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 11:28:06 AMAttachments: image003.png

image004.pngimage007.pngimage008.pngimage009.pngProvincial Contacts for EIA- related enquiries_June 2017.docxCONTACTS FOR DMR REGIONAL OFFICES_2016.docx

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 EIAadmin@environment.gov.za to reach theChief Directorate: Integrated Environmental Authorisations. Kind regardsChantal Engelbrecht

From: Mandy Kula [mailto:mkula@slrconsulting.com] Sent: Wednesday, August 16, 2017 10:55 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.

mailto:IQ@environment.gov.zamailto:mkula@slrconsulting.commailto:EIAadmin@environment.gov.za

PROVINCIAL COMPETENT AUTHORITIES: CONTACT PERSONS (NEMA and EIA Regulations)

COMPETENT AUTHORITY

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

Cecilia.gyan@dedea.gov.za

Free State

Department of Economic Development, Tourism and Environmental Affairs (DETEA)

Grace Mkhosana

0711482434 or 051 400 4817

mkhosana@detea.fs.gov.za

Gauteng

Department of Agriculture and Rural Development (GDARD)

Boniswa Belot

011 355 1212

Boniswa.Belot@gauteng.gov.za

Limpopo Department Economic Development, Environment and Tourism (LEDET)

Enquiries: Vusi Maluleke

015 290 7167 / 015 290 7138/

082 947 7755

malulekeEV@ledet.gov.za

Victor Mongwe

015 290 7090/ 015 290 7091

mongweV@ledet.gov.za

Tlhagala Ngoasheng

015 290 7058/ 082 041 3223

ngoashengTR@ledet.gov.za

Rhulani Mthombeni

015 290 7057 / 071 558 1187

mthombeniRV@ledet.gov.za

Mpumalanga

Department of Agriculture, Rural Development, Land & Environmental Affairs (DARDLEA)

Provincial Head Office

Selby Hlatshwayo

013 759 4000 or 072 281 1751

SHlatshwayo@mpg.gov.za

Ehlanzeni District

Robyn Luyt

013 759 4000 or 082 672 7868

rluyt@mpg.gov.za

Gert Sibande District

Surgeon Marebane

079 841 9582

STMarebane@mpg.gov.za

Nkangala District

Dineo Tswai

076 644 1707

dtswai@wit.mpu.gov.za

Northern Cape

Department of Environment and Nature Conservation (DENC)

B. Fischer

053 807 7470

bfisher@ncpg.gov.za

Dineo Moleko

053 807 7467

dmoleko@ncpg.gov.za

North-West

Department of Rural Environment and Agricultural (READ)

Portia Krisjan

018 389 5929

pkrisjan@nwpg.gov.za

Ellis Thebe

018 389 5099

gethebe@nwpg.gov.za

Motshabi Mohlalisi

014 597 3597/8

mmohlalisi@nwpg.gov.za

Robert Nemanashi

018 299 6696

rnemanashi@nwpg.gov.za

Western Cape

Department of Environmental Affairs and Development Planning (DEADP)

Director: Planning and Policy Coordination

Paul Hardcastle

021 483 5687

Paul.Hardcastle@pgwc.gov.za

Director: Development Management: Region 1

Zaahir Toefy

021 4832700

zaahir.toefy@westerncape.gov.za

Central Karoo & Eden District

Danie Swanepoel

044 805 8602

Danie.Swanepoel@westerncape.gov.za

Cape Winelands and Overberg District

Mare-Liez Oosthuizen

021 483 5756

Mare-Liez.Oosthuizen@westerncape.gov.za

West Coast District and City of Cape Town

Eldon van Boom

021 483 2877

Eldon.vanBoom@westerncape.gov.za

West Coast District and City of Cape Town

Alvan Gabriel

021 483 2742

Alvan.Gabriel@westerncape.gov.za

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

peter.kuyler@kzndard.gov.za kuylerp@kznded.gov.za

SOUTH REGION: Regional Office: Hilton, Pietermaritzburg

Senior Manager: South

Mr Sibusiso Mthembu

033 - 343 8330

sibusiso.mthembu@kznedtea.gov.za

eThekwini (Durban)(

Yugeshni Govender

Natasha Brijlal

031 382 9368 or 082 921 9340

031 328 9328 or 079 898 0491

yugeshni.govender@kznedtea.gov.za

Natasha.Brijlal@kznedtea.gov.za

Ugu (Port Shepstone)

Melissa Packree

039 682 2045 or 0829219406

melissa.packree@kznedtea.gov.za

Pietermaritzburg (uMgungundlovu)

Reka Kallicharan

033 347 1820 or 082 922 0859

reka.kallicharan@kznedtea.gov.za

Ladysmith (PUthukela)

Dumisane Gwede

036 634 6300 or 0829218924

dumisani.gwede@kznedtea.gov.za

Stanger (iLembe)

Malcolm Moses

032 437 7527 or082 461 8303

MalcolmMoses@kznedtea.gov.za

Ixopo (Harry Gwala)

Ndumiso Masuku

039 - 834 7600

ndumiso.masuku@kznedtea.gov.za

NORTH REGION: Regional Office: Richards Bay

Acting General Manager: Environmental Management

Dr William Mngoma

035 780 6706 or 082 461 8013

william.mngoma@kznedtea.gov.za

Dundee (Umzinyathi)

Gerald Willis-Smith

034 299 9671 or 082 461 8674

Gerald.WillisSmith@kznedtea.gov.za

willis-smithg@kznedtea.gov.za

Newcastle (Amajuba)

Poovi Moodley

034 315 3936 or 082 719 9907

poovey.moodley@kznedtea.gov.za

Ulundi (Zululand)

Sibusiso Ndwandwe

035 874 3296 or082 719 9883

Ndwandwsb@kznedtea.gov.za

sbusisozz57@gmail.com

Mtubatuba (Umkhanyakude)

Dayalin Naidoo

035 550 0210 or 079 496 8002

dayalin.naidoo@kznedtea.gov.za

Richards Bay (Uthungulu)

Muziwandile Mdamba

035 780 6844 or 082 822 2582

Muzi.Mdamba@kznedtea.gov.za

mdambam@kznedtea.gov.za

North-West

Department of Rural Environment and Agricultural (READ)

Portia Krisjan

018 389 5929

pkrisjan@nwpg.gov.za

Ellis Thebe

018 389 5099

gethebe@nwpg.gov.za

Motshabi Mohlalisi

014 597 3597/8

mmohlalisi@nwpg.gov.za

Robert Nemanashi

018 299 6696

rnemanashi@nwpg.gov.za

DMR REGIONAL OFFICE CONTACTS

REGION

REGIONAL MANAGER & PA

TELEPHONE NUMBER

POSTAL ADDRESS

Physical address

NORTHERN REGIONS

Limpopo

Mr Aaron Kharivhe

(Regional Manager)

Aaron.Kharivhe@dmr.gov.za

PA: Tebogo Mangaba

Tebogo.Mangaba@dmr.gov.za

Mr Thivhulawi Kolani

Thivhulawi.Kolani@dmr.gov.za

Deputy Director: Environment

Tel: 015 287 4703

Fax 015 287 4706

Private Bag x 9467

Polokwane

0700

101 Dorp Street Polokwane

0700

Mpumalanga

Mr Aubrey Tshivhandekano

Regional Manager

Aubrey.Tshivhandekano@dmr.gov.za

PA: Lydia Maphopha

Lydia.Maphopha@dmr.gov.za

Matshilele Ramovha

Acting Deputy Director: Environment

Matshilele.Ramovha@dmr.gov.za

Tel: 013 653 0500

Fax 013 653

Private Bag x7279

Witbank

1035

Receiver of Revenue Building

Cn Paul Kruger & Botha

Emalahleni, 1035

WESTERN REGIONS

Gauteng

Mr. Dimakatso Ledwaba

Acting Regional Manager

dimakatso.ledwaba@dmr.gov.za

PA: Carol Khanyile

Carol.Khanyile@dmr.gov.za

Rudzani Mabogo

Acting Deputy Director

Rudzani.Mabogo@dmr.gov.za

011 358 9700

Fax 011 339 2423

Private Bag x5

Braamfontein

2017

79 Mineralia Building, Cnr De korte and De beer Str Braamfontein

North West

Mr Peter Swart

Regional Manager

Pieter.Swart@dmr.gov.za

PA: Ipeleng Wesi

Ipeleng.Wesi@dmr.gov.za

Phumudzo Nethwadzi

Deputy Director: Environment

Phumudzo.Nethwadzi@dmr.gov.za

Tel: 018 487 9830 Ext 9834

Fax 086 710 1228 / 018487 9831

Private Bag A 1

Klerksdorp

2571

Vaal University of Technology, cnr Voortrekker & Magaretha, Prinsloo Str Klerksdorp 2570

CENTRAL REGIONS

Free State

Mr Ndlelenhle Zindela

Regional Manager

ndlelenhle.zindela@dmr.gov.za

PA: Tshepo Makgoba

Tshepo.Makgoba@dmr.gov.za

Meshack Mudau

Deputy Director: Environment

Meshack.Mudau@dmr.gov.za

Tel: 057 391 1300

Fax 057 357 6003

Private Bag x 33

Welkom

9460

The Strip 314

Stateway & Bok Str

Welkom

Northern Cape

Springbok Satellite office

Mr Sunday Mabaso

Regional Manager

sunday.mabaso@dmr.gov.za

PA: Brenda Monnapula

Brenda.Monnapula@dmr.gov.za

Ntsundeni Ravhugoni

Deputy Director: Environment

Ntsundeni.Ravhugoni@dmr.gov.za

Jasper Niewoudt

Jasper.Niewoudt@dmr.gov.za

PA: Ms Chrizelle Farmerf

Chrizella.Farmerf@dmr.gov.za

Tel: 053 807 1700

Fax 053 832 5631

Tel: 027 712 8160

Fax:027 712 1959

Private Bag x 6093

Kimberley

8300

Cnr Reibeck Str , 1st Floor

Van Der Stel Str, Springbok

Liberty Corner

Building 29 – 31, Currey Str, Kimberly

COASTAL REGIONS

Western Cape

Ms Sibongile Kunene

Regional Manager

sibongile.kunene@dmr.gov.za

PA: Busisiwe Magazi

Busisiwe.Magazi@dmr.gov.za

Jan Briers

Deputy Director: Environment

Jan.Briers@dmr.gov.za

021 427 1000

Fax 021 427 1050/1046

Private Bag x 9

Roggebaai

8012

Eastern Cape

Mr Azwihangwisi Mulaudzi

Regional Manager

Azwihangwisi.mulaudzi@dmr.gov.za

PA; Zimkita Tyala

Zimkita.Tyala@dmr.gov.za

Deidre Thompson (nee Watkins)

Deputy Director: Environment

Deidre.Watkins@dmr.gov.za

041 396 3900

Fax: 086 503 6992

Crispin Hall 690

Cnr Mount and Diaz Road,

Port Elizabeth

KZN

Nqobile Njoko

Regional Manager

Nqobile.Njoko@dmr.gov.za

PA: Nandipha Qwalela

Nandipha.Qwalela@dmr.gov.za

Karoon Moodley

Deputy Director: Environment

Karoon.Moodley@dmr.gov.za

Tel: 031 355 9600

Fax; 031 301 56950

Durban Bay House

333 Smith Street

Durban

REGIONAL OFFICES

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

PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC, 10025MRC, 512MRC AND 513MRCDate: 16 August 2017 11:25:54 AMAttachments: image417cdb.PNG

imaged782be.PNGimageda795b.PNGimaged13518.PNGimagea9cd61.PNGimageae71f0.PNGimageffee86.PNGimageeb495e.PNGimage6a47b5.PNGimage8a11c2.PNGAlexkor Let I&APs - BID Rev 1 (Aug 2017) - English.pdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - Afrikaans.pdfAlexkor_BID_FINAL_14Aug17.pdf

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: Kgaudi.Shapo@dmr.co.za , Telephone:053 807 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: Vincent.muila@dmr.gov.za , 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 :Johannes.Nematatani@dmr.gov.zaWebsite :

From: Mandy Kula [mailto:mkula@slrconsulting.com] Sent: Wednesday, August 16, 2017 10:55 AMTo: Mandy Kula Subject: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTALMANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS 554MRC, 10025MRC, 512MRCAND 513MRC Dear Sir / Madam

mailto:Johannes.Nematatani@dmr.gov.zamailto:mkula@slrconsulting.commailto:nsmyth@slrconsulting.commailto:Kgaudi.Shapo@dmr.gov.zamailto:Vincent.muila@dmr.gov.zamailto:Kgaudi.Shapo@dmr.co.zamailto:Vincent.muila@dmr.gov.zamailto:Johannes.Nematatani@dmr.gov.zahttps://twitter.com/DMR_SAhttps://www.facebook.com/Department-of-Mineral-Resources-212481992150861/https://www.instagram.com/dmr_gov_za/

Project Reference: 720.01087.0001 File Ref. Alexkor Let I&APs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir / Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

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

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

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

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

(NEMA), as amended; and

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

as amended.

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as “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. Mining activities are

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

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

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

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

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

SLR Environmental Consulting (South Africa) (Pty) Ltd (“SLR”), in association with Placer Resource Management

(Pty) Ltd (“PRM”), has been appointed by the PSJV to undertake the EMPR amendment and public participation

process.

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

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

If you or your organisation would like to register as an interested and affected party (I&AP) and/or wish to raise

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

Response Form and forward it to our Ms Mandy Kula (E-mail: mkula@slrconsulting.com) by no later than

15 September 2017.

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

Yours sincerely

Jeremy Blood Pr.Sci.Nat., CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl.

P:\Jobs\Ale01emp\Corresp. Out\public\BID\Alexkor Let I&APs - BID Rev 1 (Aug 2017).docx

Verwysings nommer: 720.01087.0001 Verwysing: Alexkor Let I&APs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

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

VIR MYNREGTE 554MRC, 10025MRC, 512MRC EN 513MRC

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

terme van:

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

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

(NEMA), soos gewysig; en

• Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling, 2002 (No. 28 van 2002)

(MPRDA), soos gewysig.

Die “Alexkor RMC Pooling and Sharing JV” (verder “PSJV”) is die houer van verskeie aanlandige en mariene

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

noorde, en ‘n baken ongeveer 5 kilometer noord van die dorp Kleinzee, in die suide. Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBP’s. Die PSJV is tans besig met die wysiging van die OBP’s van die verskeie

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

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

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

goedgekeur in April 2017, word nie hersien en of gewysig as deel van die huidige proses,nie.

SLR Environmental Consulting (South Africa) (Pty) Ltd (“SLR”), in samewerking met Placer Resource

Management (Pty) Ltd (“PRM”), is aangestel deur die PSJV om die OBP’s te hersien en te wysig, asook om die

publieke deelnameproses te behartig.

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

kommentaar vir ‘n periode van 30 dae vanaf 16 Augustus tot 15 September 2017. ‘n Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting.

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

wil rig aangaande die voorgestelde proses en of projek, voltooi asseblief die aangehegte vorm, “Registration and

Response Form”, en stuur dit aan Me Mandy Kula (E-pos: mkula@slrconsulting.com) teen nie later as

15 September 2017.

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

Vriendelike groete

Jeremy Blood Pr.Sci.Nat., CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl. P:\Jobs\Ale01emp\Corresp. Out\public\BID\Alexkor Let I&APs - BID Rev 1 (Aug 2017).docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC, 10025MRC, 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1. BACKGROUND

In 2011, Alexkor SOC Limited (Alexkor) and the Richtersveld

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

Joint Venture (hereafter referred to as “PSJV”), 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:

• Conventional open cast terrestrial mining;

• Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as “walpomp”);

• Boat-based diver assisted mining;

• Coffer dam mining; and

• Large vessel mining using airlift or bottom deployed

remotely operated mining systems.

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs),

as amended.

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

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

current requirements of the National Environmental

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

Environmental Impact Assessment (EIA) Regulations 2014, as

amended, and to ensure alignment with each other, all new

legislation, environmental standards, as well as internal PSJV

Performance Assessment Reports. The EMPR for the onshore

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

being amended as part of this process.

SLR Consulting (South Africa) (Pty) Ltd (“SLR”), in association

with Placer Resource Management (Pty) Ltd (“PRM”), has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC

and undertake the associated public participation process.

2. PURPOSE OF THIS DOCUMENT

This document provides information on:

• PSJV’s intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds;

• the current Mining Works Programme;

• the EMPR amendment and public participation process;

and

• how you can register as an interested and affected party

(I&AP) and submit initial comments.

3. KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below.

3.1 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT, 2002

Section 102 of the Mineral and Petroleum Resources

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

amended, requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority).

Box 1: Alexkor RMC JV’s Marine Mining Rights.

• Mining Right 554MRC, comprising:

> Centre line of the Orange River, to the bank of along

the following properties: Corridor-Wes (Farm No. 2),

Portion 17 (a portion of Portion 8), Portion 16

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

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

Farm Brandkaros (Farm No. 517);

> Surf zone along Farm No. 1 and Farm No. 155;

> Sea Concession 1a;

> Sea Concession 1b;

> Sea Concession 2a; and

> Sea Concession 3a.

• Mining Right 10025MR, comprising Sea Concession 1c;

• Mining Right 512MRC, comprising Sea Concession 4a;

and

• Mining Right 513MRC, comprising Sea Concession 4b.

REGISTER AS AN INTERESTED AND AFFECTED PARTY:

Please complete the enclosed registration / comment form or contact SLR to register as an I&AP.

Attention: Mandy Kula

PO Box 10145, Caledon Square, 7905, CAPE TOWN

Tel: 021 461 1118; Fax: 021 461 1120

E-mail: mkula@slrconsulting.com

2

Figure 1: Location map of PSJV’s 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 3.2 below).

3.2 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.

4.1 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.

4.1.1 Marine prospecting

4.1.1.1 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 (ROV/AUV) 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

4.1.1.2 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 1–10 m2 and up to 10 meters

in depth depending on the sampling tool used.

4.1.2 Marine mining

4.1.2.1 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 (20 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 “Walpomp”

(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 (>20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach), while the fine tailings (

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.

4.1.2.3 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.

4.1.2.4 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c, 1b & 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 ”grizzly” 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.

4.1.2.5 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.

5.1 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that I&APs 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:

• ensure that I&APs are notified of the intension to

amend the existing EMPRs;

• provide a reasonable opportunity for I&APs to register

on the project database; and

• provide an opportunity to comment on the proposed

amendments.

The key steps in the process where you can participate and

provide input include:

• Distribution of this Background Information Document

for a 30-day comment and registration period; and

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

comment period.

Comments received will inform the compilation of the EMPR

and specialist studies.

5.2 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:

• 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

• Estuarine / Riparian Study: This study will focus on the

Orange River estuary and river, and the management

thereof.

5.3 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:

• Volume 1: This volume will include all supporting

information that is applicable to all marine Mining Right

areas, e.g. public participation process (including

Comments and Responses Report), specialist studies,

baseline description and other generic documents.

• Volume 2: This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC.

• Volume 3: This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (i.e. Sea Concession 1c).

• Volume 4: This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (i.e. Sea Concession 4a).

• Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (i.e. Sea Concession 4b).

6. INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registration/comment form or

contact SLR to register as an I&AP.

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:

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT:

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………………….

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE:

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

…………………………………………………………………………………………… (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: mkula@slrconsulting.com

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 12:01:22 PMAttachments: image417cdb.PNG

imaged782be.PNGimageda795b.PNGimaged13518.PNGimagea9cd61.PNGimagecf2dd3.PNGimage543f2a.PNGimaged1670f.PNGimage187175.PNGimage3fbef8.PNGAlexkor Let I&APs - BID Rev 1 (Aug 2017) - English.pdfAlexkor Let IAPs - BID Rev 1 (Aug 2017) - Afrikaans.pdfAlexkor_BID_FINAL_14Aug17.pdf

Dear Linda, Kindly receive the attached documents for your attention. Regards,Takalani

Takalani KhorombiMineral RegulationsTel : 053 807 1748Email :Takalani.Khorombi@dmr.gov.zaWebsite :

From: Mandy Kula [mailto:mkula@slrconsulting.com] Sent: Wednesday, August 16, 2017 10:55 AMTo: Mandy Kula Subject: 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

mailto:Takalani.Khorombi@dmr.gov.zamailto:Linda.Njemla@dmr.gov.zamailto:mkula@slrconsulting.commailto:Takalani.Khorombi@dmr.gov.zahttps://twitter.com/DMR_SAhttps://www.facebook.com/Department-of-Mineral-Resources-212481992150861/https://www.instagram.com/dmr_gov_za/

Project Reference: 720.01087.0001 File Ref. Alexkor Let I&APs - BID Rev 1 (Aug 2017)

16 August 2017

Dear Sir / Madam

ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OF ENVIRONMENTAL MANAGEMENT

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

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

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

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

(NEMA), as amended; and

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

as amended.

The Alexkor RMC Pooling and Sharing JV (hereafter referred to as “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. Mining activities are

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

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

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

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

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

SLR Environmental Consulting (South Africa) (Pty) Ltd (“SLR”), in association with Placer Resource Management

(Pty) Ltd (“PRM”), has been appointed by the PSJV to undertake the EMPR amendment and public participation

process.

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

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

If you or your organisation would like to register as an interested and affected party (I&AP) and/or wish to raise

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

Response Form and forward it to our Ms Mandy Kula (E-mail: mkula@slrconsulting.com) by no later than

15 September 2017.

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

Yours sincerely

Jeremy Blood Pr.Sci.Nat., CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Encl.

P:\Jobs\Ale01emp\Corresp. Out\public\BID\Alexkor Let I&APs - BID Rev 1 (Aug 2017).docx

Verwysings nommer: 720.01087.0001 Verwysing: Alexkor Let I&APs - BID Rev 1 (Aug 2017)

16 Augustus 2017

Geagte Leser

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

VIR MYNREGTE 554MRC, 10025MRC, 512MRC EN 513MRC

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

terme van:

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

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

(NEMA), soos gewysig; en

• Seksie 102 van die Wet op Minerale en Petroleum Hulpbronontwikkeling, 2002 (No. 28 van 2002)

(MPRDA), soos gewysig.

Die “Alexkor RMC Pooling and Sharing JV” (verder “PSJV”) is die houer van verskeie aanlandige en mariene

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

noorde, en ‘n baken ongeveer 5 kilometer noord van die dorp Kleinzee, in die suide. Mynbou aktiwiteite word tans

uitgevoer soos omskryf in die OBP’s. Die PSJV is tans besig met die wysiging van die OBP’s van die verskeie

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

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

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

goedgekeur in April 2017, word nie hersien en of gewysig as deel van die huidige proses,nie.

SLR Environmental Consulting (South Africa) (Pty) Ltd (“SLR”), in samewerking met Placer Resource

Management (Pty) Ltd (“PRM”), is aangestel deur die PSJV om die OBP’s te hersien en te wysig, asook om die

publieke deelnameproses te behartig.

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

kommentaar vir ‘n periode van 30 dae vanaf 16 Augustus tot 15 September 2017. ‘n Kopie van die

Agtergrondinligtingsdokument is aangheg vir verdere inligting.

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

wil rig aangaande die voorgestelde proses en of projek, voltooi asseblief die aangehegte vorm, “Registration and

Response Form”, en stuur dit aan Me Mandy Kula (E-pos: mkula@slrconsulting.com) teen nie later as

15 September 2017.

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

Vriendelike groete

Jeremy Blood Pr.Sci.Nat., CEAPSA

SLR CONSULTING (SOUTH AFRICA) (PTY) LTD

Ingesl. P:\Jobs\Ale01emp\Corresp. Out\public\BID\Alexkor Let I&APs - BID Rev 1 (Aug 2017).docx

1

ALEXKOR RMC POOLING AND SHARING JV

AMENDMENT OF ENVIRONMENTAL MANAGEMENT

PROGRAMMES FOR MINING RIGHTS

554MRC, 10025MRC, 512MRC AND 513MRC

BACKGROUND INFORMATION DOCUMENT AUGUST 2017

1. BACKGROUND

In 2011, Alexkor SOC Limited (Alexkor) and the Richtersveld

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

Joint Venture (hereafter referred to as “PSJV”), 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:

• Conventional open cast terrestrial mining;

• Shore-based beach pumping in the shallow surf zone

using small-scale diver-assisted suction equipment

(referred to locally as “walpomp”);

• Boat-based diver assisted mining;

• Coffer dam mining; and

• Large vessel mining using airlift or bottom deployed

remotely operated mining systems.

Mining activities are currently undertaken in terms of three

approved Environmental Management Programmes (EMPRs),

as amended.

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

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

current requirements of the National Environmental

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

Environmental Impact Assessment (EIA) Regulations 2014, as

amended, and to ensure alignment with each other, all new

legislation, environmental standards, as well as internal PSJV

Performance Assessment Reports. The EMPR for the onshore

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

being amended as part of this process.

SLR Consulting (South Africa) (Pty) Ltd (“SLR”), in association

with Placer Resource Management (Pty) Ltd (“PRM”), has been

appointed by the PSJV as the independent Environmental

Assessment Practitioner to amend the existing EMPRs for

Mining Rights 554MRC, 10025MRC, 512MRC and 513MRC

and undertake the associated public participation process.

2. PURPOSE OF THIS DOCUMENT

This document provides information on:

• PSJV’s intension to amend its approved EMPRs for the

four marine Mining Rights it currently holds;

• the current Mining Works Programme;

• the EMPR amendment and public participation process;

and

• how you can register as an interested and affected party

(I&AP) and submit initial comments.

3. KEY LEGISLATIVE REQUIREMENTS

The key legislative requirements and guiding principles

underpinning the EMPR amendment process are outlined

below.

3.1 MINERAL AND PETROLEUM RESOURCES

DEVELOPMENT ACT, 2002

Section 102 of the Mineral and Petroleum Resources

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

amended, requires that any amendment to an EMPr

prepared in terms of the MPRDA be approved by the

Minister of Minerals and Energy (or the delegated authority).

Box 1: Alexkor RMC JV’s Marine Mining Rights.

• Mining Right 554MRC, comprising:

> Centre line of the Orange River, to the bank of along

the following properties: Corridor-Wes (Farm No. 2),

Portion 17 (a portion of Portion 8), Portion 16

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

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

Farm Brandkaros (Farm No. 517);

> Surf zone along Farm No. 1 and Farm No. 155;

> Sea Concession 1a;

> Sea Concession 1b;

> Sea Concession 2a; and

> Sea Concession 3a.

• Mining Right 10025MR, comprising Sea Concession 1c;

• Mining Right 512MRC, comprising Sea Concession 4a;

and

• Mining Right 513MRC, comprising Sea Concession 4b.

REGISTER AS AN INTERESTED AND AFFECTED PARTY:

Please complete the enclosed registration / comment form or contact SLR to register as an I&AP.

Attention: Mandy Kula

PO Box 10145, Caledon Square, 7905, CAPE TOWN

Tel: 021 461 1118; Fax: 021 461 1120

E-mail: mkula@slrconsulting.com

2

Figure 1: Location map of PSJV’s 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 3.2 below).

3.2 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.

4.1 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.

4.1.1 Marine prospecting

4.1.1.1 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 (ROV/AUV) 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

4.1.1.2 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 1–10 m2 and up to 10 meters

in depth depending on the sampling tool used.

4.1.2 Marine mining

4.1.2.1 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 (20 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 “Walpomp”

(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 (>20 mm)

accumulate around the classifier (being later dispersed

during the high tide or mechanically redistributed over the

beach), while the fine tailings (

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.

4.1.2.3 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.

4.1.2.4 Large vessel mining

Large vessel mining operations are restricted to Sea

Concessions 1c, 1b & 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 ”grizzly” 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.

4.1.2.5 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.

5.1 PUBLIC PARTICIPATION PROCESS

The EIA Regulations 2014 requires that I&APs 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:

• ensure that I&APs are notified of the intension to

amend the existing EMPRs;

• provide a reasonable opportunity for I&APs to register

on the project database; and

• provide an opportunity to comment on the proposed

amendments.

The key steps in the process where you can participate and

provide input include:

• Distribution of this Background Information Document

for a 30-day comment and registration period; and

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

comment period.

Comments received will inform the compilation of the EMPR

and specialist studies.

5.2 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:

• 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

• Estuarine / Riparian Study: This study will focus on the

Orange River estuary and river, and the management

thereof.

5.3 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:

• Volume 1: This volume will include all supporting

information that is applicable to all marine Mining Right

areas, e.g. public participation process (including

Comments and Responses Report), specialist studies,

baseline description and other generic documents.

• Volume 2: This volume will deal specifically with the

coastal and marine mining operations pertaining to

Mining Right 554MRC.

• Volume 3: This volume will deal specifically with the

marine mining operations pertaining to Mining Right

10025MR (i.e. Sea Concession 1c).

• Volume 4: This volume will deal specifically with the

marine mining operations pertaining to Mining Right

512MRC (i.e. Sea Concession 4a).

• Volume 5 This volume will deal specifically with the

marine mining operations pertaining to Mining Right

513MRC (i.e. Sea Concession 4b).

6. INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registration/comment form or

contact SLR to register as an I&AP.

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:

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

PLEASE IDENTIFY YOUR INTEREST IN THE PROPOSED PROJECT:

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………………….

PLEASE WRITE YOUR COMMENTS AND QUESTIONS HERE:

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………

…………………………………………………………………………………………… (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: mkula@slrconsulting.com

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 11:40:27 AMAttachments: image002.png

image003.pngimage005.pngimage006.pngimage007.pngimage4d3acf.PNGimage086e82.PNGimaged3a2b9.PNGimaged14132.PNGimage8bc14e.PNG

Noted 

Linda NjemlaMineral RegulationTel : 027 712 8177Email : Linda.Njemla@dmr.gov.zaWebsite :

From: Mandy Kula [mailto:mkula@slrconsulting.com] Sent: 16 August 2017 10:55 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. 

mailto:Linda.Njemla@dmr.gov.zamailto:mkula@slrconsulting.commailto:Linda.Njemla@dmr.gov.zahttps://twitter.com/DMR_SAhttps://www.facebook.com/Department-of-Mineral-Resources-212481992150861/https://www.instagram.com/dmr_gov_za/

From: Cloete, JulienTo: Mandy KulaCc: Witbooi, UrsulaSubject: Registration as I&AP for Alexkor EMP amendmentDate: 17 August 2017 11:16:13 AMAttachments: 20170817123041388.pdf

Good morning,Please find attached the registration form for Namdeb. Thanks Julien MB CloeteEnvironmental Management Coordinator – Rehabilitation Namdeb Diamond CorporationMineral Resource Department/Environmental SectionOranjemundNAMIBIA Tel: +264 63 239665Fax: +264 63 239603 www.namdeb.com

*****************************************************************************The information contained in this e-mail is confidential and may be subject to legal privilege.If 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.******************************************************************************

mailto:Julien.Cloete@namdeb.commailto:mkula@slrconsulting.commailto:ursula.witbooi@namdeb.com

From: Gregor CalderwoodTo: Mandy KulaSubject: Notice of EMPR Amendment and PPP - AlexkorDate: 21 August 2017 02:50:24 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

mailto:gregor.calderwood@gmail.commailto:mkula@slrconsulting.com

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 10:02:33 AM

Dear Mandy

SAHRA would like to register as an I&AP 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:| F:021 462 4509E: bwilliams@sahra.org.za | 111 Harrington Street | Cape Town | 8001

www.sahra.org.zaSAHRA Logo

SAHRA Values

This electronic communication and its content(s) are subject to a disclaimer which can be accessed here:http://mail.sahra.org.za/disclaimer.html

Break The Corruption Chain

mailto:bwilliams@sahra.org.zamailto:mkula@slrconsulting.comhttp://www.sahra.org.za/file:////c/www.sahra.org.zafile:////c/www.sahra.org.zahttp://mail.sahra.org.za/disclaimer.html

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 07:44:18 AMAttachments: image527d3c.PNG

image44480c.PNGimageb976b1.PNGimaged34e2e.PNGimage8b3f68.PNGimage21baaf.PNGimage001.pngimage002.png

Dear Mandy and Jeremy

Thanks for your emails, sorry I haven't 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:| F:021 462 4509E: bwilliams@sahra.org.za | 111 Harrington Street | Cape Town | 8001

www.sahra.org.zaSAHRA Logo

SAHRA Values

From: "Jeremy Blood" To: "Mandy Kula" , "Briege Williams"

Sent: Tuesday, 22 August, 2017 11:11:01 AMSubject: RE: ALEXKOR RMC POOLING AND SHARING JV - AMENDMENT OFENVIRONMENTAL MANAGEMENT PROGRAMMES (EMPRs) FOR MINING RIGHTS554MRC, 10025MRC, 512MRC AND 513MRC

Mandy, 

mailto:bwilliams@sahra.org.zamailto:jblood@slrconsulting.commailto:mkula@slrconsulting.comhttp://www.sahra.org.za/file:////c/www.sahra.org.zafile:////c/www.sahra.org.za

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 01:12:15 PMAttachments: RMC Letter Head 2017.doc

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 matthews.craig1969@gmail.com

I look forward to your response.

Regards,Craig MatthewsDirector: Richtersveld Mining Company (Pty) Ltd

mailto:matthews.craig1969@gmail.commailto:mkula@slrconsulting.commailto:matthews.craig1969@gmail.com

Richtersveld Mining Company

P.O Box 64, Alexander Bay, 8290

Richtersveld Mining Company

Frikkie Snyman, 7th Avenue, Alexander Bay, 8290

David Austen – Vice Chairperson

Craig Matthews

Richtersveld Mining CompanyRichtersveld Mining Company

P O Box 64 6 Orange Road

Alexander Bay Alexander Bay

8290 8290

Craig Matthews (Director)

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 11:00:48 AMAttachments: image005.png

image006.pngimage009.pngimage010.pngimage011.pngimage001.pngAlexkor_EWT_Registration.pdf

Dear Mandy

Our registration as an IAP is attached.

Kind regards,

Grant SmithEstuary Projects CoordinatorSource to Sea Programme

Endangered Wildlife TrustW + 27 21 799 8458 | C + 27 84 3281001Email: grants@ewt.org.za | Web: www.ewt.org.za | Skype: itisgrantORM Project Overview: http://ewt.org.za/SOURCETSEA/Orange%20Senqu%20River%20Basin.html

From: Mandy Kula [mailto:mkula@slrconsulting.com] Sent: Wednesday, August 16, 2017 10:55 AMTo: Mandy Kula Subject: 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

mailto:grants@ewt.org.zamailto:mkula@slrconsulting.commailto:grants@ewt.org.zahttp://www.ewt.org.za/http://ewt.org.za/SOURCETSEA/Orange%20Senqu%20River%20Basin.html

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 “PSJV”), 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