations, Ivanplats has made further changes to the planned Platreef Mine activities. Any change to the approved mine layout necessitates the requirement for an amendment to the relevant licences, in this case the EA, in terms of Regulation 31 of the Environmental Impact Assessment (EIA) Regulations, 2014 (Government Notice No. R. 982 of 4 December 2014 as amended) (the "EIA Regulations, 2014"). The report has also been compiled to consider International Financial Corporation (IFC) Standards with regards to implementing the principles and guidelines stipulated in the standard.

    Further to these Amendments, new infrastructure has also been proposed which triggers Listed Activities in terms of the EIA Regulations, 2014 (as amended) which requires the need for a Scoping and Environmental Impact Reporting (S&EIR) process to be followed.

    It is noted that this application will serve as an addendum to all other amendment applications submitted and will thus not replace the existing and approved EMPRs.

    As part of the proposed Project, the following changes shown in the table below (Table A) are proposed to be made to the approved EIA/EMPr. It must be noted that the development will occur in two phases (Table A).

    Table A: Proposed Amendments to the Approved activities or New proposed Activities

    Infrastructure	Description
    Phase 1
    Dry Stack Tailings Storage	Site earmarked for the Waste Rock Dump (WRD) to be used as Dry Stack TSF. Part of the Ore stockpile area will also accommodate the waste rock separately.
    Ore Stockpile (ROM)	A ROM Stockpile to be constructed. Previously the high- and low-grade ore stockpiles were separated and are now combined.
    Crushing and Screening Plant	A new smaller crushing and screening plant (700ktpa) is proposed to be constructed.
    Backfill Plant	It is proposed that waste/tailings material with a cement or similar binding material will be backfilled underground
    Stormwater Management	Stormwater Management System, consisting of two additional Storm Water Ponds (#4 and #5), various drains and cut off berms will be constructed.
    Diesel Generator Plant	The approved 10MW Diesel Generator Plant will be expanded by 10MW or more
    Phase 2
    Plant Cut off Drain	An additional cut-off drain will be constructed for the existing concentrator plant.
    Stormwater Management	The stormwater drain will be expanded to the Mogalakwena River.
    Haul Roads	The internal roads on the mine will be constructed in phases and upgraded.

    Digby Wells Environmental (Digby Wells) has been appointed by Ivanplats as the independent Environmental Assessment Practitioner (EAP) to facilitate the application for Environmental Authorisation through a Scoping and EIA process.

    To this end, the EA process aims to authorise new Listed Activities triggered in terms of the EIA Regulations, 2014 (as amended) as well as amendments to the approved mine layout which necessitates an amendment application in terms of Regulation 31 of the Environmental Impact Assessment (EIA) Regulations, 2014 (Government Notice No. R. 982 of 4 December 2014 as amended) (the "EIA Regulations, 2014")..

    Project Applicant

    The details of the Project Applicant are included in the table below.

    Company name:	Ivanplats (Pty) Ltd
    Contact person:	Gavin White
    Physical address:	82 on Maude, Second Floor 82 Maude Street Sandton South Africa
    Telephone:	011 088 4300/4369
    Email:	GavinW@Ivanplats.com

    Proposed Changes to the Approved EMPr

    The Platreef Mine is currently under development and sinking of Shaft No. 1 has been completed. In addition, certain mine infrastructure has been established to support the sinking of Shaft 1, including the mine's access road, a mine boundary fence, and temporary facilities such as workshops and offices. There has been some surface excavation work at the Shaft No. 2 area, including the construction of a fence and stormwater infrastructure. The curtain grouting around Shaft No. 2 box cut has been completed and currently, the box cut is being excavated. All the activities are contained within an area of 20 ha and demarcated by a project fence. Ivanplats wishes to amend their EIA/EMPr to optimise operations. The following amendments and developments are proposed:

  • Changing the WRD to a Dry Stack TSF;

  • Construction of an Ore Stockpile (ROM) and waste rock dump;

  • The addition of a new smaller crushing and screening plant (700ktpa);

  • The construction of a Backfill Plant;

  • Stormwater Management System, consisting of two additional Storm Water Ponds (#4 and #5), various drains and cut off berms;

  • The previously approved Diesel Generator plant will be expanded by 10MW or more;

  • An additional cut-off drain will be constructed for the existing concentrator plant;

  • The stormwater drain will be expanded to the Mogalakwena River; and

  • The internal roads on the mine will be constructed in phases and upgraded.

    Overview of the Platreef Mining Operation Phased Approach

    The first phase of the project consists of the further development of the underground workings and the construction of a new additional smaller crushing and screening plant (700ktpa), a Dry Stack TSF and supporting infrastructure.

    These operations will be supported by infrastructure that includes a 132 kV Eskom Supply, a bulk water supply from the Masodi WWTW, on site waste handling facilities and a Stormwater Management System, consisting of two additional new Storm Water Ponds (No.4 and No. 5), various drains and cut off berms.

    Underground operations will be supported from surface by workshops, warehouses, water storage tanks, water pumps, ventilation fans and explosives storage facilities.

    Once the underground workings have been developed to the orebody, stoping will commence using the Drift and Fill method. The mine will be developed using a combination of the Drift and Fill method and the Long Hole Open Stoping method. Most of the mining will be done by Long Hole Open Stoping.

    It is anticipated that in the initial stages of mining, backfilling of the works will take place using waste/tailings material with a cement or similar binding material. However, for the majority of the life of mine, back filling of the stopes will be done using of Cemented Paste Filling (CPF) during phase two.

    The current philosophy is that the paste fill plant will be developed in two modules to align to the Concentrator plant ramp up, which will be further elaborated and defined with the next phase.

    The second phase of the project will commence with the sinking and equipping of Shaft No.2. The larger Shaft No. 2 will allow the mine to increase the underground production in various steps, first to 2.9 Mtpa and then to 5.17 Mtpa, eventually ramped up to 12Mtpa in future. In addition to the Shaft sinking, the second phase of the project will commence with the additional underground development of the mine, the construction of 4.4 Mtpa PGM concentrator (Ramped up to 12Mtpa in future) and the Dry Stack TSF.

    As the underground workings expand, additional ventilation fans will be installed within the Mine Area, notable part of the system will include refrigeration plant at Shaft No.1 as well as the raise boring and equipping of approved Vent Raises No. 1, No. 2 and No. 3.

    The second phase of the project will also see the construction of additional workshops, storage facilities, permanent office facilities, change houses, training facilities and mining related support infrastructure.

    The overall stormwater management infrastructure will be completed during this phase of the project which include the remainder of stormwater drainage, diversion berms, Attenuation Pond and main Storm Water Pond No.3.

    To address the additional traffic the internal roads on the mine will be upgraded.

    Purpose of this Report

    The purpose of an EIA process is to ensure that the potential environmental and social impacts associated with the construction, operation and closure and rehabilitation phases of a project are identified, assessed, and appropriately managed. There are two primary phases of an EIA process, namely the Scoping Phase and the Impact Assessment Phase. Identification of

    potential impacts occurs during the Scoping Phase, whilst the assessment and mitigation of those impacts occurs during the Impact Assessment Phase. The impact assessment and mitigation management are presented in this EIA/EMPr Report. Various specialist studies were undertaken during the Project evaluation to inform the EIA/EMPr; these include:

  • Surface Water Impact Assessment;

  • Wetlands Impact Assessment;

  • Hydropedological Assessment;

  • Geochemical Assessment;

  • Geohydrology Assessment

  • Air Quality Impact Assessment;

  • Climate Change Impact Assessment;

  • Noise Impact Assessment;

  • Visual Assessment;

  • Social Impact Assessment;

  • Heritage Impact Assessment;

  • Traffic Impact Assessment; and

  • Rehabilitation and Closure Assessment.

    A summary of the baseline environment is presented in Section 0 (Part A). Environmental monitoring plans suggested by various specialists are included in Section 8 (Part B) of this report and should be implemented to measure compliance, determine whether mitigation measures are effective and determine trends over the life of the Project.

    Environmental Consultants

    The contact details for the independent EAP are provided in the table below.

    Company name:	Digby Wells Environmental
    Contact person:	Mia Smith
    Physical address:	Digby Wells House, Turnberry Office Park, 48 Grosvenor Road, Bryanston, 2191, South Africa.
    Telephone:	011 789 9495
    Cell phone:	011 069 6801
    Email:	Mia.Smith@digbywells.com

    Approach and Methodology for the Public Participation Process

    A Public Participation Process was initiated during the Scoping Phase, which is central to the investigation of environmental and social impacts, as it is important that stakeholders who are

    affected by the project are given an opportunity to identify concerns and to ensure that local knowledge, needs, and values are understood and taken into consideration as part of the impact assessment process. The Draft Scoping Report was released to the public for input and comments for a period of 30 days. The commenting period was from 29 October 2021 to 30 November 2021. The comments from the stakeholders are included in the Comment and Response Report that was attached as part of the Scoping Report. The Final Scoping Report was submitted to the DMRE on 10 December 2021 and approved on 21 February 2022, thereby allowing Ivanplats to continue into the EIA Phase. Following the approval, an Appeal was lodged against the acceptance of the Scoping Report by the DMRE. The Appeal process has subsequently been concluded on 23 September 2022 and Ivanplats were allowed to continue with the EIA phase of the project.

    The Draft EIA/EMP will be submitted to the public for input and comments for a period of 30 days. The commencing period was from the 14 November 2022 and ended on 14 December 2022. The electronic Draft EIA/EMP was able to be accessed and downloaded from the Digby Wells website www.digbywells.com (Public Documents) and the data-free service portal. A Hard copy of the Draft EIA/EMP was made available to the public at the Mokopane public library.

    Focus Group Meetings (FGMs) were held during this commenting period to present the Draft EIA/EMP and obtain comments from the Interested and Affected Parties (I&APs). The Draft EIA/EMP was updated with comments received from I&APs. The final EIA/EMP was submitted to the DMRE for adjudication on 15 December 2022.

    Following the submission of the final EIA/EMP, a site visit was held between the DMRE and Ivanplats representatives on 3 August 2023 and a hybrid meeting held on 7 August 2023 between DMRE, Ivanplats and Digby Wells representatives, the DMRE issued a letter to Ivanplats on 8 August 2023. The DMRE requested an update of the EIA/EMP on the activities that require environmental authorisation. Following the changes made to the final EIA/EMP, the updated report was resubmitted to the public for review and comment. It must be noted that no new listed activities were added, or changes made to specialist studies. The commenting period was from 22 August 2023 to 21 September 2023. The electronic copy of the EIA/EMP was accessible from the Digby Wells website https://www.digbywells.com (Public Documents, the data-free service portal and newspaper advertisement published on Bosveld local newspaper on week of 24-30 August 2023. A hard copy of the EIA/EMP was made available to the public at the Mokopane public library. No comments were received during the commenting period.

    Project Alternatives

    A Project alternative is defined as a possible course of action, in place of another, that would meet the same purpose and need (Department of Environmental Affairs and Tourism (DEAT), 2004). Section 9.1, Part A, provides the details of the development footprint alternatives considered for this Project. The following alternatives were considered in this EIA/EMPr:

  • Site;

  • Activity

  • Design and layout;

  • Mining Method

  • Technology; and

  • The 'No-Go" alternative.

The proposed Platreef Project area is characterised by warm, wet summers and dry winters. The area is located on the Northern Limb of the Bushveld Igneous Complex. The area is undulating and is located within the dominant Ae, Ah and Ib land types of the 2328 Pietersburg and 2428 Nylstroom land type maps (Land Type Survey Staff, 1989). These land types indicate that the underlying geology consist mainly of hornfels, shale, quartzite, conglomerate, granite and biotite granite.

The proposed Project is situated within the Savanna biome, which is the largest biome in Southern Africa. It consists of a grassy ground layer and a woody plant upper layer. It is known as Shrubveld when the woody layer is in close proximity to the grass layer and as Bushveld in any intermediate phases. The Project area occurs within four vegetation types namely, the Makhado Sweet Bushveld, Mamabolo Mountain Bushveld, Polokwane Plateau Bushveld and Waterberg Mountain Bushveld.

The current land use activities within the proposed areas are mainly artisanal and small mining, cultivation, residential areas, and livestock farming. The diffuse nature of the wetlands on site has been reduced and head-cut erosion has taken place. Livestock overgrazing and trampling have also contributed to the erosion in freshwater systems and drainage lines. The establishment of Alien Invasive Plants (AIPs) has resulted in a loss of vegetation integrity due to the decrease in biodiversity associated with land uses.

The Platreef Project area is located on the watershed boundary of quaternary catchments A61F and A61G within the Limpopo Water Management Area 1 (WMA 1). It is drained by the Mogalakwena River on the western fringe and its tributaries, the Rooisloot and Dithokeng.

The EIA Report, the associated specialist studies and the Public Participation Process (PPP) were undertaken in compliance with relevant South African legislation. A quantitative impact rating methodology was applied to determine the significance of the expected impacts pre-mitigation and post-mitigation. Table A provides a summary of the key impacts (of moderate and major significance only) expected during the various phases of the Project. This report lists and assesses all the potential impacts, together with the associated mitigation measures.

Table A: Summary of the Key Impacts Associated with the Proposed Activities

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The specialist studies that were undertaken during the EIA Phase aimed to identify and weigh anticipated significant impacts and risks associated with the proposed Platreef Project. The findings of the impact assessments have shown that the proposed Project activities will have impacts on the receiving environment. The most significant negative impacts identified are associated with site clearing during the construction phase and general operational and maintenance activities during the operational phase. These activities may result in soil erosion and subsequent sedimentation of watercourses leading to water quality deterioration and alteration of surface and subsurface drainage patterns and reduced catchment water yield reporting to Mogalakwena River and tributaries. The Platreef Project will have a visual impact on the receiving environment. The most significant visual impact of the proposed Project will be from the Dry Stack tailings TSF due to the proposed footprints and height dimensions of this infrastructure.

Wetlands were recorded and cover approximately 157.38 ha which amounts to 1.45% of the total Project Area. The proposed mining activities will have minor impacts on wetlands. An artificial wetland was identified within the proposed infrastructure area. The impacts to this wetland are negligible due to its artificial nature. The highest impacts relating to the proposed activities will be to the Small Spruit Channelled Valley Bottom (CVB) and the Nyl River Floodplain as these systems are the most natural and provide various biodiversity and environmental services. Wetlands will not be directly impacted by the proposed surface infrastructure; however, residual impacts need to be avoided and minimised as far as possible.

Surface infrastructure and the box cut will variably impact on subsurface fluxes towards the Mogalakwena River and its tributaries as they are established to certain depths into the soil profile. Interruption of subsurface flow paths will reduce the flow regime in the affected watercourses, but flows are expected to improve following mine decommissioning, rehabilitation, and re-profiling of affected landscapes, where applicable.

The findings from the noise impact assessment have indicated major impacts on the nearby sensitive receivers from Project related activities. However, the implementation of mitigation measures in addition to the waste rock berm during the different phases of the Project is recommended and is predicted to result in minor impacts post-mitigation. A graveyard and heritage resources were identified within the Project area. The mitigation measures proposed have been described in Section 5 (Part B) of this EIA.

Adequate mitigation measures have been included into the EMPr to reduce the significance of all the identified negative impacts. Most negative impacts can be reduced through the implementation of mitigation measures. Nevertheless, the visual impact assessment, for example, revealed moderate impacts which cannot be mitigated.

The socio-economic study has identified key positive impacts which will result from the Project. If the proposed Project is authorised some positive social and economic impacts will be realised at local, regional, and national level. The Project will contribute to the existing operation, which has created long-term employment opportunities, and which generates

revenue feeding into the regional and national economies in a sector which is employing a growing portion of the workforce.

Monitoring plans, which should be implemented throughout the life of the mine, have also been provided to ensure that adverse impacts are recognised, and continuous improvements are developed and monitored throughout the lifespan of the Project. Based on the findings of the impact assessment, and with the understanding that the mitigation measures proposed herein will be implemented, and the conditions of the environmental authorisation enforced by the relevant authorities will be adhered to, the EAP is of the opinion that an environmental authorisation for the proposed development should be granted.

TABLE OF CONTENTS

1. Introduction 2

2. Item 3: Project Applicant 3

   1. Item 3(a)(i): Details of Environmental Assessment Practitioner 4

   2. Item 3(a)(ii): Expertise of the EAP 4

      1. The Qualifications of the EAP 4

      2. Summary of the EAP's Experience 4

3. Item 3(b): The Location of the Development Footprint of the Activity on the Approved Site as Contemplated in the Accepted Scoping Report 5

4. Item 3(c): Locality Map 8

5. Item 3(d): Description of the Scope of the Proposed Overall Activity 11

   1. Item 3(d)(i): Listed and Specified Activities 11

   2. Item 3(d)(ii): Description of the Activities to be Undertaken 18

      1. Phase 1 Activities 18

      2. Phase 2 Activities 19

      3. Proposed Infrastructure 21

      4. Stormwater Management 21

      5. Water Supply 23

      6. Electricity Supply 24

      7. Waste Management 25

6. Item 3(e): Policy and Legislative Context 29

7. Item 3(f): Need and Desirability of the Proposed Activities 33

   1. Questions to be Engaged with when Considering Need and Desirability 33

8. Item 3(g): Motivation for the Preferred Development Footprint within the Approved Site as Contemplated in the Accepted Scoping Report 44

9. Item 3(h): Full Description of the Process Followed to Reach the Proposed Preferred Alternatives within the Site 44

   1. Item 3(h)(i): Details of the Development Footprint Alternatives Considered 44

      1. Site Alternatives 45

      2. Activity Alternative 45

      3. Design and Layout of the Project 45

      4. Technological Alternative 45

      5. Mining Method Alternative 45

      6. The No-Go Alternative 45

10. Item 3(h)(ii): Details of the Public Participation Process Followed 46

    1. Stakeholder Identification 46

    2. Consultation with Stakeholders during the Scoping Phase 47

    3. Public Participation Activities 48

    4. Consultation with Stakeholders during the EIA Phase 51

    10.2 Item 3(h)(iii): Summary of Issues Raised by I&APs 52

11. Item 3(i): The Environmental Attributes associated with the Development Footprint Alternatives 54

    1. Regional Climate 55

       1. Temperature and Humidity 57

       2. Rainfall 57

    2. Topography and Drainage 58

    3. Visual 62

       1. Baseline Viewshed Modelling 62

       2. Visual Sensitivity of the Area 63

       3. Sensitive Receptors 63

    4. Geology 66

    5. Hydropedology 68

       1. Land Types 68

       2. Soil Forms 70

       3. Hydropedological Soil Types 70

       4. Hydropedological Responses 71

    6. Surface water 75

       1. Hydrological Setting 75

       2. Water Quality 75

       3. Stormwater Management Plan. 79

    7. Groundwater 82

       1. Groundwater Levels and Flow Direction 82

       2. Groundwater Quality 87

       3. Aquifer Characterisation 88

    8. Geochemistry 89

       1. Dry Stack and Cemented Tailings 89

       2. Cemented Rockfill 92

       3. Monolith Leach Test 94

    9. Biodiversity 97

    10. Wetlands 104

        1. Wetland Indicators 104

        2. Wetland Delineation 110

        3. Present Ecological State 113

        4. Ecosystem Services 113

        5. Ecological Importance and Sensitivity 117

        6. Sensitivity Analysis 117

    11. Air Quality 118

        1. Wind Speed 118

        2. Assessment of Existing Air Quality 119

    12. Climate Change 122

        1. Overview of Platreef Project's Operations Emission causing Activities 122

        2. Estimated GHG Emissions from Platreef Project Operation 123

    13. Noise 125

        1. Sensitive Receivers 125

        2. Ambient Noise Levels 128

    14. Heritage 131

        1. Cultural Heritage Baseline Description 131

        2. Site-Specific Heritage Landscape 136

        3. Results from the Pre-Disturbance Survey 138

    15. Socio-Economic 140

        1. Regional and Secondary Study Areas 141

        2. Baseline Conditions for the Primary Study Area 143

    16. Traffic 152

        1. Existing Road Network 152

        2. Existing Traffic Volumes 153

        3. Existing Public Transport and Non-motorised Transport 153

        4. Public Transport and Non-motorised Transport Facilities 153

12. Item 3(j): Impacts and Risks Identified Including the Nature, Significance, Consequence, Extent, Duration and Probability of the Impacts 154

    1. Impacts and Mitigations per Project Phase 154

       1. Groundwater Impacts 177

       2. Carbon and Climate Change 178

    2. Cumulative Impacts 180

       1. Hydropedology 180

       2. Surface Water 180

       3. Wetlands 181

       4. Air Quality 181

       5. Noise 182

       6. Heritage 182

       7. Socio-Economic 182

13. Item 3(k): Methodology used in Determining and Ranking the Nature, Significance, Consequence, Extent, Duration and Probability of Potential Environmental Impacts and Risks 184

    1. Item 3(k)(i): The Positive and Negative Impacts that the Proposed Activity and Alternatives will have on the Environment and the Community that may be affected 189

    2. Item 3(k)(ii): The Possible Mitigation Measures that Could be Applied and the Level of Risk 189

    3. Item 3(k)(iii): Motivation where no Alternative Sites were Considered 189

    4. Item 3(k)(iv): Statement Motivating the Alternative Development Location within the Overall Site 189

14. Item 3(l): Full Description of the Process Undertaken to Identify, Assess and Rank the Impacts and Risks the Activity will Impose on the Preferred Site (In respect of the final site layout plan) Through the Life of the Activity 190

15. Item 3(m): Assessment of each Identified Potentially Significant Impact and Risk191

16. Item 3(n): Summary of Specialist Reports 203

17. Item 3(o): Environmental Impact Statement. 210

    1. Item 3(o)(i): Summary of the Key Findings of the Environmental Impact Assessment 210

    2. Item 3(o)(ii): Final Site Map 211

    3. Item 3(o)(iii): Summary of the Positive and Negative Implications and Risks of the Proposed Activity and Identified Alternatives 211

18. Item 3(p): Proposed Impact Management Objectives and the Impact Management Outcomes for Inclusion in the EMPR 212

19. Item 3(q): Final Proposed Alternatives 212

20. Item 3(r): Aspects for Inclusion as Conditions of Authorisation 213

21. Item 3(s): Description of any Assumptions, Uncertainties and Gaps in Knowledge 214

22. Item 3(t): Reasoned Opinion as to Whether the Proposed Activity should or should not be Authorised 218

    1. Reasons why the Activity should be Authorised or Not 218

    2. Conditions that must be Included in the Authorisation 219

       1. Specific Conditions to be Included into the Compilation and Approval of the EMPR 219

       2. Rehabilitation Requirements 220

23. Item 3(u): Period for which the Environmental Authorisation is Required 220

24. Item 3(v): Undertaking 220

25. Item 3(w): Financial Provision 220

    1. Explain how the Aforesaid Amount was Derived 223

       1. Rates 223

       2. DMRE Classification 223

    2. Confirm that this Amount can be Provided for from Operating Expenditure 224

26. Item 3(x): Deviations from the Approved Scoping Report and Plan of Study 224

27. Item 3(y): Specific Information Required by the Competent Authority 224

    1. Impact on the Socio-Economic Conditions of any Directly Affected Person 224

    2. Impact on any National Estate Referred to in Section 3(2) of the National Heritage Resources Act 227

28. Item 3(z): Other Matters Required in Terms of Sections 24(4)(a) and (b) of the Act 227

1. Item 1(a): Details of the EAP 229

2. Item 1(b): Description of the Aspects of the Activity 229

3. Item 1(c): Composite Map 229

4. Item 1(d): Description of Impact Management Objectives Including Management Statements 231

   1. Item 1(d)(i): Determination of Closure Objectives 231

   2. Item 1(d)(ii): The Process for Managing any Environmental Damage, Pollution, Pumping and Treatment of Extraneous Water or Ecological Degradation as a Result of Undertaking a Listed Activity 231

   3. Item 1(d)(iii): Potential Risk of Acid Mine Drainage 232

   4. Item 1(d)(iv): Steps taken to Investigate, Assess, and Evaluate the Impact of Acid Mine Drainage 233

   5. Item 1(d)(v): Engineering or Mine Design Solutions to be Implemented to Avoid or Remedy Acid Mine Drainage 234

   6. Item 1(d)(vi): Measures That Will be Put in Place to Remedy any Residual or Cumulative Impact that may Result from Acid Mine Drainage. 234

   7. Item 1(d)(vii): Volumes and Rate of Water Use Required for the Mining, Trenching or Bulk Sampling Operation 234

   8. Item 1(d)(viii): Has a Water Use Licence Been Applied for? 236

5. Item 1(e): Impacts to be Mitigated in their Respective Phases. 239

6. Item 1(f): Impact Management Outcomes. 253

7. Item 1(g) Financial Provision 258

   1. Item (g)(i): Determination of the Amount of Financial Provision 258

      1. Item (g)(1)(a): Describe the Closure Objectives and the Extent to Which They Have been Aligned to the Baseline Environment Described under the Regulation 258

      2. Item (g)(1)(b): Confirm Specifically that the Environmental Objectives in Relation to Closure have been Consulted with Landowner and Interested and Affected Parties 259

      3. Item (g)(1)(c): Provide a Rehabilitation Plan that Describes and Shows the Scale and Aerial Extent of the Main Mining Activities, Including the Anticipated Mining Area at the Time of Closure 259

      4. Item (g)(1)(d): Explain why it can be confirmed that the Rehabilitation Plan is Compatible with the Closure Objectives 261

      5. Item (g)(1)(e): Calculate and State the Quantum of the Financial Provision Required to Manage and Rehabilitate the Environment in Accordance with the Applicable Guideline 261

      6. Item (g)(1)(f): Confirm that the Financial Provision will be Provided as Determined 261

8. Item 1(h) Monitoring Compliance and Performance Assessment 261

   1. Item 1(h)(i): Monitoring of Impact Management Actions 261

      1. Surface Water 262

      2. Groundwater 263

      3. Wetlands 265

      4. Air Quality 266

      5. Carbon and Climate Change 267

      6. Noise 268

      7. Visual 268

      8. Social 269

      9. Heritage 270

   2. Item 1(h)(ii): Monitoring and Reporting Frequency 270

   3. Item 1(h)(iii): Responsible Persons 270

   4. Item 1(h)(iv): Time Period for Implementing Impact Management Actions 271

   5. Item 1(h)(v): Mechanism for Monitoring Compliance 271

9. Item 1(i): Indicate the Frequency of the Submission of the Performance Assessment/ Environmental Audit Report. 275

10. Item 1(j): Environmental Awareness Plan 275

    1. Item 1(j)(i): Manner in which the Applicant Intends to Inform his or her Employees of any Environmental Risk which may Result from their Work 275

       1. Communication Strategy 275

       2. Management Sector 275

       3. Mine Workers Sector 276

       4. Evaluation of the Environmental Awareness Plan 276

    2. Item 1(j)(ii): Manner in which Risks will be Dealt with in Order to Avoid Pollution or the Degradation of the Environment 276

11. Item 1(k): Specific Information Required by the Competent Authority 280

12. Undertaking 280

13. Reference List 281

LIST OF FIGURES

Figure 3-1: Land Tenure Map 7

Figure 4-1: Regional Setting 9

Figure 4-2: Locality Map 10

Figure 5-1: Infrastructure Layout Plan (including TSF and Pipelines) 16

Figure 5-2: Detailed Layout of Mining-Related Infrastructure. 17

Figure 5-3: Eskom Supply Network 24

Figure 5-4:Bulk Power Scope of Work 25

Figure 5-5: Waste Disposal Facilities 27

Figure 11-1: Rainfall Distribution within Quaternary Catchments A61F and A61G 55

Figure 11-2: Rainfall and Evaporation Distribution for Quaternaries A61F and A61G 56

Figure 11-3: Runoff Distribution within Quaternary Catchments A61F and A61G 56

Figure 11-4: Monthly Temperature 57

Figure 11-5: Relative Humidity 57

Figure 11-6: Rainfall 58

Figure 11-7: Topographical Map 60

Figure 11-8: Slope Model of the Project Area 61

Figure 11-9: Viewshed Analysis of the TSF 64

Figure 11-10: Viewshed Analysis of the Infrastructure Area 65

Figure 11-11: Regional Geology 67

Figure 11-12: Terrain Form Sketch of the Ae224 Land Type Present in the Platreef Project Area 68

Figure 11-13: Terrain Form Sketch of the Ah28 Land Type Present in the Platreef Project Area

. 69

Figure 11-14: Terrain Form Sketch of the Ib447 Land Type Present in the Platreef Project Area

. 70

Figure 11-15: Soil Delineation 73

Figure 11-16: Conceptual Hillslope Responses within the Platreef Project Area 74

Figure 11-17: Hydrological Setting of the Platreef Project Area 77

Figure 11-18: Floodlines for the 1:50 and 1:100-year Flood Events 81

Figure 11-19: Long-term Water Level Trend at Monitoring Site GPR-13, Mine Site Area -Central Area 82

Figure 11-20: Long-term Water Level Trend at Monitoring Site GPR-26 Upstream Area 83

Figure 11-21: Long-term Water Level Trend at Monitoring Site GPR-04 Central Area. 84

Figure 11-22: Long-term Water Level Response at Monitoring Site BH04 up to June 2021 85 Figure 11-23: Long-term Water Level Response at Monitoring Site GPT006 up to June 2021

. 85

Figure 11-24: Long-term Water Level Response at Monitoring Site GPT010 up to June 2021

. 86

Figure 11-25: Piper Diagram Plot of the Groundwater Monitoring Sites in the PSA 87

Figure 11-26: A comparison of the Mineralogical Composition of Platreef Tailings (Dry Stack and cemented) 91

Figure 11-27: A Comparison of the Mineralogical Composition of Platreef Rockfill Samples96 Figure 11-28: Regional Vegetation 100

Figure 11-29: Conservation Plan 101

Figure 11-30: Mining and Biodiversity Guidelines 102

Figure 11-31: Protected Areas and RAMSAR Sites 103

Figure 11-32: Terrain Indicators 105

Figure 11-33: Soil Indicators 107

Figure 11-34: Vegetation Indicators 109

Figure 11-35: Wetland Delineation 111

Figure 11-36: River FEPA of Platreef Mine 112

Figure 11-37: Ecosystem Services 116

Figure 11-38: Wind Class Frequency 119

Figure 11-39: Background Concentrations of PM2.5 120

Figure 11-40: Background Concentrations of PM10 120

Figure 11-41: Background SO2 Levels 121

Figure 11-42: Background Concentration of NO2 121

Figure 11-43: Background Concentration of CO 122

Figure 11-44: Noise Measurement and Sensitive Receivers Locations 127

Figure 11-45: Noise Time Series Graph for N1 129

Figure 11-46: Noise Time Series Graph for N2 129

Figure 11-47: Heritage Resources Identified within the Regional Study Area 132

Figure 11-48: State of the Environment during the Pre-disturbance Survey 140

Figure 11-49: Results of the Pre-disturbance Survey showing Newly Identified Heritage Resources 140

Figure 11-50: Primary Study Area 144

Figure 11-51: Education Profile 148

Figure 3-1: Composite Map of Environmental Sensitivities within the MRA 230

Figure 4-1: Average Water Balance (m3/d) for the Phase 1 Mining Operation 237

Figure 4-2:Average Water Balance (m3/d) for the Phase 2 Mining Operation 238

LIST OF TABLES

Table 2-1: Contact Details of the Applicant 3

Table 2-2: Contact Details of the EAP 4

Table 3-1: Property Description 5

Table 5-1: New Listed Activities to be undertaken for the Proposed Amendment Project 13

Table 5-2: Activities for Phase 1 19

Table 5-3: Proposed Activities for Phase 2 19

Table 5-4: Project Phases and Associated Activities 20

Table 6-1: Policy and Legislative Context 29

Table 7-1: Need and Desirability 34

Table 10-1: Public Participation Activities 48

Table 10-2: EIA Phase Public Participation Process Activities 51

Table 11-1: Specialist reports and associated appendices 54

Table 11-2: Climate Statistics 58

Table 11-3: Soil Forms and Hydropedological Soil Types 71

Table 11-4: Surface Water Monitoring Points 75

Table 11-5: Surface Water Quality for Streams at Ivanplats Project Site 78

Table 11-6: A Comparison of the Mineralogical percentages and Weathering rate of Project Tailings (Dry Stack and Cemented) 90

Table 11-7: Comparison of the Mineralogical Percentages and Weathering Rate of Platreef Rockfill 95

Table 11-8: Regional Biodiversity Baseline 98

Table 11-9: Wetland Hydro-geomorphic Units of Platreef Mine 110

Table 11-10: Wetland Present Ecological State 113

Table 11-11: Ecosystem Services 114

Table 11-12: Ecological Importance and Sensitivity 117

Table 11-13: Sensitive Areas 118

Table 11-14: Summary of the Ambient Air Quality Results Mahwelereng 119

Table 11-15: Summary of the Ambient Air Quality Results (Gaseous Pollutants) 122

Table 11-16: Summary of Key Emission Sources (All Scope 1 and 2) 123

Table 11-17: Baseline Noise Measurements 128

Table 11-18: Noise Sources Identified 130

Table 11-19: Archaeological Periods in South Africa 131

Table 11-20: Heritage Resources Identified within the Project Area 136

Table 11-21: Primary Study Area Village 145

Table 11-22: Population Characteristics 146

Table 11-23: Population Demographics 147

Table 11-24: Employment Status 148

Table 11-25: Average Household Income 149

Table 11-26: Access to Service Delivery 150

Table 11-27: Community Development Priority Areas 152

Table 12-1: Impact Matrix Abbreviations 154

Table 12-2: Impact Assessment associated with the Construction, Operational and Decommissioning Phases 155

Table 12-3: Impact of Platreef Project's Emissions on South Africa's National Emissions . 179 Table 12-4: Summary of Potential Cumulative Impacts 182

Table 12-5: Cumulative Impacts 182

Table 13-1: Impact Assessment Parameter Ratings 186

Table 13-2: Probability/ Consequence Matrix 187

Table 13-3: Significance Rating Description 188

Table 15-1: Assessment of each identified Potentially Significant Impact 191

Table 16-1: Specialist Studies Undertaken for the Platreef Project. 203

Table 21-1: Specialist Studies Assumptions, Uncertainties, and Gaps 215

Table 25-1: LoM Closure Cost Summary 221

Table 25-2: Mine Classification 224

Table 27-1: Summary of Socio-Economic Impacts 226

Table 1-1: Contact details of the EAP 229

Table 5-1: Impacts to be Mitigated in their Respective Phases 239

Table 6-1: Impacts to be Mitigated in their Respective Phases 253

Table 7-1: Summary of Rehabilitation and Closure Actions 260

Table 8-1: Surface Water Monitoring Plan 262

Table 8-2: Platreef Abstraction Boreholes 264

Table 8-3: Hydrochemistry Parameters Analysed 265

Table 8-4: Wetlands Monitoring Plan 266

Table 8-5: Air Quality Monitoring Plan 267

Table 8-6: Noise Monitoring Programme 268

Table 8-7: Summary of Aspects to be Monitored 269

Table 8-8: Monitoring and Management of Environmental Impacts 272

Table 10-1: Unplanned Events, Risks and their Management Measures. 277

LIST OF APPENDICES

Appendix A: EAP CV and Qualifications Appendix B: Plans

Appendix C: PP Chapter

Appendix D: Visual Impact Assessment Appendix E: Hydropedological Assessment Appendix F: Surface Water Assessment Appendix G: Groundwater Assessment Appendix H: Geochemistry Study

Appendix I: Fauna and Flora (2013 study) Appendix J: Wetland Assessment Appendix K: Air Quality Assessment Appendix L: Climate Change Assessment Appendix M: Noise Assessment Appendix N: Heritage Assessment Appendix O: Social Assessment Appendix P: Traffic Impact Assessment Appendix Q: Closure Cost Assessment Appendix R: Existing Social Labour Plan

Appendix S: Scoping Report Acceptance and Appeal Letter

LIST OF PLANS

Plan 1: Land Tenure Plan 2: Regional Setting Plan 3: Local Setting

Plan 4: Infrastructure Layout

Plan 5: Detailed Infrastructure Plan Plan 6: Floodlines

Plan 7: Vegetation Map Plan 8: Wetland Delineation Plan 9: Composite Map

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