1. INTRODUCTION and Tourism (MET). An EIA process will be … · 2019. 12. 10. · 1 1. INTRODUCTION and Tourism (MET). An EIA process will be conducted Cathral Investments Ninety

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1. INTRODUCTION

Cathral Investments Ninety One (Pty) Ltd (i.e. Cathral

Investments) holds EPL 6545, which is located in the

Lüderitz district, Karas Region approximately 50 km

northwest of Helmeringhausen (refer to Figure 1). EPL

6545 is approximately 34 600 hectares (ha) in size,

encompassing eight privately owned farms. The C27

Road crosses through the center of the EPL.

Tulela Processing Solutions (Pty) Ltd (i.e. Tulela), a

wholly-owned Namibian Metallurgical and Mining

company, holds majority shares in Cathral Investments.

Tulela intends to recover economical minerals from the

Sinclair ore body.

Cathral Investments / Tulela proposes to conduct further

exploration on the EPL, within the “area of interest”,

indicated in red in Figure 1. Furthermore, Cathral

Investments proposes to apply for a Mining Licence

(ML) from the Ministry of Mines and Energy (MME) for

mining; processing of the ore and associated activities.

The proposed ML area would cover a similar area to the

red block (in Figure 1), which is approximately 863 ha in

size.

This area of interest encompasses the “Sinclair Mine”,

where various companies have conducted exploration

and mining activities in the past. The Sinclair Mine is

situated on the Sinclair Farm.

2. ENVIRONMENTAL CLEARANCE

Prior to the commencement of the proposed Sinclair

Project activities, an application for an environmental

clearance will be submitted in terms of the

Environmental Management Act, 7 of 2007 and the

associated environmental impact assessment (EIA)

Regulations (January 2012) to the MME, as the

competent authority.

MME will review the application and relevant reports and

submit their comments to the Ministry of Environment

and Tourism (MET). An EIA process will be conducted

in terms of the above-mentioned Act and Regulations.

Namisun Environmental Projects & Development

(Namisun) has been appointed by Tulela as the

independent Environmental Assessment Practitioner to

undertake the EIA process for the proposed project.

3. PURPOSE OF THIS DOCUMENT

This document has been prepared by Namisun to inform

you about:

Previous activities at the Sinclair Mine (Section 5);

Proposed project activities (Section 6);

The EIA process (section 7);

the key environmental and social issues (i.e.

aspects and potential impacts) (Section 8); and

How you can register as an interested and /or

affected party (IAP) (sections 4 and 9).

4. PARTICIPATION IN THE EIA PROCESS

Public participation is an essential part of the EIA

process.

You have been identified as a possible IAP who may

want to be informed about the proposed project and

have input into the EIA process. All comments will be

recorded and addressed in the EIA process.

CATHRAL INVESTMENTS NINETY ONE (Pty) Ltd

EIA FOR SMALL SCALE MINING & PROCESSING ACTIVITIES AND ONGOING EXPLORATION AT

THE SINCLAIR MINE ON EXCLUSIVE PROSPECTIVE LICENCE (EPL) 6545, KARAS REGION

BACKGROUND INFORMATION DOCUMENT

HOW TO REGISTER AS AN IAP Please register as an IAP and submit any questions or

comments by means of the enclosed registration / comment sheet or through communication with

Namisun.

Attention: Werner Petrick E-mail address: [email protected]

Cell number: +264 (0)81 739 4591

If you would like your comments to be addressed in the Scoping Report please submit them by

27 September 2019.

mailto:[email protected]

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Sinclair Project

NAMISUN Environmental

Projects and Development

P.O. Box 8127, Swakopmund,

Namibia

E-mail:

[email protected]

Client: Tulela

LOCALITY MAP

Helmeringhausen

20 km

Legend:

Area of interest

EPL 6545

C27

C14

Sinclair Farm house

Sinclair Mine

Proposed Access Road

Figure 1: Regional Location of the Sinclair Project (Ref: Google Earth)

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Figure 2: Sinclair Project layout and infrastructure (Ref: Google Earth)

Sinclair Project

NAMISUN Environmental

Projects and Development

P.O. Box 8127, Swakopmund,

Namibia

E-mail:

[email protected]

Client: Tulela

Proposed

Infrastructure Layout

Plant Feed stockpile

200m

Legend:

Indicative Open Pit

DMS & Gravity Plant

VAT Leach Vessels area

Site office & workshopsSX, EW & Stripping

Water StorageProposed Access

Road

Box cut

VAT leach vessel areaPower station & Fuel storage

WRD

Sewerage System

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5. DESCRIPTION OF PREVIOUS AND PROPOSED

ACTIVITIES

5.1. PREVIOUS MINING AND EXPLORATION

ACTIVITIES AT SINCLAIR

Extensive exploration and mining programmes have

previously been carried out in this area.

The copper deposit was discovered and mined since

the mid-nineteenth century, when several ox wagon

loads of ore was hauled to the Prinzenbucht, a small

bay south of Lüderitz. (Ref: mindat.org):

Mining entrances around the hill, tracks, ore stockpiles

and old building foundations and rubble, amongst

others, are still visible, as rehabilitation work was only

carried out rudimentary.

Some of the historic work in the area is briefly listed

below (Ref: mindat.org):

1900s: First description of the deposit.

1912/13: Exploration and mining of the ore body

by the German Colonial Bergbaugesellschaft.

World War 1 put a halt to the mining.

1920s/30s: Exploration and mining resumed

under the South West Copper Company

(abandoned during the depression in 1932).

Since then, the deposit has been re-evaluated by

several companies including the African Metals

Corporation of South Africa (ISCOR) and Rio

Tinto.

Welwitschia Minerals and Hydrocarbons cc conducted

an EIA in 2017 and received an environmental

clearance from the MET in 2018 for small scale mining

and material handling at Sinclair. However, they’ve

conducted very little activities.

6.1 PHASE 1: PROCESS EXISTING SURFACE

STOCKPILES

Existing ore stockpiles (from historic mining activities)

are located at various locations around cuts into south-

west face of the hill, at Sinclair. Tulela proposes to

move all these ore stockpiles to a centralised location

(i.e. the ‘Plant feed stockpile’ on Figure 2). Excavators

and front end loaders will be used to relocate the small

stockpiles.

By moving these ore stockpiles away from their current

locations will allow Tulela to:

1. Process the ore to sell the copper product; and

2. Clear the areas for further exploration.

6. PROPOSED ACTIVITIES

No immediate blasting is required. However, in the

longer term, depending on the exploration results,

blasting might be required (refer to section 6.2).

6.1.1 Ore Processing

From the plant feed stockpile, the ore will first be

crushed via a mobile crushing plant; and thereafter

screened and treated via Dense Medium Separation

(DMS) and a spiral gravity circuit.

Two streams will be generated: 1.) A high grade

concentrate, which will be sold as product (i.e.

exported through the port of Lüderitz); and 2.) “Low

grade material” to be further processed.

Low grade material processing – Copper

extraction

Multiple VAT Leach Vessels (dams) will be constructed

in the area highlighted in light green in Figure 2. These

vessels will be constructed as required, i.e. as one

becomes redundant, it will be neutralised and the next

vessel constructed. Each vessel will be constructed on

ground surface and will have a footprint in the order of

2 500 m2 and would be ± 4 m in height.

The bottom and sides of the vessels will be lined with

a plastic lining and once it has been filled with the low

grade ore, it will also be covered (on top) with a plastic

lining. Therefore, the ore will be encapsulated inside

the plastic lining, ready to be treated.

An alkaline solution will be added to the encapsulated

ore. The leached copper-bearing solution (“PLS”) will

be pumped to the proposed solvent extraction (SX)

section and electro winning (EW) processing plant

where copper plates will be produced. The alkaline

solution will be recycled and pumped back as a

“raffinate stream” into the VAT leach vessel.

Low grade material processing – Gold / silver

extraction

The process will make provision to possibly recover

small quantities of gold and silver post the extraction

of the copper. Cyanide solution will be added to the

encapsulated material. The gold / silver-bearing

solution will be extracted; filtered and precipitated. The

VAT will be neutralised post the extraction process.

6.2 PHASE 2: FURTHER EXPLORATION, MINING

AND PROCESSING OF MINED ORE

6.2.1 Exploration

The further exploration for copper (and gold / silver)

mineral will be done on the Sinclair mine area (only),

within the red area indicated in Figure 1. The

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exploration activities will be conducted in parallel with

phase 1 of the project, as the existing ore stockpiles

are removed from their current locations.

An exploration crew will be set up to commence with

extended resource drilling in the above mentioned

target area. As the resource is partially exposed on the

surface, a box cut sample will also be taken

(highlighted in light blue in Figure 2) by further

excavation of the existing cut in the hill. The size of the

box cut will be determined as the exploration

progresses.

The following machinery/vehicles will be utilized in the

drilling program:

One Light Duty Vehicle (LDV) (i.e. 4x4 Vehicle)

Two Drill Rigs (one Reverse circulation (RC) Drill

and one Diamond Drill)

One excavator and one loader for the box cut.

It is anticipated that five people will be permanently

employed, of which three will be skilled, to carry out the

above-mentioned activities.

5.2.2 Mining

Tulela proposes to conduct relatively “small scale”

mining activities at the existing Sinclair Mine, which is

dependent on the future exploration results.

The possible mine pit footprint is indicatively illustrated

in yellow in Figure 2 and could be ±7.8 ha in size. The

open cast mining would be undertaken to depths

ranging between ± 5 and 30 m depending the

exploration results.

As per conventional open pit mining, this would include

drill and blast followed by load and haul activities.

The following machinery/vehicles will be utilized in the

mining activities:

One Dozer

One Excavator

Two Loaders

Four articulated Dump Trucks (30 ton each).

Waste rock would be disposed of at an area

(indicatively) illustrated as the WRD (i.e. waste rock

dump) in Figure 2.

5.2.3 Processing of the mined ore

The future mined ore (from the open pits and

potentially from the box cut) will be hauled to the ‘Plant

feed stockpile’ and similarly processed in the proposed

(multiple) VAT leach vessels and SX, EW & Stripping

Plant, as described in Section 6.1.

The estimated feed rate of ore to the DMS would be ±

50 t/hr and 38 t/hr to the VAT leach vessels.

6.3 WATER SUPPLY

Approximately 50 m3 per annum of water will be used

for exploration and 40 000 m3 per annum (excluding

for human consumption) for the mining and processing

activities.

Water will be sourced from nearby borehole(s) on the

farm within the area of interest.

5.2.4 Power Supply

Because of the remote site, the entire site will be

powered by diesel generators.

5.2.5 Site Access

A new road is to be graded. The proposed new site

access route is indicatively illustrated in Figure 1 in

black.

5.2.6 Employment and accommodation

Construction Phase

Approximately 50 people will be required over the ± 4

month construction period to construct the processing

plant.

For the construction phase of the project about 70% of

the crew is expected to be skilled. It is estimated that

80 % will be contractors.

Operational phase

Approximately 30 people will be required for the

operational phase of the project, of which 80% to be

skilled. It is estimated that about 70% will be fix term

contractors and 30% permanent.

A 4 shift cycle team of 5 people per shift will be

required, including the supervisor.

Three options are currently being evaluated to

accommodate the work crew:

Utilising a site base camp on the mining lease;

Accommodation on the adjacent farm; or

Accommodation in Helmeninghausen.

Both operational cost and safety risks of extended

travel distances to town will be considered.

5.2.7 Transportation

Chemicals will be trucked to site from Lüderitz or RSA.

The final metal product will be trucked to Lüderitz for

shipment to the end client.

5.2.8 Life of mine

The life of mine is expected to be between 14 and 24

months. This might however increase, depending on

future exploration results.

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6. EIA PROCESS

The main objectives of the EIA process are to:

Provide information on the proposed project

activities and facilities / infrastructure;

Describe the current environment in which it will

be situated;

Identifies, in consultation with IAPs, the potential

negative and positive environmental (and social)

aspects;

Assesses the associated potential impacts of the

proposed project; and

Report on measures required to avoid impacts or

mitigate such impacts to acceptable levels.

The likely process steps and timeframes of the EIA

process are provided in Table 1.

Table 1: EIA Process for the proposed Sinclair

Project.

STEPS IN THE EIA PROCESS

PHASE I: Project initiation & Internal Screening (August - September 2019)

EIA project initiation.

Notify MME and MET through the submission of the EIA Application Form and online (MET) Registration.

Site visit and identify environmental issues.

Identify key stakeholders.

PHASE II – Combined Scoping & Assessment Phase and Environmental Management Plan

(EMP) (September – November 2019)

Notify other regulatory authorities and IAPs of the proposed project (via newspaper advertisements, this document, emails, site notices).

Conduct public meeting (see details provided) and key stakeholder (focus group) meetings.

Carry out specialist investigations.

Assess the potential impacts of the proposed Sinclair project activities and compile a Scoping (including assessment) Report and EMP.

Distribute the EIA reports for review and comment by regulatory authorities and IAPs.

Consider comments received and compile the final reports (including an Issues and Response Report).

Submit the final reports to MME and MET for their review and decision-making.

A draft Scoping Report (including an assessment of

impacts) and an Environmental Management Plan

(EMP) for the proposed project will be made available

for public review / comment. Registered IAPs will be

notified via e-mail of the review period and the

availability of the draft Scoping Report (including impact

assessment) and EMP.

The final Report, along with all IAP comments, will be

submitted to the Ministry of Mines and Energy (MME)

for their review and recommendation, after which it will

be forwarded to MET (Environmental Commissioner)

for their review and a final decision.

7. KEY ISSUES RELATED TO THE PROPOSED

EXPLORATION, SMALL SCALE MINING AND

PROCESSING ACTIVITIES

Potential environmental issues (i.e. aspects / potential

impacts), that need to be assessed as part of the EIA,

associated with the proposed Sinclair Project, include:

Groundwater and Surface water impacts:

Groundwater contamination; lowering of

groundwater level due to pumping from on-site

borehole(s); alteration of drainage patterns and

pollution of surface water.

Air Quality:

Potential air pollution as a result of dust from

exploration and mining activities, i.e. trucks,

machinery, blasting, etc., impacting on third

parties’ health and causing nuisance.

Noise:

Increase in ambient noise causing

disturbance/nuisance.

Biodiversity:

Physical destruction and general disturbance of

biodiversity.

Archaeology:

Destruction and damage to archaeological sites

and landscapes.

Socio-economic:

Potential negative impacts on current

(surrounding) land use activities; health and

safety concerns to nearby land owners;

nuisance-related disturbance; impacts relating to

mining staff on site.

Positive economic impacts associated with

income and employment.

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8. INVITATION TO REGISTER AND COMMENT

Please complete the enclosed registration/comment

form or contact Namisun to register as an IAP.

For comments to be included in the Scoping (including

Impact Assessment) Report they must reach Namisun

by no later than 27 September 2019.

9. INFORMATION SHARING MEETING

6. K

You are invited to attend the following information-sharing meeting:

Date: 2 October 2019

Location & venue: Sinclair Farm Homestead

Time: 9:00 am

DMS and Spiral Supply

Leach Feed

VAT Leaching

Ammonium Makeup

WaterAmmonium

Reagent

Cyanide Dilution

Water Cyanide

Reagent

SXExtraction

SX PLS Feed

SXStripping

Electrowinning

Cu

Plates

Gold Extraction

Precipitation

PLS

Zn Dust

Ore Concentrate

Mined Ore

Water

Metal

Concentrate

Neutralising Reagent

Sulphuric

Acid

Water

Organic

Supply

Impurity

Bleed

Figure 3: Conceptual Process Flow Diagram

CATHRAL INVESTMENTS NINETY ONE (Pty) Ltd



IAP REGISTRATION AND COMMENTS FORM

DATE:

IAP PARTICULARS:

NAME AND SURNAME:

ORGANISATION:

E-MAIL:

TEL & CELL PHONE NUMBERS:

PLEASE IDENTIFY YOUR INTERS IN THE PROPOSED PROJECT:

PLEASE PROVIDE YOUR COMMENTS / QUESTIONS:

From: Werner Petrick [mailto:[email protected]] Sent: Monday, 16 September 2019 12:05 Subject: NOTICE OF EIA PROCESS: PROPOSED SMALL SCALE MINING & PROCESSING ACTIVITIES AND ONGOING EXPLORATION AT THE SINCLAIR MINE Dear Sir/Madam This email and attached background information document (BID) provides formal notification

that Cathral Investments Ninety One (Pty) Ltd is in the process of applying for a Mining

Licence (ML) from the Ministry of Mines and Energy (MME) for mining and associated

activities at the Sinclair Mine.

Tulela Processing Solutions (Pty) Ltd (i.e. Tulela), a wholly-owned Namibian Metallurgical

and Mining company, holds majority shares in Cathral Investments. Cathral Investments /

Tulela proposes to process existing surface ore stockpiles from historic mining activities; and

to conduct further exploration, mining and processing (of future mined ore) activities, to

extract copper and to possibly recover small quantities of gold and silver, at the Sinclair

Mine.

Prior to conducting the proposed activities, an Environmental Impact Assessment (EIA) process will be conducted and an application for an environmental clearance certificate will be submitted to the MME as the competent authority who will review and forward the application to the Ministry of Environment and Tourism (Environmental Commissioner) in terms of the Environmental Management Act, 7 of 2007 and Regulations 19 and 21 of the EIA Regulations (January 2012). The Sinclair Mine is located in the Lüderitz district, Karas Region, approximately 50 km

northwest of Helmeringhausen, on the Sinclair Farm. Extensive exploration and mining

programmes have previously been carried out at the Sinclair Mine by various companies.

Namisun Environmental Projects & Development (Namisun) has been appointed by Tulela as

the independent Environmental Assessment Practitioner to undertake the EIA process for the

proposed project.

Registration to receive notifications and information:

If you would like to register as an Interested and/or Affected Party (IAP) with Namisun,

please submit your comments, full name and contact details by email, or by contacting the

undersigned. The attached BID is available for a review and comment period until 27

September 2019.

An information-sharing meeting will be held at the Sinclair Farm:


Location & venue:

Sinclair Farm Homestead

Time: 9:00 am

For questions, issues and/or comments to be included in the EIA Scoping (including Impact

Assessment) Report, please forward them to Namisun by no later than 27 September

2019.

Yours sincerely

Werner Petrick +264 (0)81 739 4591

From: Werner Petrick [mailto:[email protected]] Sent: Thursday, 31 October 2019 14:12 Subject: EIA FOR THE PROPOSED SMALL SCALE MINING & PROCESSING ACTIVITIES AND ONGOING EXPLORATION AT THE SINCLAIR MINE Dear Sir / Madam

EIA FOR THE PROPOSED SMALL SCALE MINING & PROCESSING ACTIVITIES AND

ONGOING EXPLORATION AT THE SINCLAIR MINE, KARAS REGION - 50 KM

NORTHWEST OF HELMERINGHAUSEN

With reference to earlier correspondence regarding the above mentioned project and EIA

process, please be advised that the Environmental Impact Assessment (EIA) Scoping &

Assessment Report and Environmental Management Plan are now available for review and

comment.

A hard copy and an electronic copy of the full report (including all Appendices) are available

at the Sinclair Farm Homestead from the 6th of November 2019.

Attached, please find the Main Report (excluding Appendices). An electronic copy of the full

report is also available on request to Namisun.

Please send any comments you might have on the report to the undersigned by 15

November 2019.

Yours sincerely,

Werner Petrick +264(0)81 140 5968

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MINUTES OF FOCUS GROUP MEETING 1:

Sinclair Farm Owner

MEETING DETAILS

DATE 10 September 2019

TIME: 14:00

VENUE: Telecom

PROJECT: Sinclair Project

PURPOSE: The purpose of the meeting was to:

Inform the Sinclair Farm Owner about:

The proposed project activities;

The Environmental Impact Assessment (EIA) process being followed;

To agree on the date, time and venue for the public meeting; and

How interested and/or affected parties (IAPs) could participate in the

EIA process.

Discuss potential environmental impacts.

Obtain initial input from the Sinclair Farm Owner on issues and concerns,

and input on environmental sensitivities and potential impacts.

ATTENDANCE: Mr. Marc Pampe (Sinclair Farm owner)

Mr. Philip Badenhorst (Tulela Processing Solutions (Pty) Ltd)

Mr. Werner Petrick (Namisun Environmental Projects & Development)

1. OPENING OF THE MEETING AND GENERAL INTRODUCTION

Werner Petrick (WP) welcomed all to the meeting and WP and Philip Badenhorst (PB) introduced

themselves to Marc Pampe (MP). This was followed by a short introduction, which included:

The objectives of the meeting

Brief explanation of the EIA process being followed, the EIA Team, etc.

2. PRESENTATION

Due to the fact that it was a telecom meeting, a formal presentation was not made. However, the

Background Information Document (BID), which WP send to MP before the meeting, was used as the

basis for the discussion. WP and PB provided an overview of the proposed project activities, EIA

process and key environmental issues, by referring to the BID.

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3. DISCUSSION (QUESTIONS AND ANSWERS)

MP raised a number of questions / comments / issues during the meeting. These have been recorded

in the attached table (refer to Appendix 1). The responses provided by either WP or PB are also

recorded in the table.

4. THE WAY FORWARD

WP outlined the way forward as follows:

MP will send a list of neighbouring farmers with contact details to WP.

WP will update his IAP database with the above information and distribute the BID to all IAPs on

the database (via e-mail).

MP will send further comments in writing (if any) soonest (but before 27 September 2019).

A public meeting will be held at the Sinclair Farm Homestead on the 2nd of October 2019

(9:00am). WP will invite IAPs to the meeting through the newspaper advert and e-mails that will

be sent to IAPs.

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APPENDIX 1: Questions / Comments / Concerns raised by MP and responses provided by WP and PB

No. Questions / Comment / Issue raised Response

1 Will the copper be in the solution coming from the

VAT System?

Yes. An alkaline solution will be added to the encapsulated ore. The leached

copper-bearing solution will be pumped to the processing plant where copper

plates will be produced.

2 Is it a Closed Cycle? With the solution therefore be

pumped back into the VAT?

Yes. The alkaline solution will be recycled and pumped back into the VAT leach

vessel.

3 After neutralising the material inside the VAT, what

will happen with the solution? Will there be any

discharge of the “Neutralised solution” into the

environment”?

Multiple VAT Leach Vessels (dams) will be constructed. As one becomes

redundant, it will be neutralised and the next vessel constructed. The neutralised

solution will also be pumped from the “redundant VAT” to the new one.

4 What happened at the last / final VAT. Will the

“neutralised solution” from this VAT have to be

discharged?

The decision regarding the final VAT and the discharge from this VAT still need to

be confirmed. A possibility would be that a small evaporation pond will have to be

constructed next to the last VAT and the “neutralised solution pumped to this

evaporation pond.

5 Can one VAT be used than once?? Each VAT will only be used once for the copper extractions and thereafter

(possibly) for the gold / silver extraction.

The soil will therefore remain, encapsulated, indie the plastic liners (i.e. plastic

lining on all sides). Once neutralised, it will therefore remain as is.

If this soil were to be removed, there would be a danger in damaging the liner and

the soil/slurry will have to be disposed of at a new “tailings storage facility.

6 Will the plastic line stay behind after the VAT become

redundant?

My concern is that the plastic will demolish from the

sun and be blown around.

The “Neutralised soil / slurry will remain inside the VAT. Therefore, the only plastic

lining that will be exposed will the top part that covers the soil/slurry.

Once redundant, the plastic liner will have to be covered with soil / topsoil and

vegetation growth allowed. This would form part of the rehabilitation strategy.

7 Is it therefore part of th planning to add soil on top of

the VAT?

Yes. The exact timing in terms of covering the VAT with soil still needs to be

confirmed though (i.e. during or after the operations of the VAT).

8 Will there be any harmful chemicals staying behind?

Howe affective will the neutralization be?

The soil/slurry inside the VAT will be flooded and this should be 100% affective.

4

No. Questions / Comment / Issue raised Response

9 I see diesel generators will be used for power supply.

I am concerned about the noise from the generators.

Will make noise also at night?

The electro winning and SX will run 24/7. None of the other activities(i.e. earth

moving activities, crushing, etc.) will be undertaken during the night time.

The generators will however have to run 24/7. The diesel generators will be

enclosed in a container to minimize the noise.

A noise specialist was appointed as part of the EIA team to assess the potential

noise impacts from the proposed activities and provide management and

mitigation measures regarding these issues.

10 Will the activities be 24/7? Concerned about noise at

night.

11 Will the further explanation only entail drilling, or will

there also be further trenching.

Only drilling and a box cut sample will be taken by further excavation of the

existing cut in the hill.

12 Will holes be covered up attention drilling The boreholes drilled need to be covered, however, it must still be acceptable for

possible future monitoring.

13 How high will the waste rock dump (WRD) be? Will

this be a new mountain?

The only material that will be disposed of at such a WRD facility will be overburden

from the mining activities. The volumes of WRD still needs to be estimated.

Another options would be to backfill the mine pit with the waste rock.

14 My biggest concern is water. What is the maximum

volume of water that will be required?

Max 40 000 m3 per annum would be required (for phase 1 and 2). The same plant

will be used for processing the mined ore during phase 2 and it is designed to

handle a specific throughput.

15 How will the housing for the workers be handled. The housing for the workers still need to be confirmed. Either way, Tulela is

considering temporary infrastructure. This could possibly be a business opportunity

for someone to provide the housing to the workers.

1



MINUTES OF MEETING:

Public Meeting

MEETING DETAILS

DATE 02 October 2019

TIME: 14:00

VENUE: Sinclair Farm Homestead

PROJECT: Tulela Processing Solution: Sinclair Project – EIA Process

PURPOSE: The purpose of the meeting was to:

Provide a description of the proposed “Sinclair Project” activities

Provide a description of the EIA process

Provide IAPs with further opportunity to be involved in the EIA

Identify any potential environmental issues and impacts

Describe the way forward, highlighting further opportunities to be involved

in the EIA process.

ATTENDANCE: Refer to Appendix 2.

1. OPENING OF THE MEETING AND GENERAL INTRODUCTION

Werner Petrick (WP) from Namisun Environmental Projects and Development introduced himself as the

independent environmental practitioner, conducting the EIA process, and welcomed all to the meeting.

Philip Badenhorst (PB) (Tulela Processing Solutions (Pty) Ltd) and Arnold Bittner (AB) (SLR

Environmental Consulting (Pty) Ltd) - Water Specialist and part of the EIA Team) introduced

themselves.

This was followed by a short introduction by WP, which included:

The meeting procedure and objectives of the meeting.

General introduction to the project and brief explanation of the EIA process being followed, the

EIA Team, etc.

2. PRESENTATION

A formal PowerPoint presentation was made, as follows:

• A description of proposed project activities by PB.

• The EIA process and key potential environmental issues identified to the date of the meeting by

WP

• Background and initial study findings of the ground water supply and related issues by AB.

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3. DISCUSSION (QUESTIONS, COMMENTS AND ISSUES RAISED)

The meeting attendees (i.e. interested and affected parties) raised a number of questions / comments /

issues during the meeting. These have been recorded in the attached table (refer to Appendix 1).

Responses provided in the meeting are not captured as part of this minutes of the meeting. A separate

Comments and Response Report (CRR), incorporating all questions / comments / issues raised

throughout the EIA process (including those raised in the meeting) is attached as Appendix B to the EIA

Scoping & Assessment Report.

4. THE WAY FORWARD

WP outlined the way forward as follows:

Comments received to date and during this meeting will be considered and included in the Draft

EIA Scoping & Assessment Report, where relevant.

The Draft Report will be distributed for comment towards mid-October 2019.

It was agreed in the meeting that the review will be conducted as follows:

o A two week review period will suffice.

o The Main EIA Scoping & Assessment Report (excluding Appendices) will be sent per e-

mail to all attendees (and other registered IAPs).

o One hard copy and one electronic copy of the full report (including all Appendices) will

be made available at the Sinclair Homestead for review by all IAPs.

3

APPENDIX 1: QUESTIONS / COMMENTS / ISSUES RAISED BY IAPS (REFER TO THE CRR, ATTACHED TO THE EIA SCOPING & ASSESSMENT REPORT,

FOR REPONSES TO ALL QUESTIONS / COMMENTS / ISSUES RAISED THROUGHOUT THE EIA PROCESS)

No. Questions / Comment / Issue raised

1 Is there a feasibility study? Is the project Economically feasible?

2 What method did you use to assess, explore & determine the feasibility?

3 Where is the Sinclair homestead located in relation to the mine?

4 Explain the difference between VAT leach and Heap leach.

5 What is meant with agglomeration??

6 Will water to the mine come from the ground?

7 Where will you add an acid solution?

8 How high is the VAT/Leach facility? What will be the overall dimensions of the VAT/Leach facility be?

9 What volumes of crushed material will go onto each VAT?

10 The Background Information Document (BID) mentioned DMS and Spirals. Where are those (not mentioned in the presentation)?

11 Why were these taken out?

12 What is the difference in permeability between the current stock piles future mined ore?

What will the difference be in particle size?

13 Will you screen the material before it goes onto the VAT/leach facility?

14 Without agglomeration you will not get permeability.

15 How was the sampling done? How many samples were taken?

16 Once leaching is done how will the VATs be closed and rehabilitated?

17 A Mine Closure Plan (including closure costing) needs to be developed. A key issues is, should the project not be feasible, there needs to be budget for

properly closing the mine and conducting effective rehabilitation.

4


18 Topsoil needs to be removed prior to the construction activities / clearing of areas; separately stockpiled and used during the rehabilitation at closure. Also, to

get the rehabilitation “going” the topsoil (once placed back) might require some water.

19 Will the material in the VATs be neutralised? How will the neutralising differ between the Acid and Alkaline leaching processes?

20 Is Tulela happy with one bakkie load as a representative sample?

It is not a representative sample of the area – it is a risk.

21 Will all material be crushed & Screened. How long does the crushing & screening take? Will it be done 24/7?

22 Why conduct exploration after processing starts? This seems to be the wrong way around.

23 Will it be entirely an open pit?

Why one big open pit? It should rather be various smaller pits / box cuts along the areas where the ore is found due to the fact that there will likely be various

areas between the ore veins without any ore.

24 Does the processing remain the same for phase 2?

25 Concerned about the noise from the electricity generators.

26 How much power is required?

27 There are various endemic biodiversity species in the area and they are seasonal. It is currently a bad time of the year for plants as there are were no rains

yet. Locals need to look at the species list.

28 Tourism is important for the area.

29 Will you use existing boreholes or drill new ones for the water supply to the mine?

30 The proposed new borehole location is a good location for groundwater monitoring.

31 We are concerned about the water abstraction as the mine will be pumping for many days/ weeks/months. How will this impact the other groundwater users

in the area?

32 The water table is a concern. The water requirements for the mine is an order of magnitude difference of water used by farmers. Also, the average rainfall in

the area is very low and we are concerned about the recharge of the groundwater.

Neighbouring could be affected. Should the groundwater monitoring not also be extended to neighbouring farms as well?

5


33 The groundwater abstraction could be a long term impact, extending beyond the operations of the mine.

34 Ideally long term monitoring data is required.

35 An independent person should do the monitoring.

36 The EPL holder is Cathral Investments. Do they do other project as well?

37 Does Tulela have 3rd party insurance in terms of liabilities?

I.e. field fires, water losses, etc.

38 After mining, what will happen? There must be a funds for mine closure / rehabilitation from the beginning of the project.

39 Where will water be stored?

40 What chemicals will be used and where will chemicals be stored?

41 Is there no low grade stockpile / dump?

42 Will there be Crushing plant?

43 There is lots of quarts that could damage the crusher.

44 What will be the width and depth of the box cut? There might be lots of waste?

45 What will be the tonnage of ore from box cut?

46 What grade is expected?

47 The BID referred to “ore stockpiles”. That is wrong terminology. Is should be regarded as “waste dumps” with some copper.

48 It is on record that the ore reserve estimate is 3%. Valuable ore have been “hand-picked already by historical mining activities.

There is a risk that too little samples were taken by Tulela to determine whether it will be a feasible project.

The risk lies in the fact that, if there is no income from the project, there will also be no money for rehabilitation - as part of closure.

There needs to be a fund for the closure / rehabilitation.

49 What are the copper minerals?

6


50 Gold would be negligible.

51 How long will the liners in the VAT/ Leach facility last?

52 Will there be dust suppression on the crushers?

53 Will the material stay in the VATs?

54 What is the expected copper recovery?

55 What will be used to neutralise the material in the VATs?

56 From where will the neutralising material come?

57 Will calcrete from the area be used the neutralise the VAT? If this is mined, what will be the impacts?

58 What will happen with final effluent from the VATs?

59 How long will the alkaline leaching take in one VAT?

60 Will permeability play a role in leaching process?

61 How long will the acid leaching take in one VAT?

62 What will the average grades left behind in VATs?

63 What neutralising agent will be used for the VATs?

64 What if the grade of gold and silver is not good?

65 If recovery of copper is much lower than expected but precious metals is good, will you then process this only?

66 Will there be no slimes dam (i.e. Tailings storage facility)?

67 What will happen with the final effluent coming out of the process – any discharge to the environment?

68 The MAWF will have to be part of the EIA.

69 Land use needs to be considered in the EIA?

70 Will the geology be described?

7


71 Will there be dust suppression?

72 Workers might be an issue regarding community safety. Also, drug use and dealing with drugs s are issues in the area.

73 All potential impacts must be considered as part of the EIA and management and mitigation measure developed in included in an EMP.

8

APPENDIX 2: ATTENDANCE REGISTER

2019/12/02

1


SINCLAIR MINE ON EPL 6545

2 October 2019

1

Public Information Sharing Meeting

Sinclair Farm Homestead

Agenda

2

• IntroductionMeeting ProcedureObjectives of the meeting General introduction

• Description of proposed project activities• EIA process• Key potential environmental issues• Question and answer session • Way forward and closure

Meeting Procedures

3

• Opportunity to ask questions / give comments• Minutes are being taken• Please sign the Attendance Register

Objectives of the meeting

4

• Provide a description of the proposed “Sinclair Project” activities

• Provide a description of the EIA process

• Provide IAPs with further opportunity to be involved in the EIA

• Identify any potential environmental issues and impacts

• Describe the way forward, highlighting further opportunities to be involved in the EIA process

General Introduction

5

• Cathral Investments Ninety One (Pty) Ltd holds EPL 6545 34 600 ha in size.

• Tulela Processing Solutions (Pty) Ltd (i.e. Tulela), a wholly-owned Namibian Metallurgical and Mining company, holds majority shares in Cathral Investments.

• Tulela intends to recover economical minerals from the Sinclair ore body.

General Introduction

6

• Cathral Investments proposes to:Conduct further exploration on the EPL, within the “area of interest”Apply for a Mining Licence MME for:

• Mining; • Processing of the ore and associated activities

ML area would be ± 863 ha Encompasses the “Sinclair Mine”, where various companies have

conducted exploration and mining activities in the past. The life of mine: ± 14 and 24 months (might however increase,

depending on future exploration results).

2019/12/02

2

7 8

Project Description

9

• Phase 1:Process existing surface stockpiles

• Phase 2:Further exploration, mining and processing of mined ore

Project Description: Phase 1

10

• Move existing “ore stockpiles” to a centralised location with excavators and front end loaders

Process the ore to sell the copper product

…This will Clear the areas for further exploration.

Project Description: Ore Processing

11

Sinclair Project

Crushing & Screening

Leach Feed

VAT Leaching

Leach ReagentMakeup

Water Leach Reagent

Cyanide Dilution

Water Cyanide Reagent

SXExtraction

SX PLS FeedRaffinate return to VAT

SXStripping

Loaded OrganicStripped Organic

Electrowinning

Loaded ElectrolyteStripped Electrolyte

Cu Plates

Gold Extraction

Pregnant Solution

Barren Solution

Zn Dust

Mined Ore

Metal Concentrate

Neutralising Reagent

Sulphuric Acid

Water

Organic Supply

Impurity Bleed

12

Crushing and Screening

Plant feed stockpile

Site offices & workshops Water Storage

SX, EW & Stripping

2019/12/02

3

Project Description: Ore Processing – Leaching Alternatives

13

Dump Leach Heap Leach In-Situ Leach VAT Leach Tank LeachCrushing Yes Yes No Yes YesAgglomeration No Yes No No NoMilling No No No No YesTailings Dam No No No No YesWater Required High High High Low HighWater Recycling Med Low Med High LowEnergy Required Low Med Low Low High

Tulela AdditionCover

RequiredSpecial Conditions Required? No No

Impermeable Layer No No

Residence Time High High High High LowPerformance Medium Med - High Med - High Med - High High


14

• Tank Leach: • High capital cost and water required.

• Heap leach:

• Surface area of the heaps require a considerable amount of water addition due to evaporation.

• VAT leach: • VAT is typically flooded with leached solution.


15

• Hybrid VAT / Heap leach: • VAT is drip irrigated with leached solution.

• To reduce water consumption and foot print - combined the VAT and heap leach concept

• Added plastic cover - reducing water locked up in the ore; reduce water evaporation significantly.

• Acid leach being considered.

Project Description: VAT Leach System design

16

Side and bottom

Plastic lining

Top Plastic lining

Drip Irrigation

(Drawing not to scale)


17

Exploration• Further exploration for copper (and gold / silver) mineral will

be done on the Sinclair mine area (only): Extended resource drilling.A box cut sample - further excavation of the existing cut in the hill.


18

Mining• Relatively “small scale” mining activitiesDependent on the future exploration resultsConventional open pit mining (i.e. drill and blast followed by

load and haul activities)One DozerOne Excavator Two Loaders Four articulated Dump Trucks (30 ton each)

• The possible mine pit footprint: ±7.8 ha in size• Open cast mining to depths ranging between ± 5 and 30 m

depending the exploration results• Waste rock would be disposed of at the WRD (i.e. waste

rock dump)

2019/12/02

4

19


20

Processing of the mined ore• Future mined ore will be hauled to the ‘Plant feed stockpile’

and similarly processed in the proposed (multiple) VAT leach vessels and SX, EW & Stripping Plant, as previously described.

• Estimated feed rate of ore: ± 50 t/hr to the crusher and thereafter to the VAT leach area

Project Description: Water supply

21

• Exploration: ±50 m3 / annum • Mining and processing: (estimate) 40 000 m3 / annum

(90 - 120m3/day)• Water will be sourced from nearby borehole(s) on the farm.

Project Description: Power supply

22

• The entire site will be powered by diesel generators.

Project Description: Site Access

23

• A new road is to be graded.

Project Description: Employment & Accommodation

24

Construction Phase• ± 20 people (estimated)• ± 4 month construction period.

Operational phase• ± 20 people (80% skilled. It is estimated that about 70% will be

fix term contractors and 30% permanent). • A 4 shift cycle team of 5 people per shift will be required,

including the supervisor.

Accommodation • Three options:

Site base camp on the mining lease; Accommodation on adjacent farm; orAccommodation in Helmeninghausen.

2019/12/02

5

EIA Process

25

Aug - Sept ’19

Screening & initiation

Sept – Oct ‘19

• Registration period, advertise,distribute BID, etc. receive initial comments

• IAP meetings

Oct ’19

Finalise specialist investigations

EIA Scoping & Assessment

Report and EMP

Oct ’19

IAPS review of reports

Nov ’19

Finalise reports with

IAP comments & submit to MME & MET

Authority review and decision-making

Key Potential Issues

26

Groundwater and Surface water impacts: • Groundwater contamination; • lowering of groundwater level due to pumping from on-site

borehole(s);

Surface Water:• Alteration of drainage patterns and pollution of surface

water.


27

Air Quality: • Potential air pollution as a result of dust from exploration and

mining activities, i.e. trucks, machinery, etc., impacting on third parties’ health and causing nuisance.

Noise: Increase in ambient noise causing disturbance/nuisance.


28

Biodiversity: • Physical destruction and general disturbance of biodiversity.

Archaeology: • Destruction and damage to archaeological sites and

landscapes.

Socio-economic:• Potential negative impacts on current (surrounding) land use

activities; health and safety concerns to nearby land owners; nuisance-related disturbance; impacts relating to mining staff on site.

• Positive economic impacts associated with income and employment.

Key Potential Issues: Groundwater - supply

29

Water supply from borehole WW70293• Test

pumping of WW70293

BH

Id

Test type

RWL

[m bgl]

PID

[m bgl]

Discharge rate

[m3/h]

Test Duration Max. WL drawdown

[m]

Residual drawdown

[m]Pumping Recovery

WW70293STD 24.89 35 2,3,5 3 0.32 0CDT 24.89 35 5 24 24 0.35 0

Borehole Id Maximum abstraction rate Expected pump water level

Pump inlet depth Use

m3/h hours/day1) m3/day [m bgl] [m]

Sinclair Windmill 10 12 120 28 35 Sinclair Mine

31

2019/12/02

6

Sinclair Mine Groundwater Monitoring• Planned drilling of 2 production/monitoring boreholes

30

Way Forward

32

• Comments received to date and during this meeting will be included in the Draft EIA Scoping & Assessment Report.

• Draft Report will be distributed for comment: Towards mid-October 2019.

Attention: Werner Petrick

E-mail address: [email protected]

Cell number: +264 (0)81 739 4591

Questions / Comments ?

33

NOTICE OF ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

PROPOSED SMALL SCALE MINING & PROCESSING ACTIVITIES AND ONGOING EXPLORATION AT THE SINCLAIR MINE, ±50 KM NORTHWEST OF HELMERINGHAUSEN, KARAS REGION.

Cathral Investments Ninety One (Pty) Ltd herewith gives notice in terms of the Environmental Management Act, 7 of 2007 and Regulations 19 and 21 of the Environmental Impact Assessment (EIA) Regulations (January 2012), of the proposed mining, processing, exploration and associated activities at the Sinclair Mine.

Prior to conducting the proposed activities, an EIA process will be conducted and an application for an environmental clearance certificate will be submitted to the Ministry of Mines and Energy (MME) as the competent authority who will review and forward the application to the Ministry of Environment and Tourism (Environmental Commissioner) in terms of the above mentioned regulations. This advertisement forms part of the EIA public participation process.

Applicant: Cathral Investments Ninety One (Pty) Ltd (i.e. Cathral Investments).

Nature and location of the proposed activity: The Sinclair Mine is located in the Lüderitz district, Karas Region, approximately 50 km northwest of Helmeringhausen, on the Sinclair Farm. Extensive exploration and mining programmes have previously been carried out at the Sinclair Mine by various companies.

Tulela Processing Solutions (Pty) Ltd (i.e. Tulela), a wholly-owned Namibian Metallurgical and Mining company, holds majority shares in Cathral Investments. Cathral Investments / Tulela proposes to process existing surface ore stockpiles from historic mining activities; and to conduct further exploration, mining and processing (of future mined ore) activities, to extract copper and to possibly recover small quantities of gold and silver, at the Sinclair Mine.

Independent Environmental Assessment Practitioner: Namisun Environmental Projects & Development (Namisun) has been appointed by Tulela as the independent Environmental Assessment Practitioner to undertake the EIA process for the proposed project.

Contact Person: Werner PetrickTel: +264 (0)81 739 4591E-mail: [email protected]

Registration to receive notifications and information: Register as an Interested and/or Affected Party (IAP) with Namisun by submitting your comments, full name and contact details by email, or by contacting Werner Petrick. A Background Information Document (BID) is available for a review and comment period from 13 to 27 September 2019. Electronic copies of the BID are available on request from Namisun as per above details.

An information-sharing meeting will be held at the Sinclair Farm:


Location & venue: Sinclair Farm Homestead

Time: 9:00 am

For issues and/or comments to be included in the Scoping Report forward them to Namisun by no later than 27 September 2019.

DM0201900345853_IK

EIA FOR SMALL SCALE MINING & PROCESSING ACTIVITIES AND ONGOING EXPLORATION AT THE SINCLAIR MINE ON

EXCLUSIVE PROSPECTIVE LICENCE (EPL) 6545, KARAS REGION

ISSUES AND RESPONSE REPORT

TABLE 1: COMMENTS / QUESTIONS / ISSUES RAISED DURING THE BID REVIEW AND REGISTRATION PERIOD AND DURING PUBLIC AND KEY STAKEHOLDER

MEETINGS

NO. COMMENT / QUESTIONS / ISSUE RAISED

NAME & ORGANISATION

METHOD RESPONSE

General / EIA process

G1 Welwitschia Minerals and Hydrocarbons received an environmental clearance from MET in 2018. How and why was this possible without public participation? Will the MET official responsible in 2018 just rubber stamp the current EIA again?

JDS Miller Email Cannot comment on the previous EIA process that was conducted. Refer to section 10 (Environmental Impact Statement and Conclusions) of the EIA report relating to the current EIA.

G2 If agreements are reached between the mine and the local community regarding any potential disruptions to the community’s daily activities and also long-term livelihood, how are these agreements monitored and enforced?

Contractual agreements will be signed, where relevant.

G3 Where is the Sinclair house located in relation to the mine?

Farm owners Public meeting (2nd of October)

Refer to sections 1.1 and 5.8.2.7 of the EIA Scoping & Assessment Report.


NAME & ORGANISATION

METHOD RESPONSE

G4 How much power is required? ±1 MW (EW use the most power). Refer to section 4.2.6 of the EIA Scoping & Assessment Report.

G5 The EPL holder is Cathral Investments. Do they do other project as well?

Cathral Invests is a consortium of investors for this project alone, although Tulela, as a majority shareholder, is involved in various other operational sites in the Africa Continent.

G6 Does Tulela have 3rd party insurance in

terms of liabilities?

I.e. field fires, water losses, etc.

Yes, this will be in place prior to the implementation of the project.

Noise

N1 I see diesel generators will be used for power supply. I am concerned about the noise from the generators.

Will it make noise also at night?

Marc Pampe (Sinclair farm owner)

Telephonic meeting (10th of September)

The electro winning and SX will run 24/7. None of the other activities (i.e. earth moving activities, crushing, etc.) will be undertaken during the night time. The generators will however have to run 24/7.

The diesel generators will be enclosed in a container to minimize the noise. A noise specialist was appointed as part of the EIA team to assess the potential noise impacts from the proposed activities and provide management and mitigation measures regarding these issues.

Refer to section 8.6 of the EIA Scoping & Assessment Report.

N2 Will the activities be 24/7? Concerned about noise at night.

N3 Concerned about the noise from the electricity generators.

Farm owner Public meeting (2 October 2019)

Technical issues (Processing, mining, exploration, etc.)


NAME & ORGANISATION

METHOD RESPONSE

T1 Will the further exploration only entail drilling, or will there also be further trenching.



Only drilling and a box cut sample will be taken by further excavation of the existing cut in the hill. Size of excavation will depend on the exploration outcome.

T2 Will holes be covered up after drilling With reference to the EMP, the Exploration boreholes should be capped.

The boreholes will be marked as it must still be accessible for possible future use.

T3 How high will the waste rock dump (WRD) be? Will this be a new mountain?

The only material that will be disposed of at such a WRD facility will be overburden from the mining and associated activities. The volumes of WRD is unknown at this stage.

However, an estimated ±100,000 ton waste rock might be produced. The height will be approximately 10 m.

T4 Where is the Sinclair homestead located in relation to the mine?

Farm owners Public meeting (2 October 2019)

Refer to sections 1.1 and 5.8.2.7 of the EIA Scoping & Assessment Report.

T5 Explain the difference between VAT leach and Heap leach.

A Combination of the two will be used in order to reduce fresh water consumption.

T6 What is meant with agglomeration? No agglomeration will be done as part of the process.

T7 Where will you add an acid solution? At the SX section of the process.

T8 How high is the VAT/Leach facility? What will be the overall dimensions of the VAT/Leach facility be?

±6 m (refer to section 3.1.2 of the EIA report).


NAME & ORGANISATION

METHOD RESPONSE

T9 What volumes of crushed material will go onto each VAT?

± 200,000tons.

T10 The Background Information Document (BID) mentioned DMS and Spirals. Where are those (not mentioned in the presentation)?

The process design has changed since the time the BID was developed. However, with reference to section 4.2.1.1, Tulela might in future change the design again to re-introduce the installation of the Dense Medium Separation (DMS) and a spiral gravity circuit for treatment of the screened material before leaching.

T11 Why were these taken out?

T12 Will you screen the material before it goes onto the VAT/leach facility?

Yes.

T13 Will the material in the VATs be neutralised? How will the neutralising differ between the Acid and Alkaline leaching processes?

Yes. Refer to section 4 of the EIA report.

T14 Will all material be crushed & Screened. How long does the crushing & screening take? Will it be done 24/7?

Yes. This will only be conducted during daytime hours.

T15 Why conduct exploration after processing starts? This seems to be the wrong way around.

These two processes would run in parallel (to a certain extent). Refer to section 4 of the EIA report.

T16 Does the processing remain the same for phase 2?

Yes.

T17 Will you use existing boreholes or drill new ones for the water supply to the mine?

New holes will be drilled, which will also be used for monitoring purposes.


NAME & ORGANISATION

METHOD RESPONSE

T18 What chemicals will be used and where will chemicals be stored?

Organic compounds and sulphuric acid / ammonia. Refer to the EMP requirements relating to storage of hazardous substances.

T19 Is there no low grade stockpile / dump? No.

T20 Will there be Crushing plant? Yes.

T21 There is lots of quarts that could damage the crusher.

Noted.

T22 What will be the width and depth of the box cut? There might be lots of waste?

This depends on the exploration results.

T23 What will be the tonnage of ore from box cut?

T24 What grade is expected?

T25 What are the copper minerals? Primary mineral is Malachite.

T26 Gold would be negligible. Noted.

T27 How long will the liners in the VAT/ Leach facility last?

The liners will not be exposed to the sun and is expected to last for decades.


NAME & ORGANISATION

METHOD RESPONSE

T28 Will the material stay in the VATs? Yes.

T29 What will be used to neutralise the material in the VATs?

Refer to section 4 of the EIA report.

T30 From where will the neutralising material come?

It will be purchased.

T31 Will calcrete from the area be used the neutralise the VAT? If this is mined, what will be the impacts?

No.

T32 What will happen with final effluent from the VATs?

It will evaporate in the ILS pond. The crystalized residue will be removed and disposed of at a licensed hazardous waste site. Refer to section 4.2.1.4 of the EIA Scoping & Assessment Report.

T33 How long will the alkaline leaching take in one VAT?

Unknown at this stage.

T34 Will permeability play a role in leaching process?

Yes.

T35 What will the average grades be left behind in VATs?

Unknown at this stage, however the target less than 0.5 %.

T36 What if the grade of gold and silver is not good?

Then it will not be processed.

T37 If recovery of copper is much lower than expected but precious metals is good, will you then process this only?

Yes.


NAME & ORGANISATION

METHOD RESPONSE

T38 Will there be no slimes dam (i.e. Tailings storage facility)?

No.

T39 During the operational phase, a 4 shift working cycle will be required. Does this mean that mining operations will be carried out throughout the night? What hours of operation are envisaged?

JDS Miller Email Refer to section 4.4 of the EIA report.

T40 Roy Miller Email Refer to section 4.3 of the EIA Scoping & Assessment Report and various related management plans in the EMP.

T41 How often do you sprinkle your leach dams before pumping to the SX plant?

Continuously.

T42 How and what with do you finally cover the leach dams once all leaching and neutralization is complete?

Refer to section 4.2 of the EIA report.

T43 You indicate that the leach dams will be covered during leaching. How then do you get the leach solutions into the crushed ore?

Drip irrigation will be used.

T44 How long before all cyanide is neutralized?

Unknown at this stage.

T45 What are the alkaline chemicals you use in the leaching dams?

Ammonia solution.

T46 How do you get effective penetration of the cyanide neutralizing solutions into the finely crushed waste in the leach dams?

Drip irrigation.


NAME & ORGANISATION

METHOD RESPONSE

T47 What are the daughter products of that neutralization process?

Nitrogen and water for Ammonia breakdown and also Nitrogen for Cyanide.

T48 With what do you neutralize the cyanide remaining in the leach dams?

SMBS.

T49 What do you precipitate Au and Ag with? Zinc dust.

T50 Will the alkali leach process release Au and Ag from the minerals that they occur in.

No. Alkaline is only used for copper leaching

T51 How often do you sprinkle your leach dams with cyanide before pumping out the leachate?

Continuously.

T52 Cyanide extraction – what cyanide compound do you use?

Thiocyanate solution.

T53 “Multiple VAT Leach Vessels will be constructed….” . How many?

JDS Miller Email Refer to section 4 of the EIA report.

T54 After DMS, the high grade concentrate will be sold as product, and the low grade material will go to the VAT leach dams. What is the tonnage of high grade concentrate expected to be, and what transport logistics will be required?

This process has changed since the BID was developed. Refer to section 4 of the EIA report.

T55 Will the copper be in the solution coming from the VAT System?



Yes.


NAME & ORGANISATION

METHOD RESPONSE

T56 Is it a Closed Cycle? With the solution therefore be pumped back into the VAT?

Yes.

T56 After neutralising the material inside the VAT, what will happen with the solution? Will there be any discharge of the “Neutralised solution” into the environment”?

The remaining solution will evaporated in the ILS pond.

T57 What happened at the last / final VAT. Will the “neutralised solution” from this VAT have to be discharged?

T58 Can one VAT be used more than once Each VAT will only be used once.

T59 Will the plastic line stay behind after the VAT become redundant?

My concern is that the plastic will demolish from the sun and be blown around.

The plastic liner will have to be covered with soil / topsoil and vegetation growth allowed. This would form part of the rehabilitation strategy.

T60 Is it therefore part of the planning to add soil on top of the VAT?

Yes.

T61 Will there be any harmful chemicals staying behind? Howe affective will the neutralization be?

Unlikely. The compounds will be in steady state.

T62 Will it be entirely an open pit? Why one big open pit? It should rather be various smaller pits / box cuts along the areas where the ore is found due to the fact that there will likely be various areas between the ore veins without any ore.

Farm owner Public meeting This is depended on exploration results. The EIA however assessed a “worst case scenario”.


NAME & ORGANISATION

METHOD RESPONSE

T63 What happens to this solution after EW extraction of the copper?

Roy Miller Email Recycled to SX.

T64 What happens to the cyanide solution after precipitation of the Au and Ag?

Recycled back to the VATs.

T65 What are your plans for avoiding slimes dam failures during operations and for decades into the future

There will be no slimes dams.

T66 What chemical is used to release the copper back into solution from the SX compound?

Sulphuric Acid.

T67 What happens to leachate solution after SX extraction of the copper?

Recycled back to the VATs.

T68 What compound is used for SX? Organic compounds.

T70 During the operational phase, a 4 shift working cycle will be required. Does this mean that mining operations will be carried out throughout the night? What hours of operation are envisaged?

JDS Miller Email Refer to section 4.4 of the scoping report.

Water

W1 There is not regional aquifer in the area. Roy Miller Email The potential impacts on groundwater (i.e. potential groundwater quality impacts and impacts due to groundwater abstraction) was assessed by the Water Specialist Team, i.e. SLR Environmental Consulting. Refer to Appendix G of the EIA Scoping 5.5 and 8.3 of the EIA report.

W2 Should this submitted proof be inaccurate, how will you compensate surrounding farmers for falling water


NAME & ORGANISATION

METHOD RESPONSE

tables in their boreholes and for drying up of boreholes?

The EMP also provide relevant management and mitigation measures and morning requirements.

W3 With the need for this amount of water, the Ministry of Agriculture, Water and Forestry (MAWF) must also be informed of your activities and plans and you will need their approval for the abstraction of that amount of water. This approval will depend on whether you can prove that water boreholes/wells in the area will not be affected by your abstraction. This proof that you give to MAWF must be part of you EIA report and must be circulated to all IAPs.

W4 Apparently, some pump tests have been done. We need to have the details of these tests sent to all IAPs before the meeting on the 2nd October. This MUST include all the graphics produced during the pump tests.

W5 There is no borehole in the area that comes anywhere near this daily requirement.

W6 With plant, human usage and exploration drilling you will need 125 m3 of water per day according to the numbers you present in your Background Information Document.

W7 With an estimated ore feed rate of 50t/hour, how much water will be required in the DMS stage of ore processing?

JDS Miller Email


NAME & ORGANISATION

METHOD RESPONSE

W8 Have any groundwater samples from the area been analysed yet to establish baseline values for the monitoring of the water quality? Is a monitoring program in place yet?

W9 The estimated water requirements of the project will have a devastating effect on the surrounding groundwater aquifer, exceeding the expected lifespan of the mine by far.

Thorsten Theile Email

W10 How is the wastewater treated and what measures are in place to avoid environmental contamination?

W11 Will water to the mine come from the ground?

Farm owners

Public meeting (2nd of October)

W12 The proposed new borehole location is a good location for groundwater monitoring.

W13 We are concerned about the water abstraction as the mine will be pumping for many days/ weeks/months. How will this impact the other groundwater users in the area?

W14 The water table is a concern. The water

requirements for the mine is an order of

magnitude difference of water used by

farmers. Also, the average rainfall in the

area is very low and we are concerned

about the recharge of the groundwater.

Neighbouring could be affected. Should the groundwater monitoring not also be extended to neighbouring farms as well?


NAME & ORGANISATION

METHOD RESPONSE

W15 The groundwater abstraction could be a

long term impact, extending beyond the

operations of the mine.

W16 Ideally long term monitoring data is

required.

W17 An independent person should do the

monitoring.

W18 Where will water be stored?

W19 Will the geology be described?

Feasibility

F1 No mention is made in the scoping report about a recent detailed exploration programme report

Roy Miller Email The questions / comments in this section relate (mostly) to the “Feasibility of the proposed project”. The feasibility the project (i.e. to establish whether the project would be feasible or not) is not part of the scope of the EIA. However, an associated issue relating to this relate to the risk of closure or even ’early closure’ of the mine and whether there will be funds available for closure and rehabilitation requirements.

F2 Is there a feasibility study? Is the project Economically feasible?


F3 What method did you use to assess, explore & determine the feasibility?

F4 How was the sampling done? How many samples were taken?


NAME & ORGANISATION

METHOD RESPONSE

F5 It is not a representative sample of the area – it is a risk.

Refer to the Mine Closure Strategy (Appendix A to the EMP) as well as further specific Mine Closure Questions below.

F6 The BID referred to “ore stockpiles”. That is wrong terminology. Is should be regarded as “waste dumps” with some copper.

F7 It is on record that the ore reserve

estimate is 3%. Valuable ore have been

“hand-picked already by historical mining

activities.

There is a risk that too little samples

were taken by Tulela to determine

whether it will be a feasible project.

The risk lies in the fact that, if there is no

income from the project, there will also

be no money for rehabilitation - as part of

closure.

There needs to be a fund for the closure / rehabilitation.

F8 What is the difference in permeability

between the current stock piles and

future mined ore?

What will the difference be in particle

size?

F9 Without agglomeration you will not get

permeability.

F10 What is the expected copper recovery?


NAME & ORGANISATION

METHOD RESPONSE

F11 What is the concentration of copper in

the low grade stream expected to be and

how much of this will be recovered by

the leaching process?

F12 Have the silver and gold concentrations

in the surface ore stockpiles been

determined yet.

F13 What fraction of any gold or silver is

expected to be recovered by the VAT

cyanide leaching process?

F14 No mention is made in the scoping report about a recent detailed geological report.

Le Roux van Schalwyk

Email

F14 No mention is made in the scoping report about a recent detailed feasibility report.

Environmental Impacts

E1 All IAPs need to see and understand your detailed Environmental Management Plan.

Roy Miller Email Noted. Refer to Appendix J of the EIA Scoping & Assessment Report for the EMP.

E2 What specialized investigations are being carried out?

Refer to sections 1.3 and 8 of the EIA Scoping Report and Appendices E to I.

E3 What are your plans to avoid and mitigate impacts?

Refer to section 8 of the EIA Scoping Report and Appendix J for the EMP.

E4 What plans do you have to ensure that construction and operational employees


NAME & ORGANISATION

METHOD RESPONSE

have no contact whatsoever with farmers and farm workers in the area.

E5 What are your plans for dust suppression during operations and for decades into the future?

E6 There are various endemic biodiversity species in the area and they are seasonal. It is currently a bad time of the year for plants as there are were no rains yet. Locals need to look at the species list.


Noted. The Biodiversity Specialist is aware of this. Specialist lists were shared by locals and considered by the Biodiversity Specialist.

E7 Will there be dust suppression on the crushers?

Refer to section 8 of the EIA Scoping Report and Appendix J for the EMP.

E8 Will there be dust suppression?

E9 The MAWF will have to be part of the EIA. The MAWF is part of the IAP database and the relevant reports (i.e. BID and EIA Scoping and Assessment Report) shared with them.

E10 All potential impacts must be considered as part of the EIA and management and mitigation measure developed in included in an EMP.

Refer to sections 7 and 8 of the EIA Scoping Report and Appendix J for the EMP.

Socio – economic – including Community Health and Safety, tourism, traffic, economy, etc.

S1 Introducing 30 – 50 mine employees, which in all likelihood will be 90% male will have a disturbing effect on the farming community in the surrounding area, i.e.

Thorsten Theile Email Potential impacts from the workers were assessed. Refer to Appendix H and section 7 of the EIA Scoping & Assessment Report. Refer to the EMP for relevant management and mitigation measures.


NAME & ORGANISATION

METHOD RESPONSE

labour force related, threat to game & livestock, etc.

S2 What is the impact of this project on tourism in the area?

Potential Tourism impacts were considered. Refer to Appendix H and section 7 of the EIA Scoping & Assessment Report.

S3 Increased heavy traffic on the gravel roads. Already not coping with the current traffic load will lead to even faster deterioration of this infrastructure

Potential traffic related impacts were considered. Refer to sections 4.2.8 and 7 of the EIA Scoping & Assessment Report.

S4 Tourism is important for the area. Farm owners Public meeting (2nd of October)

Potential Tourism impacts were considered. Refer to Appendix H and section 7 of the EIA Scoping & Assessment Report.

S5 Land use needs to be considered in the EIA?

A detailed description of the current / receiving environment is provided in section 5 of the EIA Scoping & Assessment Report.

S6 Workers might be an issue regarding community safety. Also, drug use and dealing with drugs s are issues in the area.

Potential impacts from the workers were assessed. Refer to Appendix H and section 7 of the EIA Scoping & Assessment Report. Refer to the EMP for relevant management and mitigation measures.

S7 How will the housing for the workers be handled.



Refer to section 4.2.9 and 6.4 of the EIA Scoping and Assessment Report.

Mine Closure and Rehabilitation

MC1 Plan for mine closure. Specifically, for early mine closure.

Roy Miller (Farm owner)

Email Refer to section 4.4 of the EIA Scoping and Assessment Report and the Mine Closure Strategy in Appendix A of the EMP.

MC2 A Mine Closure Plan (including closure costing) needs to be developed. A key issues is, should the project not be

Farm owners Public meeting (2nd of October


NAME & ORGANISATION

METHOD RESPONSE

feasible, there needs to be budget for properly closing the mine and conducting effective rehabilitation

MC3 Once leaching is done how will the VATs be closed and rehabilitated?

MC4 Topsoil needs to be removed prior to the construction activities / clearing of areas; separately stockpiled and used during the rehabilitation at closure. Also, to get the rehabilitation “going” the topsoil (once placed back) might require some water.

Refer to Section 8.4 of the EIA report and the EMP for topsoil Management.

MC5 After mining, what will happen? There must be a funds for mine closure / rehabilitation from the beginning of the project.

Refer to section 4.4 of the EIA Scoping and Assessment Report and the Mine Closure Strategy in Appendix A of the EMP.

TABLE 2: COMMENTS RECEIVED ON THE DRAFT EIA SCOPING / ASSESSMENT REPORT AND EMP DURING THE REVIEW PERIOD BY IAPS


NAME & ORGANISATION

METHOD RESPONSE

General

G1 On page 19, 4.1.2 – Cathral Investments Shareholders:

Morne Du Plessis – 20%

Morne Du Plessis was the person who received an Environmental Clearance Certificate on the 08.10.2018, as attached.

No Public Participation Process ever happened. No stakeholder was consulted. On the 07.12.2018, Morne Du Plessis signed the Surface Rights Agreement, where it was stipulated, that certain compensations must be paid to Marc Pampe on a monthly basis.

The effective date of the agreement was the 07.12.2018.

Invoices were send to Morne Du Plessis on a monthly basis.

To date no payment was effected by Morne Du Plessis.

It is of great concern, that Morne Du Plessis, with all his short comings, ignoring the signed document between him and myself, is a 20% stakeholder/shareholder in Cathral Investments.

My faith, trust and confidence levels in Cathral Investments are negatively impacted by this.


e-mail Please note that the previous EIA was conducted by a different company / Applicant and Cathral Investments / Tulela did not form part of this company. Also at that time, Morne Du Plessis was not a shareholder of Cathral Investments. Cannot comment on the previous EIA process that was conducted. Refer to section 10) of the EIA Scoping & Assessment Report relating to the Environmental Impact Statement and Conclusions of the current EIA. Cannot comment on previous agreements. Cathral Investments / Tulela was not part of those agreements. New contractual agreements will be signed, between the landowner and Cathral Investments / Tulela.


NAME & ORGANISATION

METHOD RESPONSE

This makes for a unhealthy relationship between Cathral Investments and me the owner of the farm.

G2 “Attached please find The EIA and EMP with my editing comments. Without a Closure and Restoration Plan, the EMP is incomplete”.

Roy Miller

(Neighboring

farm owner)

e-mail Various comments were made directly in the EIA Scoping and Assessment Report, EMP and IAP database by Mr. Miller – as “comments”.

These are not all be included in this table. However, the key comments (or questions) made in the Scoping/Assessment Report and EMP are included in the relevant sections below.

Other comments made to the EMP were considered and the EMP amended, where relevant.

The IAP database was updated.

G3 Original statement in EMP (section 4.2.2): “Some of the waste rock will be used for construction of the VAT/Heap Leach facility”.

Question:

What waste rock are you talking about? According to your plans, you intend starting immediately with VAT/heap leach. All the present dumps you call ore stockpile. Thus, without any mining at the start of the processing you do not have any waste rock to construct VAT/heap

Roy Miller

(Neighboring

farm owner)

e-mail (comment in EMP)

The sentence in the EMP was changed to elaborate more on the specific material tpo be used:

“Some of the waste rock produced while doing surface treatment / levelling for the VAT/Heap leach will be used for construction of the VAT/Heap Leach facility”.


NAME & ORGANISATION

METHOD RESPONSE

leach facilities. This does not make sense.

Topsoil

S1 Section 3.1.2 of the Scoping/Assessment Report (Leaching – top of VAT/Heap leach vessels):

“Top cannot be covered with top soil as the chemicals will destroy the micro-organisms that are critical to keeping the top soil viable for the healthy rooting of plants which will be part of the rehabilitation process. Furthermore, there is very little top soil in the area and this has to be retained for final rehabilitation and not used in the processing of ore”.

Roy Miller

(Neighboring

farm owner)

e-mail (comments made in the report)

This section was amended in the report. The intension is to cover (on top) the facility with a plastic lining.

At closure, the entire VAT/Heap leach vessel (with the bottom, side and top plastic liner remaining) will be covered with waste rock material and then topsoil. The final Mine Closure Plan, however still needs to be developed – as described in the EMP and the Mine Closure Framework provided as Appendix A to the EMP.

Water

W1 The rainfall data for Farm Sinclair, for the last four rainy seasons is the following:

2015/2016 – 78mm

2016/2017 – 67mm

2017/2018 – 46mm

2018/2019 – 12mm

It is not accurate to use the average rainfall data of Farm Aruab – Farm Aruab


e-mail The rainfall baseline data was updated in the Water Specialist Report under section 2.2.1 taking into consideration most up-to-date rainfall information as well as rainfall stations that are closest to the Sinclair mine. To that effect a composite rainfall record was thus developed and re-assed to give a more realistic rainfall picture in the local area. These amendments were included in the EIA Scoping & Assessment Report (section


NAME & ORGANISATION

METHOD RESPONSE

has a much higher average rainfall than Farm Sinclair.

Farm Aruab lies in the mountains and it is well known that the average rainfall is higher in that area than at Sinclair.

5.1.2.2), taking this information provided into account. Furthermore, this information was considered in the assessment of impacts relating to the groundwater abstraction activities. The Water Specialist Report and the EIA Scoping & Assessment Report (section 8.3) was amended accordingly. However, the overall significance rating, in the mitigated scenario, has not changed.

W2 I have gone through the EIA and EMP for Sinclair, and have attached my comments. I have also attached Sinclair rainfall data that was given to me by the previous owner, Mrs. Hannelore Hoffmann. Although there is a gap in the data, it is more relevant to the project than the rainfall data from Aruab.

Jörn Miller

(Neighboring

farm owner)

e-mail

W3 Section 5.1.2.2 of Scoping/Assessment Report (Rainfall):

Why does the Aruab data not extend to 2018. Data from 2004 to 2018 is available. This data is relevant to the present drought and to the fact that the project intends to pump up to 120 m3 per day of water from underground sources.

Roy Miller

(Neighboring

farm owner)


W4 The rainfall situation is not correct. On Campbells Valley (Mount Valley), neighbor farm to Sinclair, the average farm rainfall was:

2012/2013: 32,2 mm,

2013/2014: 86,5 mm,

2014/2015: 47,3 mm,

2015/2016: 39,3 mm,

2016/2017: 35,6 mm,

2017/2018: 100,1 mm,

2018/2019: 0 mm.

Christa and

Ruediger

Hennings

e-mail


NAME & ORGANISATION

METHOD RESPONSE

W5 Surface Water (Report Par. 8.2)

Although the storm water management plan foresees the mitigation/avoidance of

contamination of surface water during normal operations, it does not make any mention of what measures are to be undertaken if there is any breach of the VAT leach dams or any other reservoirs filled with dangerous liquids and a subsequent accidental contamination of the surface water. Furthermore I did not see any mention of how a possible contamination is then reversed should it occur irrespective of preventative measures being in place. The client must have processes in place to recover/reverse any contamination of surface water in case of an accident as part of the EMP.

Thorsten Theile

(NAMTIB

Biosphere

Reserve)

e-mail In Section 5.2 of the water specialist report safeguards against surface water contamination have been addressed. In that regard, process material in the VAT/Heap Leach Vessels is in pulp or slurry form (not liquid), therefore it will not flow when the vessels breach. However, the requirement for emergency measures to contain and remove the slurry has been recommended to be in place to address the breach of VAT vessels, was added the Water Specialist Report, the EIA Scoping & Assessment Report and the EMP (Surface Water MP).

W6 Reduction in Groundwater Levels (Report Par. 8.3.1).

Even though the groundwater report has shown that the impact of the mining activities may be moderate to low at the proposed maximum abstraction rate, these assumptions are based on short term tests only and with very little knowledge of the local aquifer formations. It should be kept in mind that once a significant drop in water levels can be noted within the area, the damage has already been done and based on the historic local rainfall figures, recharge of the water table will definitely take much longer than the duration of the project.

Thorsten Theile

(NAMTIB

Biosphere

Reserve)

e-mail Section 5.3 in the water specialist report where it is highlighted that “in the absence of pertinent data required to quantify resources and define limits for abstraction measures to collect such data should be in place in the form of a groundwater management plan forming part of this assessment. The monitoring plan includes the groundwater levels and groundwater quality in production and monitoring boreholes on farms Sinclair and Aubures, as well as metered abstraction volumes from production boreholes” This in addition to recommendations to drill additional abstraction boreholes will reduce stress on the current envisioned production borehole.


NAME & ORGANISATION

METHOD RESPONSE

Additionally the report should also include the consequences for the client, should the abstraction exceed the recommended limit and/or cause the groundwater level to drop, i.e. there must be a financial implication for the client if either is the case in the form of a penalty to be paid to the landowner / neighboring farms affected.

With the above measures in place to collect necessary information that will be used to update the monitoring plan as well as firm up additional measures that will be required to mitigate impact on other users. A measure is in place for contingent water supply to users in the event that water level drop proven to be caused by mining operations. Another action included in the EMP, to address the specific comment, is to reduce pumping rates in case water levels in production boreholes drop to levels deeper than expected - to stabilise the water level. Specific actions have been included in the EMP for the event that groundwater abstraction for mining activities has been proven to affect other users.

W7 Contamination of Groundwater (Report Par 8.3.2)

Contamination of the groundwater is probably the worst that could happen during and after the mining process. The client should also be obliged to supply a written guarantee on the lifetime of the lining used for the VAT leach dams. Furthermore, the same comments apply as mentioned in Paragraph 1 above with the addition of financial penalties to be implemented for the client should a contamination of the groundwater take place.

Thorsten Theile

(NAMTIB

Biosphere

Reserve)

e-mail With reference to section 3.1.4 of the EIA Scoping & Assessment Report, the material in the VAT/Leach Vessels will be neutralized post the extraction process. Therefore, the potential for groundwater contamination impacts would reduce. Furthermore, an action in the EMP requires that Tulela need to line the facility with long-term durable lining to prevent seepage of contaminants into the groundwater. With reference to Appendix A of the EMP, a Mine Closure Framework was developed. The requirement for Tulela to develop a Mine Closure Plan is specified and the relevant closure objectives, key


NAME & ORGANISATION

METHOD RESPONSE

environmental values and closure needs are provided. The requirement for monitoring after closure is also one of the items to be further developed as part of the Closure Plan.

W8 The water which ‘Cathral’ will need daily is only estimation. Maybe ‘Cathral’ take 200.000 Litre or more daily. It is not said, what the maximum is ‘Cathral’ can take without the boreholes and the environment in the neighbourhood will collapse.

Christa and

Ruediger

Hennings

e-mail The maximum (allowed) abstraction rate is included in the EMP. Refer to Action 2 in the Groundwater Management Plan.

W9 I have gone through the EIA for the Sinclair Project and I remain extremely concerned about the water requirements for the project. I feel very strongly that the potential impact on groundwater reserves should be classed as “high” especially considering the aridity of the area, and the fact that depletion of this resource will have an impact well beyond the envisaged life of the mine.

Furthermore, steps to mitigate the impact should not only include a program of monitoring the groundwater, but also a well defined set of depletion limits and the clear stipulation to cease abstraction should these depletion limits be reached. (Drilling a borehole deeper to get more water is not a mitigating step because it only facilitates further depletion of the resource.)

My arguments to have the ground water impact classed as “high” are as follows:

1. The water requirement of 90 to 120m3 per day, is between ten

Jörn Miller

(Neighboring

farm owner)

e-mail Section 5.3 in the water specialist report where it is highlighted that “in the absence of pertinent data required to quantify resources and define limits for abstraction measures to collect such data should be in place in the form of a groundwater management plan forming part of this assessment. The monitoring plan includes the groundwater levels and groundwater quality in production and monitoring boreholes on farms Sinclair and Aubures, as well as metered abstraction volumes from production boreholes”

This in addition to recommendations to drill additional abstraction boreholes will reduce stress on the current envisioned production borehole.

With the above measures in place to collect necessary information that will be used to update the monitoring plan as well as firm up additional measures that will be required to mitigate impact on other users.


NAME & ORGANISATION

METHOD RESPONSE

and twenty times higher than the extraction rate that groundwater resources in the area are normally subjected to.

2. The pumping rate of 5m3/hour that the mine requires is more than double the average yield (1.95m3/hour) of boreholes in this area.

3. The size and extent of the groundwater resources to be pumped are completely unknown factors.

4. Sinclair is a very arid farm where groundwater recharging events are even less predictable than the rainfall. In this respect, it must be pointed out that the use of the Aruab rainfall data in the climatic baseline description is inappropriate and highly misleading. The Aruab rain gauge is situated at 1600m (above sea level) on the eastern slopes of the “Rooi Rand” Escarpment, some 3 km from the north-south trending watershed. Sinclair on the other hand lies 17 km to the west and approximately 700m below the peaks of the escarpment (i.e. in a rainshadow). Rain that falls at the Aruab gauge drains towards the east into the Konkiep River basin, and does not recharge any of the groundwater structures on Sinclair.

A measure is in place for contingent water supply to users in the event that water level drop proven to be caused by mining operations Key in this regard is that the actions (i.e. management and mitigation measures) provided by the Water Specialist Team, which are included in the EMP must be implemented by Tulela.


NAME & ORGANISATION

METHOD RESPONSE

5. Sinclair rainfall data (from 1933 – 1976 and 1990 – 2016) was provided to me by the previous owners of the farm (see Excel attachment to my email)). This data, particularly from the last three decades, should underline our concerns. From 1990 to 2016 the average annual rainfall for Sinclair was 82.8 mm, which is less than half, and close to 100 mm below the 180mm average that Aruab recorded for the same period.

6. Of even greater concern from the 1990 – 2016 data is the sixteen year interval (1990 to 2005) during which the annual total rainfall only exceeded 100 mm on one occasion, and then only by a very small margin (115 mm in 1994). It is highly unlikely that groundwater was replenished at all during this period. Without any guarantee of when the next replenishment will occur, the mine’s annual water consumption, ten to twenty times above the historical abstraction rates, represents a very high risk to the resource. The problem is compounded if extraction at this rate is to continue over two years.

W10 On the subject of groundwater in the proposed EMP, I also have a number of concerns:

Jörn Miller

(Neighboring

farm owner)

e-mail Section 4.4 in the Water specialist report a revised monitoring plan was recommended taking into consideration all boreholes on Farm Sinclair as well as the frequency of monitoring.


NAME & ORGANISATION

METHOD RESPONSE

1. The water levels in all the boreholes at the Sinclair house, and the “Garden Borehole” in the Aubures River should be monitored at least once a month. These boreholes are closest to the mine, they serve the activity hub of the farm, and potentially negative effects due to excessive pumping should be flagged at the earliest sign. (Even the characteristic stands of Camelthorn Trees in the Aubures River may deteriorate if groundwater levels drop significantly.)

2. Since the Sinclair borehole WW70293 (which is to be used as a production borehole) is close to the Aubures boundary, I will monitor the water levels of boreholes WW70289 (at the Aubures house) and WW70285 (Aubures, Cattle Post) on a monthly basis. (Aubures borehole WW70286 at the Sinclair / Aubures boundary fence has been dry for several years already).

3. Marc , the owner of Sinclair, his foreman or any other person appointed by him, should be able to attend any groundwater monitoring events, and all weekly/monthly test results should be forwarded to him on an ongoing basis. Any chemical analysis results of groundwater

This practical and effective Groundwater Monitoring Programme, is also included in the revised EMP. Noted. Reporting requirements are include in section 7 of the EMP. However, more detailed reporting requirements between Tulela and the Farm Owner needs to be confirmed in the agreement between these two parties.


NAME & ORGANISATION

METHOD RESPONSE

samples should also be forwarded to him directly.

4. If a cyanide leaching step is to be included as a processing step, groundwater samples should be analysed for cyanide residues as well.

5. Before processing and water abstraction commences, a clearly defined set of groundwater depletion limits should be agreed upon (i.e. fall in water table, lower pumping yields, slower water level recoveries). Furthermore, it must be agreed that pumping must cease if any of these limits are reached or exceeded. In such an event, drilling the borehole deeper is not an acceptable solution – it may temporarily provide the mine with more water, but it compounds the long-term risk of water resource depletion.

Included in the EMP Section 5.3 in the water specialist report where it is highlighted that “in the absence of pertinent data required to quantify resources and define limits for abstraction measures to collect such data should be in place in the form of a groundwater management plan forming part of this assessment. The monitoring plan includes the groundwater levels and groundwater quality in production and monitoring boreholes on farms Sinclair and Aubures As well as metered abstraction volumes from production boreholes” This in addition to recommendations to drill additional abstraction boreholes will reduce stress on the current envisioned production borehole. With the above measures in place to collect necessary information that will be used to update the monitoring plan as well as firm up additional measures that will be required to mitigate impact on other users. A measure is in place for contingent water supply to users in the event that water level drop proven. The following action was included in the EMP - In case water levels in production


NAME & ORGANISATION

METHOD RESPONSE

boreholes drop to levels deeper than expected, pumping rates should be reduced to stabilise the water level.

W11 Section 5.5.2.1 of Scoping/Assessment Report (The farm house is located on the Barby Formation / Aubures Formation contact):

“near the contact, not on it”

Roy Miller

(Neighboring

farm owner)


Wording was changed in the report.

W12 Section 5.5.2.1 of Scoping/Assessment Report:

“The alluvium is definitely not saturated”

Roy Miller

(Neighboring farm

owner)



W13 Section 5.6.2.1 of Scoping/Assessment Report (All rivers in the catchment are ephemeral rivers with episodic flows (less than 75% of the year)):

“much less than 75%”

Roy Miller

(Neighboring farm

owner)


Noted.

W14 Section 5.6.2.1 of Scoping/Assessment Report (the Aubures River flows in a northeastern direction, before turning southwest and disappearing under the Namib Sand sea):

“southeast then northwest, then southwest, not northeast at all”

Roy Miller

(Neighboring farm

owner)



W15 Section 8.3.1.2 of Scoping/Assessment Report (nature of impact) will reduce to low with mitigation):

“only if additional boreholes are drilled over a wider area to reduce the impact on the only borehole that came anywhere near providing the required amount of water. Pumping of that borehole alone will

Roy Miller

(Neighboring

farm owner)


Key requirements (amongst others) included in the EMP drilling of 2 production boreholes at the mine site in order to supplement the water supply from borehole WW70293 and reduce the impact on the groundwater level around that borehole on farms Sinclair and Aubures. Furthermore, these two new production boreholes will be used as monitoring boreholes.


NAME & ORGANISATION

METHOD RESPONSE

have a massive impact on its water table. A 24-hour pump test is not measure of the impact that pumping at the required rate day after day for a year and more. SLR said they did not know why that borehole was so strong, i.e they did not understand it - dangerous for long-term intense utilisation. We also do not know how water from this borehole/geological feature feeds into that groundwater system that feeds other boreholes, e.g. those at the Sinclair house which is downslope from the strong borehole”.

W16 Section 8.3.1.2 of Scoping/Assessment Report (Extent - impact will be localised to the farm Sinclair:

“You do not know this. The strong borehole is located close to the boundary of the farm Aubures. The impact will not be low in this environment where most boreholes have yields of about 2m3 per hour. Its impact would be moderate, or even high. Mitigation is to drill other boreholes and use these as well instead of over-exploiting a single borehole. This would then reduce impact to moderate or low.”

Roy Miller

(Neighboring farm

owner)


The assessment of the potential impacts were conducted for the unmitigated and mitigated scenario. The significance rating in the “Mitigated Scenario” is assessed as Low. One of the key requirements (amongst others) included in the EMP are is the drilling of 2 production boreholes at the mine site in order to supplement the water supply from borehole WW70293 and reduce the impact on the groundwater level around that borehole on farms Sinclair and Aubures. The Water Specialist Team took the additional information (i.e. historic rainfall data) provided by the relevant farmers into consideration and amended their report accordingly. The severity of the potential impact relating the water abstraction was

W17 Section 8.3.1.2 of Scoping/Assessment Report (probability): “With most other boreholes in the region having yields of about 2m3 per hour, the potential is high for abstraction volumes being too high”.

Roy Miller

(Neighboring

farm owner)



NAME & ORGANISATION

METHOD RESPONSE

W18 Section 8.3.1.2 of Scoping/Assessment

Report (With mitigation, probability reduces to low):

“Only if other boreholes are drilled and used.”

Roy Miller

(Neighboring

farm owner)


changed to “high” in the unmitigated scenario. The overall significance rating, in the mitigated scenario, has not changed.

W19 Section 8.3.1.2 of Scoping/Assessment Report (The significance of this potential impact is moderate in the unmitigated scenario and low in the mitigated scenario):

“Nonsense - see above comments”.

Roy Miller

(Neighboring farm

owner)


W20 Section 8.3.1.2 of Scoping/Assessment Report (significance rating with mitigation):

“All should be M”.

Roy Miller

(Neighboring

farm owner)


W21 Section 8.3.2.2 of Scoping/Assessment Report (Seepage from the waste rock dumpsite is not considered hazardous due to the oxide nature of the rocks and ore minerals that are contained as these do not contain sulphides):

“The main ore mineral, chalcocite, is a sulphide. There is also some chalcopyrite and bornite which are also sulphides. Rephrase.”.

Roy Miller

(Neighboring farm

owner)


The Section in the report was rephrased accordingly.

W22 Statement in EMP (section 4.2.5): “Once the final infrastructure drawings and plans have been completed, the conceptual storm water plan can be updated to take into account the final layouts”.

Comment / question:

This sentence means that the EMP is not complete. A final, complete EMP needs to be prepared for final comment and

Roy Miller

(Neighboring

farm owner)


The EMP, submitted to MME & MET is the Final version, for their review and decision. All comments and questions raised by IAPs during the review of the (draft) report were considered and incorporated into the various documents, where relevant. In general, EIAs are never conducted on “detail design” information. Rather, the EIA process is generally aligned with the


NAME & ORGANISATION

METHOD RESPONSE

evaluation by IAPs before being submitted to MET for a clearance certificate.

Feasibility / Basic design stages in the project execution model”. Sometimes EIAs could even commence as early as the “Concept stage”. Prior to the implementation of the proposed Sinclair Project, the design Team might still propose minor changes to the site layout (amongst others). This could therefore also entail that the final Storm Water Management Plan needs minor modifications - as long as the relevant requirements are implemented to ensure potential impacts are avoided / minimized – i.e. the relevant management and mitigation measures (as stipulated in the EMP) are incorporated. Therefore, should the final layout not change, the “Conceptual” Storm Water Plan presented in the EIA could very well be the final one. Significant changes to a project (i.e. in terms of additional / new activities or increase in the proposed project capacity/throughput, or footprint, etc.) could require an EIA amendment, if an ECC has already been issued by MET.

Feasibility of the Project and Mine Closure

F1 During the public meeting it became apparent that the feasibility of the whole project was based on rather basic, if not insufficient, sampling being done on the waste dumps (referred to as stockpiles in the EIA report) of the old Sinclair Mine,

Thorsten Theile

(NAMTIB

Biosphere

Reserve)

e-mail The questions / comments in this section relate (mostly) to the “Feasibility of the proposed project”. The feasibility the project (i.e. to establish whether the project would be feasible or not


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which has been abandoned a couple of times in the past. It was generally agreed amongst all IAP’s that more sampling should be undertaken in order to truly establish the feasibility of reviving the mining activities at Sinclair Mine. Based on the general doubt of the feasibility of this project it is even more important that sufficient funding must be available to cover all costs that might be incurred during the mining process (any penalties that might become applicable) and especially to cover the costs involved when shutting down the mine in accordance with the EMP. These funds should be placed in a trust especially earmarked for this purpose, before any mining/exploration activities commence. The exact amount to be deposited in the trust and subsequent management of the trust should be agreed upon between the client and the affected stakeholders.

and the need for further sampling, etc.) is not part of the scope of the EIA. However, an associated issue relating to this relate to the risk of closure or even ’early closure’ of the mine and whether there will be funds available for closure and rehabilitation requirements. Refer to section 4.4 of the EIA Scoping and Assessment Report and the (revised) Mine Closure Strategy in Appendix A of the EMP. A Mine Closure Plan (including closure costing) needs to be developed, in line with the relevant legislation and Namibia Mine Closure Framework, long before the closure of the mine. This is essential, given the very short lifespan of the mine. Tulela will make funds (Financial Assurance) available for closure of the mine, from the outset of the implementation of the project. A (Conceptual) Mine Closure Plan will be submitted as part of the Mining Licence Application to MME. The Conceptual Financial Assurance amount will be included as part of the Conceptual Mine Closure Plan, to be submitted to MME as part of the ML Application (see section 1).


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F2 Mr. Badenhorst told on the 2.10.19 at Sinclair, that ‘Cathral’ will fall bankrupt if the mine is not profitable. The same will happen, when the project is finished. Who will then remove the environment damages in the region?

Christa and Ruediger Hennings

e-mail This statement it not correct and was misinterpreted. Please see F1 regarding the Mine Closure Plan and Financial Assurance.

F3 Table 6 in EMP (section 6)

Comment / question:

Rehabilitation missing in this list.

Roy Miller

(Neighboring

farm owner)


The list provides the various “Management Plans (MP)” as part of the EMP. There is not a specific MP for “Rehabilitation”. Rather, various rehabilitation requirements are included under the relevant MPs. Furthermore, Appendix A of the EMP provides the Mine Closure Framework and includes the requirement for Tulela to develop a Mine Closure Plan. The “rehabilitation requirements” need to be further developed as part of the Mine Closure Plan (MCP) – taking the commitments that form part of the EMP into consideration. A MCP does not have to form part of the EIA / EMP before an ECC is issued by MET. However, the decommissioning and closure phase were considered as part of the EIA, and relevant management and mitigation measures relating to this phase included in the EMP. However, the requirements for the (Conceptual) Mine Closure Plan that needs to be submitted as part of the Mining Licence Application to MME, is included in the Mine Closure Framework (Appendix A of the EMP).

F4 Socio-Economic MP (section 6.10.2.4) – closure:

“Ensure there is a detailed Mine Closure Plan in place long before the closure of the mine. This is essential, given the very short lifespan of the mine”.

Comment / question:

This indicates there is no Mine Decommissioning and Closure Plan. Must be part of the EMP before an EC is issued. The MCP is a living document so is modified continuously as mining and rehabilitation progress.


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Biodiversity and topsoil

B1 Biodiversity (Report Par 8.4)

The mining area should be completely fenced off, so as to prevent any animals from entering it. Signposts alone should not be an option as mitigating measure.

Thorsten Theile

(NAMTIB

Biosphere

Reserve)

e-mail There is an existing fence around the working are of the mine. Section 6.2.2.1 of the EMP stipulates that the fence around the working area of the mine will be maintained. The requirement for the fence is to provide a barrier to keep third parties from potentially dangerous excavations, infrastructure and associated activities. Also, to prevent workers to move freely outside the project area. Unless it is game fencing, a fence has limited efficacy in keeping out (all) animals - it works for ostrich and some antelopes, but not for all mammals nor reptiles. On this site, the main value to biodiversity would be to restrict human activity and disturbance to the mine site.

B2 Dust prevention measures should be implemented to the full extend technically possible.

The report mentions Acacia Erioloba trees in particular in the close vicinity of the project.

Excessive dust pollution will eventually suffocate these trees and other plants, due to the lack of regular rainfall to wash off the dust from the trees’ leaves. Once again the client should be held accountable in case these plants are killed off by insufficient dust control measures on his behalf.

Thorsten Theile

(NAMTIB

Biosphere

Reserve)

e-mail With reference to section 5.7.2.2, there are only limited protected trees in the proposed mining and processing area, including:

One mature Acacia erioloba.

Three mature Aloe dichotoma

One mature Parkinsonia Africana The Biodiversity assessment (Appendix E of the EIA Scoping/Assessment Report) took cognisance of this fact in assessing the potential impacts on vegetation. Potential impacts on protected tree species, relating to dust, are not regarded significant.


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With reference to section 6.5 of the EMP, relevant management and mitigation measures (including monitoring) for air pollution (i.e. dust) is provided.

B3 Section 8.4.1.2 of Scoping/Assessment Report (Larger mammals and birds are the taxa most likely to be affected):

“and small reptiles”.

Roy Miller (Neighboring farm owner)


Section 8.4.1.2 of the report was amended accordingly. It is unlikely that the directional movements, daily activities and behavior of reptiles would be significantly affected by the mining activities, certainly not to the same extent as those of mammals and birds. It is likely that some individual reptiles will die, but destruction of organisms is dealt with in another impact.

B4 Section 8.4.1.2 of Scoping/Assessment Report (Mining and processing areas are already disturbed to a certain extend):

“but existing dumps provide refuges for small mammals, small reptiles and invertebrates”.

Roy Miller

(Neighboring farm

owner)


Correct, the old dumps have been recolonised over time and now provide habitat for certain organisms. However, on balance, the mining area still is disturbed rather than pristine in terms of biodiversity. Section 8.4.1.2 of the report was amended accordingly.

B5 Section 8.4.2.2 of Scoping/Assessment Report (The Aubures River is however alluvial and its ecology thus depends more on surface water than groundwater): “Wrong. It is rare for the Aubures River to flow. Surface water therefore lasts only a few days. The water in the alluvium is also underground water”.


e-mail

(comments

made in the

report)

Section 8.4.2.2 was amended accordingly.

The amended section in the report is as

follows:

“The Aubures River in the project area

comprises alluvial sediments of unknown

saturated thickness (an open well located

in the Aubures River on farm Sinclair

showed an alluvium thickness of more than

5 m at that location). Its ecology thus

depends on shallow alluvial groundwater,

which is recharged after irregular seasonal


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METHOD RESPONSE

flood events, rather than on deeper

groundwater (i.e. deep hardrock aquifer).

Although the alluvial aquifer is also

recharged to a small percentage by the

hardrock aquifer, the proposed volumes of

abstraction are not expected to negatively

affect the groundwater levels in the

Aubures River alluvium”.

B6 Biodiversity MP in the EMP (Issue 4):

Comment / question:

..."should be drawn up".... This means there is no comprehensive restoration plan which also means that this EMP is incomplete and as such cannot be issued a clearance certificate.

Roy Miller

(Neighboring

farm owner)

e-mail (comment

in EMP)

Not correct. This EMP is complete. Appendix A of the EMP provides the Mine Closure Framework and includes the requirement for Tulela to develop a Mine Closure Plan. The “detailed rehabilitation requirements” need to be further developed as part of the Mine Closure Plan – taking the commitments that form part of the EMP into consideration. The relevant section in the EMP was however modified as follows: “A comprehensive restoration plan must be drawn up by an expert as part of the Mine Closure Plan. Some rehabilitation actions must be implemented during construction / operations in order to be effective, e.g. removal and storage of topsoil (refer to “Issue 5”)”.

Socio – economic – including Community Health and Safety, etc.

S1 Section 5.8.2.3 of Scoping/Assessment Report (Bethanie Village Council office about 100 km south-east of the mine in Bethanie village):



Section 5.8.2.3 was amended accordingly.


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“more than 100 km”

S2 Section 8.1.1.2 of Scoping/Assessment Report (duration of impact):

You cannot avoid the long-term impacts. You will always have long-term impacts, even after rehabilitation.



This comment relates to the “duration” of the following potential impact – in the mitigated scenario: Hazardous excavations, infrastructure and activities; and movement of mining vehicles that could pose a safety risk, specifically to 3rd parties, but also animals. Comment noted and the assessment amended. However, the overall significance rating before and after remains as is, because with mitigation, the possibility of the safety risks are reduced, meaning the nature and intensity are also reduced. The same argument applies for potential hazardous infrastructure that will remain beyond closure of the mine. Even though the potential hazardous infrastructure will remain (after closure), with the effective implementation of relevant management and mitigation measure (i.e. facilities to be “closed in a manner that they present land forms that have similar safety attributes to the natural land forms in the area”, etc.), potential impacts can be avoided / minimized.

Documents

1. INTRODUCTION and Tourism (MET). An EIA process will be … · 2019. 12. 10. · 1 1. INTRODUCTION and Tourism (MET). An EIA process will be conducted Cathral Investments Ninety