Annexure F Rehabilitation Methods (Updated)

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ANNEXURE F

OLD WORKS REHABILITATION METHODS (OBJECTIVES AND SPECIFICATIONS)

INDEX TO REHABILITATION METHODS INTRODUCTION REGARDING THE SELECTION AND APPLICATION OF THESE REHABILITATION METHODS ........................................................................................................................................................... 2 OD. OVERBURDEN DUMPS OD1$ & OD3$ to be implemented with the 2014 revegetation Class level refinement in Method V3...................................................................................................................................... 3 CD. COARSE TAILINGS DUMPS ................................................................................................................. 8 FD. FINE TAILINGS DUMPS / SLIMES DAM FD1.3$ .................................................................... 10 OS. OVERSIZE DUMPS OS 1$ ................................................................................................ 13 KD. CONCENTRATE DUMPS .................................................................................................................... 14 EX. EXCAVATIONS to be implemented with the 2014 revegetation Class level refinement in Method V314 TR. TRENCHES TR 5$ be implemented with the 2014 revegetation Class level refinement in Method V318 PROCESSING PLANTS TP 3$, TP 6$ & TP 9$ ................................................................................... 22 TP. Terrestrial plants ................................................................................................................................... 22 PP. Prospecting Plants ................................................................................................................................ 25 FP. Final recovery plant (Alexander Bay) ................................................................................................... 25 OP. Very old HMS plant (Main multi-storey building & old concrete reservoirs) ......................................... 26 HP. Historical plants .................................................................................................................................... 26 JP. Jigging plant area at muisvlakte ........................................................................................................... 26 MP. Mobile plants of contractors (in-field screening and jigging plants) ...................................................... 26 SPECIFIC FACILITIES ...................................................................................................................................... 26 CF. Central fuel storage and despatch facility (Alexander Bay).................................................................. 26 IW. Central inside workshop (Refer photos H10 & AU13) .......................................................................... 27 HB. Alexander Bay Harbour and Logistical Facilities .................................................................................. 27 DW. Domestic waste site within the security area ........................................................................................ 27 SY. Salvage yard/industrial waste disposal sites ........................................................................................ 28 AW. Asbestos waste site .............................................................................................................................. 28 2014 FURTHER FACILITIES ............................................................................................................................ 28 HC. Hostel Complexes at Alexander Bay .......................................................................................................... 28 MO. Main Office Complex.................................................................................................................................. 28 OW. Outside Workshops and Stores Complex ................................................................................................. 29 DC. Old Security Dog Centre at Alexander Bay ................................................................................................ 29 SECURITY FACILITIES AND OTHER ACCOMMODATION ............................................................................ 29 SB. Security buildings .................................................................................................................................. 29 TRUNK ENGINEERING SERVICES (ES) ....................................................................................................... 30 EL. Electrical lines (external to plant sites) ................................................................................................. 30 WP. Water pipelines (external to plant sites) ............................................................................................... 30 SP. Sea water pump stations (external to plant sites) ................................................................................ 30 FS. Fences (security) .................................................................................................................................. 31 ENVIRONMENTAL RECTIFICATION ITEMS ................................................................................................... 31 DP. Dust Plume Management ..................................................................................................................... 31 SP. Seepage Prevention ............................................................................................................................. 31 BI. Beach Interface Rehabilitation .............................................................................................................. 31 AR. Archaeological Restoration, preservation/protection ............................................................................ 32 WI. Wetland interface .................................................................................................................................. 32 V Vegetation V3 (2014 revegetation Class level refinement) ................................................................. 33 RS ROADS ................................................................................................................................................. 42

APRIL 2015 OCTOBER 2008 #2714/AAR-P/F/R1#2446 / SMR / Rev 2

2015 UPDATE METHODOLOGY (REV OCT 2008 FROM 1 APR 2005)

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INTRODUCTION REGARDING THE SELECTION AND APPLICATION OF THESE REHABILITATION METHODS The standard rehabilitation methods were developed to achieve a rehabilitation of historical damages on the basis of the Accepted “pragmatic approach” to rehabilitation being cost effective and making disturbed areas safe and non-polluting. The standard methods are however complemented by the following two considerations, namely:

i) Elevated Rehabilitation Levels in Post-Mining Land Use considerations, which dictate in the 2008 EMP on the basis of the Court Order of 12 October 2007 that the rehabilitation of disturbances be implemented within the context of the future Post-Mining Land Use Plan. Accordingly, the 2008 methods were expanded to include optional methods denoted by a $ suffix to the method code, in terms of which such methods provide for elevated levels of rehabilitation to be selected and applied in post-mining land use nodes, where the future use such as tourism, recreation or cultural value dictate an elevated rehabilitation level.

Consequently, the list of methods reflects such varied methods designated with the $ suffix. ii) The extent to which the standard method is applied to each disturbance in

accordance with that disturbance’s natural revegetation classification level. The current revegetation status (level) as groundtruthed in the Mining Earthworks Rehabilitation Baseline Tables’ column of “Rehab_cat” contains such revegetation Class ranging between 1 and 5. The Class determines, as described in part V the level and extent of earthworks, revegetation seeding and netting to be applied in the disturbance’s physical rehabilitation in order to take cognizance of- and not disturb existing slope stabilities and natural revegetation which has occurred to date over the disturbance. Procedure for prescribing elevated rehabilitation levels

In the preparation of tenders or internal works programmes for rehabilitation projects the ECO shall follow the following procedure in application of the elevated standards and identification and prescription of the areas and specific disturbances to which such elevated rehabilitation methods shall apply:

1. Apply elevated standards to those rehabilitation actions which will take place within the visual envelope of the post-mining nodes and corridors. To this end the choices of methodologies provide for the selection of the appropriate $ suffix method in the consideration of rehabilitation of trenches (item TR5$), mining blocks (item EX5$), dumps (item OD1$), processing plants (item TP$) and engineering services (item ES$).

2. Identify the areas for elevated standards to apply by means conducting an

overlay analysis between historical disturbances and post-mining land use nodes and corridors (as discussed and illustrated in Plan 6b extract from the EMP later in the explanatory note 6-b).

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3. Prepare a list of elevated rehabilitation activities emanating from the overlay analysis which defines the extent of historical damage. Extent being the measurement parameters of each individual trench by volume, etc which will define the cost of backfill and area which will define the cost of topsoiling and revegetation as well as the relevant parameters of all other disturbance types (refer explanatory notes 4, 5 & 6). (See table 6b for example of List)

Procedure for determining the Scope of Works involved in each individual Mining

Earthworks Rehabilitation, in accordance with its Natural Revegetation Class

1. Once the disturbances comprising a rehabilitation project (tender) have been selected from the Mining Earthworks Baseline Tables inclusive of each disturbance’s “Class”, the ECO must consult the GIS and LIDAR Aerial Image of each disturbance with the Item Classification and prepare Plans for Individual disturbances or groups thereof showing the portions of each disturbance affected by the limitations imposed by the “Class”. Such Plans together with the other parameters (eg total length and depth of trench) of each disturbance as contained in the Mining Earthworks Baseline Tables will inform the tenderer or Internal Works team of the extent of rehabilitation works to be undertaken in respect of each disturbance.

2. The specification for the rehabilitation of such disturbances will therefore distinguish on the basis of the percentage split applied to the aerial image in reflecting which areas will receive the reduced intervention and which will receive the full intervention according to the relevant standard methods. This will apply to reshaping, revegetation, and the erection of windbreak netting. Such netting which will only have the function of wind speed reduction for promoting germination and protecting the saplings will comprise only two or maximum three rows of nets aligned in areas reshaped and where the need for wind speed reduction is determined per disturbance.

OD. OVERBURDEN DUMPS OD1$ & OD3$ to be implemented with the 2014

revegetation Class level refinement in Method V3

OD1.$ TOTAL REMOVAL OF OVERBURDEN DUMPS TO BACKFILL OF

EXCAVATION

(Note other costs allocated under excavation backfill) Objective of OD1 spec.

Impact reduction, to a minimum, given the overburden dump’s location within future land use sensitive areas. Overall Method of OD1:

o Removal of any topsoil and vegetation on the dump to temporary stockpile area o Load, haul and tip overburden - dump material to excavation filling o Scarify dump footprint (assume topsoil remained in place during dump creation) o Place topsoil from topsoil stockpile over smoothed fill

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o Re-vegetate both dump footprint and filled excavation by supplementary seeding and wind-break netting

OD1.1 Scarify area where dump has been removed (light scarification)

Specification:

Scarify hardened area to 150mm deep at 700mm spacing

OD1.2 Revegetate

Specification:

Conduct revegetation to re vegetation spec V3-2014

OD1.3 Load, Haul & dump in backfill area

Specification:

Load, haul, tip and spread overburden material in designated backfill area.

OD1.4 Topsoil management

Specification:

o Trim available topsoil and vegetation from dump and place in temporary topsoil stockpile.

o Place topsoil from topsoil stockpile onto filled excavation and smooth.

OD2. SHOULDER ROUNDING OF DUMPS to be implemented with the 2014

revegetation Class level refinement in Method V3

Objective of OD2 spec.

Impact reduction of unshaped overburden dumps to minimum safety and non-polluting level, by improving stability of side-slopes to allow sustainable revegetation while simultaneously achieving an improved visual form. Overall Method of OD2

o Perimeter Topsoil Removal to provide for increased size of rounded dump o Round overburden dump shoulders o Smooth top surface of overburden dump o Replace topsoil over dump from perimeter berm o Revegetate

OD2.1 Topsoil removal

Specification:

Remove perimeter Topsoil to depth of 150mm with vegetation and seed bank to temporary perimeter topsoil stockpile to provide for increased size of rounded dump.

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Temporarytopsoil stockpile

Temporarytopsoil stockpile

10m10m

OD2.2 Doze dump edges

Specification: Round overburden dump shoulders by dozer (dump edges max. 1:3 slope, rounded top edge and toes) (Dozing distance 10-20m)

Original dump profile

Max 1:3 slope

Rounded shoulderprofile

Ngl

Temporary topsoil berm

OD2.3 Smoothe surface of dump

Specification: Smoothe top surface of overburden dumps with undulating top surfaces selected for shoulder rounding.

OD2.4 Re-topsoiling shaped dump from perimeter berm

Specification: To topsoiling specification as per Method V3

OD2.5 Revegetate

Specification: Conduct re-vegetation to re vegetation specification V3

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OD3$. COMPLETE (TORTOISE SHELL) ROUNDING OF OVERBURDEN DUMPS to be implemented with the 2014 revegetation Class level refinement in Method V3 Objective of OD3 spec.: Visual Impact reduction of unshaped or poorly shaped overburden dumps where visual sensitivity is a prime consideration but where total removal of the dump is not justifiable or practical from a haul distance perspective. Overall Method of OD3:

o Perimeter Topsoil Removal to provide for increased size of rounded dump o Totally reshape overburden dump o Replace topsoil over dump from perimeter berm o Revegetate

OD3.1 Perimeter Topsoil Removal

Specification: Remove perimeter Topsoil to depth of 150mm with vegetation and seed bank to temporary perimeter topsoil stockpile to provide for increased size of rounded dump.

Temporarytopsoil stockpile

Temporarytopsoil stockpile

10m10m

OD3.2 Round Dump (by Dozing)

Specification:

Shape dump to fully rounded profile with max slopes 1:4 (±15°)

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Temporarytopsoil stockpile

Temporarytopsoil stockpile Original profile of dump

Full “tortoise shell”rounding of dump

OD3.3 Re-topsoiling shaped dump from perimeter berm

Specification:

To topsoiling specification as per Method V3

OD3.4 Revegetate

Specification:

Conduct re-vegetation to re vegetation spec V3

OD4. LONG HAUL TOPSOILING OF SHAPED OVERBURDEN DUMPS OR

FOOTPRINTS OF REMOVED DUMPS WHERE NO TOPSOIL EXISTS

Specification:

Load topsoil ex topsoil berm, transport 1km and dump on rounded dump surface and spread (blade) to cover dump surface to min 50mm depth (but costed to 100mm depth).

OD5. FULL SCARIFICATION OF ROUNDED/TOPSOILED DUMPS to be

implemented with the 2014 revegetation Class level refinement in Method V3

Objective of OD5 spec.:

To loosen the topsoil and a rounded and topsoiled but as yet un-revegetated dump, to prepare such dump for revegetation. Specification: Scarify topsoil at 700mm spacing to the depth of topsoil which occurs on the dump (not deeper as it could introduce toxic substrate into the topsoil).

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OD6. BROAD SPACED SCARIFICATION OF PARTIALLY REVEGETATED DUMPS

to be implemented with the 2014 revegetation Class level refinement in Method V3

Objective of OD6 spec.:

Where shaped, topsoiled and partly vegetated dumps occur and vegetation is classified as sustainable, broad spaced scarification by hand raking or alternatively light tractor and grop to break any crust formed on the surface and/or to create undulations for seed entrapment promoting germination. Specification: Scarify by light tractor /hand hoe the un-revegetated areas of such dumps to topsoil depth and hand seed to seed rate specification in V3 OD7. RE-VEGETATION/SEEDING OF SHAPED OVERBURDEN DUMP to be

implemented with the 2014 revegetation Class level refinement in Method V3

Specification: Refer to specifications V3

CD. COARSE TAILINGS DUMPS

CD1. PROFILE/SHAPE (WEDGE-SHAPED DUMPS)

Objective of CD1 spec.:

Visual Impact reduction and reduction of side slopes to below angle of repose to improve safety and stability for natural re-vegetation of unshaped (wedge-shaped) coarse tailings dumps or shaping of the remnant coarse tailings dump where such dump would have been partially reworked or removed for use as fine tailings dam/dump cover. Specification: Round top point and side edges of dumps sketch below.

Ngl

Round edges of conveyor ramp

Round tip

Final profile

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CD2. CONSTRUCT COARSE TAILINGS DUMP PERIMETER PADDOCKS (LEACHATE CUT-OFF TRENCH) Objective of CD2 spec. To contain saline and silt run-off; to reduce impact thereof on the surrounding vegetation. Two alternative methods are offered below.

a) Paddock specification

Specification: At base of dump construct paddocks to serve as traps for leached fines, slumped material and leached saline drainage to prevent spread of dump toe into surrounding area and prevent saline run-off into surrounding soil and or vegetation. Doze paddock 10m wide and 0.5m deep generally as shown below.

b) Cut-off Trench alternative

Specification: At base of dump construct a trench 1m deep x 2m wide to serve as trap for leached fines, slumped material and leached saline drainage to prevent spread of dump toe into surrounding area and prevent saline run-off into surrounding soil and or vegetation.

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FD. FINE TAILINGS DUMPS / SLIMES DAM FD1.3$ Objective of FD spec. The primary objective of rehabilitation dumps/dams is the reduction/elimination of wind blown dust emanating from these dams/dumps once they dry out. The secondary objective is to soften their visual impact by rounding their shoulders, in any event required to reduce their outer wall slope so as to facilitate armouring with coarse tailings. The methodology is based on the urgency to stabilise the wind blown dust source (by pebble cover) and then relying on the observed roll of such pebble to accumulate wind blown sand and seed in the promotion of natural revegetation of such covered dumps. The methodology relies on the fact that there is always a large coarse tailings dump in 300m proximity of a fine tailings dam/dump. While specifications FD1.1 and FD1.2 accept the retention of the dump, specification FD1.3 provides for total removal of fine tailings dumps such as at Boegoeberg, where such dump falls within a post mining tourism node. FD1. OLD ABANDONED SLIMES DUMPS (HEAPS) (in the form of a heap not a dam)

FD1.1 Shaping of old abandoned dried fine tailings heaps Eg. Perdevlei

Specification: Shape (doze) dumps to max slope of 1:4 in preparation for pebble (coarse tailings) cover.

FD1.2 Armouring of Old Slimes Dumps (which will have been shaped by FD1.1 above) with medium / coarse pebble to prevent wind-blown dust generation

Specification: Cover shaped dump surface with pebble from nearby pebble dump/coarse tailings dumps (assume within 400m) and spread to min. 250mm deep over shaped dump surface. (Load from nearby dumps, transport to shaped dumps, tip onto dump and spread as specified).

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FD1.3$ Total Removal of Old Slimes Dumps

Overall Method of FD1.3 a) Load, Haul & Tip dump material to excavation filling

Specification: Load, haul and tip and spread overburden material in designated backfill area.

b) Scarify area where dump has been removed (light scarification)

Specification: Scarify hardened area to 150mm deep at 700mm spacing

c) Place topsoil from other source over scarified footprint area.

Specification: Conduct top-soiling to topsoiling specification as per Method V3

d) Revegetate

Specification: Conduct revegetation to re vegetation spec V3

FD2. CURRENT WALLED SLIMES DAMS

FD2.1 Profiling Outer Walls of Slimes Dam to Stable Slope (prior to pebble/coarse tailings armouring of such profiled walls to control wind erosion)

Objective of FD2.1 spec. The primary objective of the profiling of the outer wall is to achieve a reduced slope on which equipment can move and which can support a pebble/coarse tailings armouring.

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Specification:

Shape outer slope of slimes dam wall (by dozing) (if width provides without destabilizing wall) or with added dumped coarse tailings to outer wall to slope of max. 1:2. (preferable to 1:3.5) Assume 50:50 split between dozing and backfill.

FD2.2 Armouring of Profiled Slimes Dam Walls (outer slope) where no coarse tailings have been used on outer slope to create 1:3.5 slope.

Specification: Load coarse tailings with high pebble content from coarse tailings dump within 1km of slimes dam, transport to slimes dam wall and dump and spread to min 250mm deep

FD2.3 Construct Paddocks or Leachate cut-off trench around Slimes Dam Perimeter Toe

Objective of FD2.3 spec. To contain saline and silt run-off to reduce impact thereof on the surrounding vegetation. Two alternative methods are offered below.

a) Paddocks : Specification: At base of perimeter of profiled and armoured outer wall construct paddocks to serve as traps for leached fines, slumped material and leached saline drainage to prevent spread of dam wall toe into surrounding area and prevent saline run-off into surrounding soil and or vegetation. Doze paddock 10m wide and 0.5m deep generally as shown below.

Note: In the case of operational slimes dams paddock construction to be to full specification of the Code of Practise for Tailings Dames (DME)

Or

b) Cut-off Trench Alternative :

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Specification: At base of perimeter of profiled and armoured outer wall construct a trench 1m deep x 2m wide to serve as trap for leached fines, slumped material and leached saline drainage to prevent spread of dam toe into surrounding area and prevent saline run-off into surrounding soil and or vegetation.

FD2.4 Armouring of Full Slimes Dams Surfaces

ENSURE THAT SLIMES ARE SUITABLY DRY TO WORK ON WITH VIBRATING EQUIPMENT SUCH AS A DOZER WHICH CAUSES SOLFLUXION OF SEMI-DRIED SLIMES AND IN THE EVENT OF INSUFFICIENT DRYING COULD LEAD TO LOSS OF EQUIPMENT OR DEATH OF OPERATOR. Specification: Load coarse tailings with high pebble content from nearest coarse tailings/pebble dumps, assumed within 1km, transport to and dump coarse tailings/pebble on slimes dam surface and spread to final min. 250mm deep to prevent wind-blown dust generation off dried slimes dam surface. Application of 250mm is likely to be required to achieve effective 150mm cover.

OS. OVERSIZE DUMPS OS 1$ Prior to including such dumps in any rehabilitation project/contract, the Resource manager should assess whether such material constitutes a reserve a such boulders are in many cases heaps of stockpiled basal ferricrete with potentially high diamond yield, and should be reserved for crushing oin a future primary plant with suitable jaw size after pneumatic picking. Objective of OS spec. To reduce the visual impact of heaps of large rock (>400mm in dia) by:

a. recovering rocks in excess of 1ton for armouring of the Alexander Bay harbour wall and then either

b. burying the remaining in an excavation identified for backfill ; or c. shaping the remaining oversize dump and covering with coarse tailings and

allowing to re-vegetate OS1. SHAPE OVERSIZE DUMPS

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Specification: All oversize material not utilised as per a & b above will be rounded/shaped so as to limit dump height to 3m and then cover with coarse tailings/pebble. No topsoil to be provided (merely shape and cover) OS 1$. TOTAL REMOVAL OF OVERSIZED DUMP To same method and detail as FD 1.3, same cost items and output costs to spreadsheet.

KD. CONCENTRATE DUMPS KD1. As washed concentrate is saleable or useful in manufacture of exposed aggregate products and viewed as an opportunity for small business (job creation) in post- mining, no removal of these dumps or treatment thereof is proposed.

EX. EXCAVATIONS to be implemented with the 2014 revegetation Class level refinement in Method V3 Objective of EX specs. The objectives of the specification are split between:

a. Those excavations which fall within the visual envelope of post mining land use node (refer EX 5 below) and corridors where incomplete rehabilitation could detract from the cultural, visual, recreational and or tourism attraction of those post mining areas. For these excavations the emphasis is placed on the visual rehabilitation to as close to pre-mining status as possible/ justifiable.

b. Those excavations which are not directly exposed to future land use nodes and corridors or to visual exposure from key view points. For this group of excavations the objectives for rehabilitation are to make safe and non-polluting which is to be achieved by:

shaping the perimeter of the excavation (Excavation Edges) and re-vegetating such perimeter slope primarily to reduce wind erosion of existing steep slopes and resultant dust plume generation, to be implemented with the 2014 revegetation Class level refinement in Method V3

retaining the swept mine floors without backfill as sand traps with associated natural seeding and re vegetation observed in especially the thickly bedded bedrock areas.

EX1. MINE BLOCK OF DENUDED SCHISTS/SHALES BETWEEN NOORDSIF PLANT, THE OLD HMS AND ALEX BAY HARBOUR Note: The 2005 re-assessment of the purpose of treating these areas and the 2007 soil chemistry analysis reflecting the high phytotoxicity of soils derived from these volcanic origin shales has led to the total exclusion of these areas from the 2005 calculation and from the 2008 specification other than considering the specification below. This exclusion is based on the specialist botanist and soil scientist’s observation that where in-blown sand does accumulate sufficiently behind pebbles and in local hollows thus permitting germination and growth of plants to near maturity they are seen to die off as soon as their root systems penetrate through the accumulated sand into the weathered shale.

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Specification: In order to create some form of sand trap (undulated surface) and visually improve the appearance of the denuded landscape, it was considered to spread a coarse pebble thinly over the denuded surface through loading and transporting coarse tailings (+2mm material and pebble) from nearby dumps at Noordsif. However, in light of the impact of the shale derived soil chemistry on the plant roots intersecting the bedrock interface, this treatment will serve little purpose and consequently the exposed shale is to be left un-rehabilitated. EX2. OVERBURDEN REMOVED MINE BLOCK IN 1 – 4M DEEP OVERBURDEN AREA be implemented with the 2014 revegetation Class level refinement in Method V3 (not situated in visually sensitive post mining land use envelope) Specification: Note: Treat edge only not floor.

(i) Remove any in-situ topsoil/vegetation by blading/dozing for a strip of 10m wide to berm (assumed topsoil 150mm deep) around the perimeter of the excavation.

(ii) Doze edge of excavation to 1:3.5 slope into excavation as well as directly adjacent overburden dump material where such dump exists.

(iii) Blade topsoil from perimeter berm back over shaped excavation perimeter. (iv) Retain remaining exposed mine block floor as exposed rock area as wind

blown sand trap. (v) Re-vegetate the sloped edges by application of specification V3 (shade

netting and supplementary seeding) EX3. OVERBURDEN REMOVED, MINE BLOCK (with a well defined perimeter and depth of 4.1m to 12m) average 7m deep (treat edge only - not floor) be implemented with the 2014 revegetation Class level refinement in Method V3 Specification: (Refer sketch below)

(i) Remove any in-situ topsoil/vegetation by blading/dozing for a strip of 10m wide to berm (assumed topsoil 150mm deep) around the perimeter of the excavation.

(ii) Doze edge of excavation to 1:3.5 slope into excavation as well as directly adjacent overburden dump material where such dump exists.

(iii) Blade topsoil from perimeter berm back over shaped excavation perimeter.

(iv) Retain remaining exposed mine block floor as exposed rock area as wind blown sand trap.

(v) Re-vegetate the sloped edges by application of specification V3 (shade netting and supplementary seeding)

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a) Where topsoil does occur up tomine block perimeter, blade topsoil toassumed 150mm depth back ±30mfrom mine block perimeter beforecommencing with the shaping

Directly adjacent or"Overhanging"overburdendump (see Photo AV2)

Depth 4-12m (Average 7m)

B) Once perimeter profiling bydozer is complete, blade topsoil back over reshaped perimeterto 50-100mm deep

New dozed perimeter profile

Retained exposedmine block floor

Ngl

Detail of toe slopeand finish not finalised(assume as per Photo SZ-A21)

The method of rehabilitation is:

to doze the adjacent overburden face and

any directly “overhanging” overburden dump material over the face perimeter into the excavation as partial backfill.

EX4. MINE AREA IN DEEP OVERBURDEN-REMOVED UNDULATING AREA WITH POOR “BLOCK” DEFINITION AND MINING DEPTH >12M DEEP (Refer photos AV2, Oa2, Oa1, FB 28-31, AW14-15, B33) Objective of EX4 spec: Such deep mining by Alexkor has to-date been restricted to the Voltas area. As this deep-mining offers the opportunity to serve as a visitor attraction within the mine tour context (during and post mining), there is a conflict between reserving the area for tourist attraction (the negative element being that of safety and potential high dust generation) or alternatively reshaping it to specification EX4 as specified below. In both cases wind blown sand is a significant consideration and while wind-break netting and supplementary seeding on a reshaped and topsoiled profile will achieve more than partial netting and re-vegetation of the existing profile with existing floors serving as sand traps, the decision to mine the blocks of unmined floor below the retained “pillars” is likely to be the determining factor in the choice between rehabilitation and retention as a tourist attraction. As at March 2015 this area is included in the area for new mining prospecting, and consequently such decision will be taken at the appropriate time. In these deep poorly defined mining areas (not “blocks”) where overburden had in most cases been dumped in high (10m high) dumps in the mining area and then these dumps were later partially undercut by mining, no standard mine block dimensions can be designated and consequently a cost is sought for general re-shaping of the area to provide for: Specification: (Refer sketch below) The cost for general re-shaping of the area to provide for:

(i) the rational improvement of the landscape appearance (ii) creating an undulating but “waved” profiled surface with slopes which can

be pebble stabilised or on which revegetation can be considered to

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prevent wind-blown dust generation through, bulk earthworks by combined dozing and excavator loading and dump truck hauling of an estimated 25% of original excavation volume.

(iii) Re-vegetate the undulating surface by application of specification V3 (shade netting and supplementary seeding)

Post mining profile in cross section view

OverburdenOverburden

Overburden

Envisaged finalsurface

Ngl

Certain excavationfloors retained

EX5$. OVERBURDEN REMOVED, MINE BLOCKS WHICH FALL WITHIN THE VISUAL ENVELOPE OF POST MINING LAND USE PRECINCT be implemented with the 2014 revegetation Class level refinement in Method V3 (with a well-defined perimeter and depth of less than 12m) Typically this will apply to the rehabilitation of the mine floor between the two Boegoeberge, and accordingly such Mine Floor is dealt with in its own Pivot Table (Mined Floor Peacock Bay Node) Objective of EX5 spec. Any excavations which fall within the visual envelope of post mining land use node or corridor shall be rehabilitated to a level that (as far as practically and economically possible) resembles the pre-mining status. Given the elevated status of these post mining land uses areas, additional emphasis will be placed on rehabilitation of excavations within these areas and will include:

shaping the edges to a lower gradient (1:4-1:5)

ensuring total cover of exposed floors (using additional imported backfill if required)

Providing sufficient topsoil over the entire shaped excavation

Conduction supplementary seeding Specification: (i) Remove any in-situ topsoil/vegetation by blading/dozing for a strip of 10m wide to

berm (assumed topsoil 150mm deep) around the perimeter of the excavation. (ii) Doze edge of excavation to between 1:4 – 1:5 slope into excavation as well as

directly adjacent overburden dump material where such dump exists. (iii) Bring in additional fill material to cover any exposed floors if required. (iv) Blade topsoil from perimeter berm back over shaped excavation perimeter. (v) If required , bring in additional topsoil to fully topsoil shaped area

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(vi) Re-vegetate the sloped edges and floors by application of specification V3 (shade netting and supplementary seeding)

a) Where topsoil does occur up tomine block perimeter, blade topsoil toassumed 150mm depth back ±30mfrom mine block perimeter beforecommencing with the shaping

Directly adjacent or"Overhanging"overburdendump (see Photo AV2)

Up to12m

b) Once perimeter profiling bydozer is complete, blade topsoil back over reshaped perimeterto 50-100mm deep and supplement with additional imported topsoil if required

Ngl

Final profile 1:4-1:5

TR. TRENCHES TR 5$ be implemented with the 2014 revegetation Class level refinement in Method V3 Objective of TR specs: The objectives of this specification are split between:

a. those trenches which fall within the visual envelope of post mining land use node and corridors where incomplete rehabilitation could detract from the cultural, visual, recreational and or tourism attraction of those post mining areas. For these trenches the emphasis is placed on the visual rehabilitation to as close to pre-mining status as possible/ justifiable.

b. those trenches which are not directly exposed to future land use nodes and corridors or to visual exposure from key view points. For this group of excavations the objectives for rehabilitation are to make safe and non-polluting which is to be achieved by:

shaping the sides of the trench and re-vegetating such perimeter slope primarily to reduce wind erosion of existing steep slopes and resultant dust plume generation

retaining the remaining V-shaped depression (ie: without backfilling entire trench to ngl) as sand traps with associated natural seeding and re vegetation currently observed

The distinction between trenches on the basis of future land use is further considered within the context of trench shape (i.e : V vs U-shaped) and the level of re-vegetation already occurring in certain V-shaped trenches be implemented with the 2014 revegetation Class level refinement in Method V3. TR1 “V” shaped trenches <3,5m deep in soft sand overburden where no hardpan (brown dorbank or white calcrete) layer exists in the profile below the topsoil and where natural re-vegetation has not occurred to a level which classifies the trench as re-vegetated, be implemented with the 2014 revegetation Class level refinement in Method V3

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Specification: a) Blade/doze topsoil (to assumed 150mm deep), away from trench edge for 9m

wide strip on each side of trench to temporary topsoil/vegetation berm when trench is 3m deep or alternatively doze strip 3m wide where trench is only 1m deep.

b) Conduct slope trimming of trench to max. 1:3.5 trench side slope. c) Blade/doze topsoil from temporary berm back over profiled edge to average

depth of 100mm d) Re-vegetate the sloped edges and floors by application of specification V3

(shade netting and supplementary seeding)

TR2. “V” shaped trench >3,5m deep: no hardpan horizon occurs be implemented

with the 2014 revegetation Class level refinement in Method V3

Specification:

a) Blade/doze topsoil (to assumed 150mm deep), away from trench edge for 10m wide strip on each side of trench to temporary topsoil/vegetation berm when trench is 7m deep.

b) Conduct slope trimming of trench to max. 1:3.5 trench side slope. c) Blade/doze topsoil from temporary berm back over profiled edge to average

depth of 100mm d) Re-vegetate the sloped edges and floors by application of specification V3

(shade netting and supplementary seeding)

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TR3. “U’ shaped trench <5m deep (Average 4m deep) (Ref photos OA 4 and ‘4-21) be implemented with the 2014 revegetation Class level refinement in Method V3 As U-shaped trenches are noted in 2014 Groundtruthing to often have served as significant wind-blown dust traps , with such trapped sand fill now at acceptable slopes with significant natural revegetation, the groundtruthing classification in terms of the revegetation class level refinement in V3 has classified such U-shaped trenches for only partial treatment to avoid the disturbance of such sand-filled areas Specification:

1. Blade/doze topsoil to assumed 500mm deep (in hard-pan/dorbank/calcrete not phytotoxic) away from trench edge for 7m on each side of trench to temporary topsoil/vegetation berm for trench average 4m deep.

2. Conduct slope trimming of trench to max. 1:3.5 side slope. 3. Doze/blade hardpan material over sloped backfill. 4. Doze/blade topsoil over the smoothed hardpan material. 5. Re-vegetate the sloped edges and floors by application of specification V3

(shade netting and supplementary seeding)

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TR4. “U” SHAPED TRENCH >5M (5-18m average 7m deep)(ref photos OA – 4 and ‘4-21) be implemented with the 2014 revegetation Class level refinement in Method V3 (In soft sand overburden where hardpan horizon occurs below the topsoil.) Specification: As per TR3 with the only difference being the depth of trench and related width of topsoil and hardpan removal by dozing.

TR5$. TOTAL BACKFILL OF V or U-SHAPED TRENCH IRRESPECTIVE OF DEPTH be implemented with the 2014 revegetation Class level refinement in Method V3 where trenches occur in post mining land use nodes or corridors Objective of TR5 spec: Any trench which falls within the visual envelope of a post mining land use node or corridor shall (unless it presents in the ground truthing as a well re-vegetated, stable V-shaped trench with low visual impact) be rehabilitated by total backfill or to a level that (as far as practically and economically possible) resembles the pre-mining status and a shall have its surface smoothed to a max 1:5 slope with re-vegetation to specification V3 Specification: a. Backfill trench either totally or to a level which will permit the shaping of the surface

to slopes of not more than 1:5. b. Generate sufficient topsoil to cover the filled trench by either:

i. Importing a portion of topsoil being removed from new works nearby to the trench; or

ii. Blading 75mm of topsoil from the area immediately surrounding the trench onto the trench backfill (i.e by borrowing topsoil from an area equivalent in area to that of the trench). It is proposed that such borrowing leaves strips of undisturbed topsoil in the borrow area to ensure retention of full plant species and seed bank in these retained strips.

c. Re-vegetate the surface of the fully backfilled or the 1:5 sloped sides by implementation of specification V3 (shade netting and supplementary seeding)

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PROCESSING PLANTS TP 3$, TP 6$ & TP 9$ TP. Terrestrial plants

Objective of TP spec: The objective in rehabilitation of terrestrial plants acknowledges that during the establishment of plant and use of the plant site together with associated slimes dam and coarse tailings dump which develop adjacent to a terrestrial processing plant, the site is so transformed that return of these sites to their pre-mining condition is simply not economically justifiable and in any event there is no topsoil available for the cover of these areas. Fortunately none of these sites, other than the sea diamonds recovery plant and a remnant of the old Boegoeberg plant, occur in close proximity to post mining land use node or corridor. In light of the above, the plant and plant area rehabilitation specifications are limited to practical and economically justifiable actions with reliance on long term sand tapping and re-vegetation towards more complete rehabilitation. For example, no reinforced concrete foundations are removed from the ground and concrete floors are covered in coarse tailings. Only in the case of the remnant structures of the Boegoeberg plant and the sea diamonds recovery plant, will total removal and re-vegetation be done. TP1. Removal of all steelwork

TP1.1 Re-use plant structure elsewhere – no consideration

OR

TP1.2 Includes, demolition, cutting, driving away and recovery of saleable value to contractor account

Specification: Scrap steel/used mining plant. Dealer to cost to remove all plant steel structures under agreement that he may dispose of all saleable plant and scrap steel to his benefit

TP2. Demolition and removal of all structural concrete Specification:

(i) The demolition of all concrete and brick pedestals, retaining walls, wing walls, columns, beams and elevated platforms and includes the raw water reservoir and the main production control office and the primary hopper control room. Demolition generally to ground level with no protruding structures to remain above a max. of 200mm above immediately surrounding ground level and includes the main production control/office which is generally two storeys;

(ii) The removal of such waste rubble from the plant site and dumping thereof in a designated builders rubble site; and

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(iii) Cover of such waste concrete with coarse tailings loaded and hauled from the plant’s coarse tailings dump ensuring that the borrow area in the borrow dump and the covered waste are stable and neatly trimmed.

TP3$. Removal of plant footings and floors (optional requirement in elevated rehabilitation areas of post mining land use nodes) Specification: Removal of: Plant pedestals. Plant pedestals and drip floors, concrete channels and plant walls. In the event that plant footings which protrude less than 200mm above surrounding ground level and concrete floors <200mm above ground level have to be removed instead of being covered

(i) Remove concrete from ground; (ii) The removal of such waste rubble from the plant site and dumping thereof

in a designated builders rubble site; and (iii) Cover of such waste concrete with coarse tailings loaded and hauled from

the plant’s coarse tailings dump ensuring that the borrow area in the borrow dump and the covered waste are stable and neatly trimmed.

(iv) Lightly topsoil the coarse tailing cover to 50mm deep with imported topsoil as per TP 9 below

(v) Re-vegetate the covered surface by implementation of specification V3 (shade netting and supplementary seeding)

TP4. Cover of retained plant footings, foundations and floors Specification: (Only if TP-3 above is not applied) Cover of retained plant footings, foundations and floors which do not protrude >200mm above immediate surrounding ground level (inclusive of the raw water reservoir floor) with coarse tailings/pebble. Requires loading coarse tailings and pebble from plant’s dumps located within 200 to 500m of the site, transport, tip and smoothe to give cover of 500mm above ground level. Note: Such coarse tailings cover of the terrestrial plant node areas receives no topsoiling as the cover will form a deflation surface, gradually accumulating inblown dust with seed, and relies on total natural revegetation over time. TP5. Demolition of logistical buildings

TP5.1: Demolition of Formal Workshops 5 – 6m high steel framed brick infill generally to 2m with asbestos cladding above. Assume contractor may sell recovered structures and scrap steel for own account where possible. Buildings to be demolished to floor level with retention of floor which is to be covered under separate item TP7

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Specification: (i) Remove steel structure (ii) Remove asbestos cladding (iii) Transport Asbestos to designated Alex Bay asbestos waste site –

Allow average 20km. Cover material for a licenced Asbestos waste site to be obtained from nearest plant’s coarse tailings dumps, with borrow area in dump to be left neatly shaped and stable. Refer para 3.3.3.2 regarding asbestos waste site licencing.

(iv) All builders rubble to be disposed of in demarcated builders rubble sites.

TP5.2 Demolition of lighter construction logistical buildings of 3 – 4m high generally brick or cement block built but includes certain structural concrete such as in upper floors of the transformer house. Demolition to floor level provided that no floors or foundation protrudes >200mm above ground. Average plant has 540m² of such structures.

Specification:

(i) The demolition of all walls (ii) Remove asbestos roof and haul and dump at asbestos disposal

site/collection point (iii) Haul and dump builders rubble to designated builders rubble site (iv) Cover rubble in builders rubble site to finish with coarse tailings

TP6$. Removal of all demolished light block construction building floors and foundations (optional requirement in elevated rehabilitation areas of post mining land use nodes)

TP6.1: Remove workshop floors, foundations.

TP6.2: Removal of all demolished light block construction building floors and foundations and tipping and burial of such waste rubble as per specification TP6. Assume normal strip footings and 75 – 100mm thick floors.

Specification:

(i) Break concrete out of ground (ii) Transport to builders rubble site; and (iii) Cover rubble in builders rubble site to finish with coarse tailings

TP7. Cover of retained light building foundations and floors (only if TP-6 above is not applied) Specification: Cover of retained light building foundations and floors (if retained) i.e. not included in specification TP6 above) to 500mm cover above surrounding ground level using coarse tailings/pebble from the plant’s coarse tailings dump. Smoothe cover off and ensure borrow area is smoothed and stable.

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TP8. Conduct shaping and cover of the primary ramp and ad hoc tipped coarse material dumps Specification: Once the retaining and wing walls have been removed, shape the primary ramp and all ad hoc dumps in the proximity of the plant manoeuvring area with slopes to 1:3.5 and cover with coarse tailings ex. coarse tailings dump to min. 150mm cover.

TP9$. Topsoil (coarse tailings cover) selected area of the plant’s manoeuvring and logistical facilities area (optional requirement in elevated rehabilitation areas of post mining land use nodes)

Specification: Load, haul and cover to average 50mm deep with topsoil from a designated borrow area assumed 1km from site (do no cost for rehabilitation of the topsoil borrow pit). TP10. Rip or scarify compacted plant logistical maneuvering area (D-6 with 3- 5 tangs or grader with 5-7 tangs) Objective of TP10 Spec: To improve the permeability of the compacted areas and to form an improved key between the cover material and the substrate. Specification: (Either directly or after topsoiling). Either: o Rip by D6 to 300mm deep at ±0.7m centres; or o Scarify by grader to 100-150mm deep at 250-300mm centres TP11. Sparsely armour selected portions of the plant / manoeuvring area Specification: Sparsely armour selected portions of the plant / manoeuvring area with coarse pebble to prevent wind-blown dust. Load pebble from coarse pebble stockpile area within 1km of site, transport and spread directly delivery from vehicle at rate of 1m³ pebble per 20m² ground surface Assume 1ha/plant area to be covered.

TP 12. Provision for general site works Load, haul, tip and spread

PP. Prospecting Plants Specification:

(i) Remove mobile plant and logistical containers (ii) Scarify hardened manoeuvring area (iii) Spread topsoil ex topsoil berms (iv) Conduct re-vegetation to Spec V2

FP. Final recovery plant (Alexander Bay)

As this is a long term provision no detail is done now, but it can be assumed that it will be done in accordance with the combination of other specifications for building removal and site rehabilitation.

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OP. Very old HMS plant (Main multi-storey building & old concrete reservoirs) OP- 1: Extent of Building Given the riveted method of its steel construction and its plastered marine ply sheeting together with its shape which is reminiscent of old mine works buildings, this structure is identified for preservation as an historic site. Consequently only the low buildings and old concrete reservoirs are identified for demolition and treatment of their footprint. OP-2: Extent of Concrete Reservoirs Specification: Demolish 4 x concrete reservoirs and bury in builders rubble designated site as per builders rubble.

HP. Historical plants HP1. Merensky plant 2015 In-Out Workshop and site visit of 2014 confirmed merits of demolishing and removal of all structuers as access results in high impact in the low-lying rehabilitating lee hummock dune area of the Noordsif slimes dam

JP. Jigging plant area at Muisvlakte Mainly removed by 2014. Removal of remnant structures in accordance with the Built Structures Baseline Table.

MP. Mobile plants of contractors (in-field screening and jigging plants)

The removal of all mobile plants includes:

(i) mobile in-field screening plants (Findlay type) (ii) composite but generally mobile custom built screening plants; and (iii) semi fixed but generally modular mobile concentrating plants

and is the responsibility of the contractors in terms of respective mining contracts, and for which such contractors provide separate rehabilitation funds, no provision is made for rehabilitation of such plants or sites.

SPECIFIC FACILITIES

CF. Central fuel storage and despatch facility (Alexander Bay) Bulk diesel tanks (refer photo C21 (two tanks with bund wall)) 1 of total 2 million litres capacity each with security fence, Small control building and the separate main fuel despatch facility:

(i) one external bunded diesel tank (fed from the bulk tanks) (ii) one underground petrol tank; and (iii) the dispatch buildings and external concrete aprons

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(iv) as well as a diesel pipeline of 250m which connects the bulk tanks to the despatch buildings to be removed

Specification:

(i) Remove bulk tanks (steel to contractor account) (ii) Remove 1 x diesel tank and 1 x petrol underground tank (despatch

facility): (iii) Demolish Buildings and bund walls to surrounding ground level (±50m²) (iv) Remove diesel pipeline of 250m which connects the bulk tanks to the

despatch buildings (v) Fill removed petrol tank excavation. (vi) Cover disturbed area including demolished building floor and apron

with coarse tailings to 150mm (vii) Rip/scarify to 300mm deep (after cover) (viii) Conduct re-vegetation to Spec V3

IW. Central inside workshop (Refer photos H10 & AU13)

Objective of Spec IW: Given the high cost versus low benefit of removal of heavy foundations and footings and the fact that workshop floors are heavily reinforced, removal of foundations and floors is not contemplated but all structures will be removed to floor level with no protrusions above 200mm above immediately surrounding ground level. Given the potential hazard of dust generation from topsoiling these floor areas directly south of Alexander Bay town, it is not envisaged to topsoil these areas but to merely cover them in coarse pebble ex. the tailings dump of Noordsif ±3km away. Specification:

(i) Remove steel structure new workshop for sale (ii) Remove asbestos cladding to asbestos waste site (iii) Demolish brick and concrete old main workshop and power station

building , tip in designated builders rubble site (iv) Demolish low rise buildings and tip rubble (v) Cover to 300-500mm thick over a gross area with coarse tailings transported

over a distance of 3km from Noordsif Coarse Tailings dump

HB. Alexander Bay Harbour and Logistical Facilities As the infrastructure of the harbour and harbour control office, its fuel tanks and its workshop, stores and personnel amenities are all required for the sustained operation of the harbour to serve the post-mining community, no demolition of only certain informal facilities at the site is envisaged. Provision is only made for the rationalization of manoeuvring area with requiring ripping of the excess compacted areas and clear demarcation of the retained roadways and parking and manoeuvring areas.

DW. Domestic waste site within the security area

Specification:

(i) Cover of remaining open waste with 1,0m deep overburden material by dozing assume 500m² at 1,0m deep (doze 500m³ of material).

(ii) Shaping of cover to rounded land form by dozer during cover. (iii) Removal of fence (±150linear m)

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(iv) Ensuring stormwater drainage cannot impact on waste site in long term by ensuring structure trench if required is operational.

(v) Scarifying access road of 500m long x 5m wide. SY. Salvage yard/industrial waste disposal sites

Assumptions: As the current activity of salvaging and selling all scrap metal and tyres is well advanced, the volume of remaining non sale-able scrap and fine rubble is significantly reduced as at 2014, but the site is reserved for its licenced purpose to serve the lfie-of-mine, following which it will be closed and rehabilitated. Specification: As follows: (i) Load and haul average 0,6m deep remaining mix of small waste metals, plastics,

etc., tip such material in despatch landfill/land building area at base of old cliffed mining area (haul distance ±0 to 400m). Build new landfill/landbuild dump to maximum height of 6m above present disposal site level.

(ii) Cover land build dump with 1m thick material continuously excavated from landfill/build operation:

Estimated land build dump is 10 000m² x 6m high

Obtain overburden cover from continuous strip and cover operation during tipping of waste or doze down from adjacent overburden dump.

(iii) Smoothe entire old salvage yard area of 10ha where scrap has been moved (iv) Armour entire smoothed old salvage area and land build dump (which have now

been covered with overburden) with coarse tailings/pebble ex. the coarse tailings dumps of Noordsif 3km away (to prevent dust generation off the rehabilitated surface).

(v) Remove fencing and leave site tidy.

AW. Asbestos waste site As per paragraph 3.3.3.2 the licencing of an asbestos waste site within the security area is being undertaken at March 2015 and when approved will serve as the Alexkor mine asbestos waste disposal site and will be managed will be managed in accordance with the licence prescriptions.

2014 FURTHER FACILITIES

HC. Hostel Complexes at Alexander Bay The demolition of the hostel complexes is dealt with in the respective built structures classes as per brick built structures. Demolition is selective in accordance with the classification of the buildings in phases and will entail demolition of the structure and burial of builders rubble at the designated builders rubble waste site, with retention of the floors and foundations, and cover thereof in coarse tailings to the same treatment as terrestrial nodes and workshop complexes

MO. Main Office Complex The demolition of the office complex is dealt with in the respective built structures classes as per brick built structures. Demolition is selective in accordance with the classification of the buildings in phases and will entail demolition of the structure and burial of builders rubble at the designated builders rubble waste site, with retention of the

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floors and foundations, and cover thereof in coarse tailings to the same treatment as terrestrial nodes and workshop complexes

OW. Outside Workshops and Stores Complex The demolition of the workshop and stores complex is dealt with in the respective built structures classes as per brick built structures. Demolition is selective in accordance with the classification of the buildings in phases and will entail demolition of the structure and burial of builders rubble at the designated builders rubble waste site, with retention of the floors and foundations, and cover thereof in coarse tailings to the same treatment as terrestrial nodes and workshop complexes

DC. Old Security Dog Centre at Alexander Bay The demolition of the dog centre is dealt with in the respective built structures classes as per brick built structures. Demolition is selective in accordance with the classification of the buildings in phases and will entail demolition of the structure and burial of builders rubble at the designated builders rubble waste site. Given the proximity of the site to direct view from the public road (tourism route) and the adjacent lichen hill, all floors and foundations will be removed and instead of coarse tailings cover, the site will be topsoiled and revegetated to as per specification V3, with special regard being paid to the harsh climate of the site and the high wind conditions which exist on the elevated west slope of the lichen hill

SECURITY FACILITIES AND OTHER ACCOMMODATION

SB. Security buildings SB1-4 Security buildings at Muisvlakte East, Muisvlakte West, House & Facilities at Alexander Bay Beach and Miscellaneous security facilities at Obeep Section Activities:

(i) Demolish buildings (ii) Cover retained floor areas in coarse tailings (iii) Topsoil hardened areas (iv) Scarify hardened areas (v) Provision for general tidying

In the case of the security buildings on the primary dune north of the OHMS, all structures, footings and floors to be removed to fully restore the dune ridge. In the case of Obeep, it is noted that the Old Police Station Building was previously restored as a monument and shall not be demolished, but again be retored to this function. SB5. Accommodation complex at Muisvlakte Given the good construction of the complex and its proximity to Port Nolloth this complex has been developed as a bed and breakfast facility and shall be retained.

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SB6. Accommodation units south of Perdevlei and old security complex (fuel supply depot) on Perdevlei access road

SB6.1 The predominantly wooden structures in process of demolition during 2014 groundtruthing are to be completed with all builders rubble disposed of at designated builders rubble site, inclusive of floors and foundations which are to be removed. Site must be scarified.

SB6.2 Demolition of structures (temporary and 3 x small permanent block structures) at Perdevlei security (road fuel depot).

All rubble to be buried in designated builders rubble site at Perdevlei Plant.

SB6.3 Demolition of the remaining hostel block accommodation facility south of Perdevlei plant, retained floors covered with coarse tailings. All rubble to be buried in designated builders rubble site at Perdevlei Plant.

TRUNK ENGINEERING SERVICES (ES) Objective of Trunk Engineering Services Specs The retention vs demolition of these services will be determined during annual OEMP updates on the basis of:

Whether such services require retention to serve plants which are either mothballed or intended for future use; or

Whether such services should be retained in support of the post mining land uses for the serviced area.

For example the retention of electrical and fresh water supply to plants in proximity to post mining land use nodes or the retention of sea-water pump stations with their electrical supply where these can supply facilities for mariculture.

EL. Electrical lines (external to plant sites) Mine management must ensure that the Eskom connections at the 3 Eskom supply switching stations are retained despite possible periods of them not being used during new mining, as they may be required to serve post mining land use development

WP. Water pipelines (external to plant sites) As in the case of bulk electrical supply, mine management in respct of fres water supply must ensure the retention of supply points on the Alexander Bay-Port Nolloth water pipeline and the pipelines from these points to the respective nodes to serve possible post mining land use freshwater supply.

SP. Sea water pump stations (external to plant sites) The “In”-“Out” meeting of 3 February 2015 selected which of the pump stations are to be demolished and which retained as recorded in the Built Structures Baseline Table in Annexure A. The individual facility record in Annexure A is of sufficient detail to reflect the retention of certain components of the seawater pumping facilities while retaining certain others. In general where demolition is contemplated, this will not include the concrete foundations and concrete platforms and pedestals below the high water mark as the removal thereof will have a higher impact that their retention.

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FS. Fences (security) As the role of fences in a future consideration of farming, or conservation environment is not known, nor the level of security which may be required to be maintained until complete closure of the mine, it is not possible to prepare a schedule of fence removal at this stage. All existing fences will be managed by new mining within overall mine security consideration of both Alexkor SOC and RMC JV

ENVIRONMENTAL RECTIFICATION ITEMS

DP. Dust Plume Management

(Limited to physical control of major dust sources by shaping and pebble armouring and the provision cut-off fences) As the 2014 dust plume study report SPC#2714/DP/R1 fully details the management of windblown dust for the site, all windblown dust control shall be conducted in accordance with such study, which primarily targets, as highest priority, the reduction of windblown dust by stabilization of the dust sources and through the use of cut-off netting systems where the captured dust/sand is removed periodically for burial in existing excavations, insodoing reducing the total dust in the mobile system. The application of the 2014 revegetation Class level refinement in Method V3 has the aim of further reducing future dust generation off of denuded areas through assisted natural revegetation. As per the set of rehabilitation methods, each of the methods where application of the V3 specification is relevant are marked accordingly.

SP. Seepage Prevention Saline seepage impact (Rietfontein South), rectification is taken care of in the respective methods per individual slimes dam and coarse tailings dump through the provision for paddocks or cut-off trenches around these facilities which leach saline water and threaten surrounding soil and vegetation.

BI. Beach Interface Rehabilitation Refer Part B-1f Beach Dune Dynamics Beach-intrusion overburden dumps

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In respect of overburden dumps which have been developed with a seaward slope onto the beach, the 2008 coastal assessment revealed a vast range of impact considerations and in fact found that certain dumps had surprisingly low impact , other than visual, revealing unexpected natural revegetation of such slopes despite their steepness and not warranting rehabilitation rectification as the activity would likely have a greater impact than the retention of such dumps. The level of revegetation was ascribed to the sea-mist with high levels of condensation ocurring at those specific sites. The classification of such overburden dumps in the Overburden Dump groundtruthing GIS file therefore directs the rehabilitation primarily at the stabiliasation of the surface of such dumps, and the shaping of the upper edges and treatment of landward lee slopes which is where wind undercutting erosion is the source of high windblown dust downwind. Accordingly, the V3 revegetation specification inclusive of percentage shaping is to be applied. On-shore operations of shallow water contractors (walpompe) The specification F8 is contemplated in the 2008 EMP Part F to manage the environment of Walpomp operations, in order to avoid the future degradation of especially the hummock dune and primary dune zones. Such degradation which has occurred through historical walpomp operations is prevalent in many areas along the entire coastal zone of Alexkor Mining Area, and with the nature of disturbance (levelled tops of dunes, roadways through dunes, etc) being very specific to each site, and the sites occurring within varied back-of-beach topographies, no generic method can be specified and accordingly the rehabilitation intervention in order toa void further degradation through such actions must be carefully specified on a site for site basis by the ECO and it is recommended that this task which entails very local and light equipment requirements would best be done by an internal dayworks team.

AR. Archaeological Restoration, preservation/protection Part B-1i Archaeology in the 2008 EMP serves together with the 2014 additional sites recorded in the specialist archaeological visit of May 2014, to record the archaeological sites for preservation, and will serve in the overlay analyses of the LEMPs for rehabilitation contracting. The Environmental specification F-10 from the LEMP compilation methodology in the EMP Update for: operating procedures for reporting and response to archaeological finds, deals with the management of archaeological finds during both new mining and execution of rehabilitation, and will be attached as a methodology to the respective LEMPs contemplated for rehabilitation projects.

WI. Wetland interface The EMPR commits Alexkor to the following tasks in terms of the preservation of the Mining Interface with the RAMSAR site:

a) To ensure the completion of the digging of the cut-off channels on the outside of the Noordsif new slimes dam wall but outside of the RAMSAR fence to ensure that such trench fulfils the function of preventing saline leachate from the slimes dam into the salt marsh of the estuary by discharging such water into the pumping sump adjacent to the old HMS plant.

b) To commit to assisting the RAMSAR management in the removal of sections of the old beach access road which is restricting the flushing of the salt marshes.

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c) Shaping and coarse tailings covering of the Old HMS fine tailings dump to terminate the wind blown dust into the Southwest corner of the estuary.

d) Ensuring that no other sources of dust develop which can threaten the vegetation of especially the salt marsh (e.g. The Noordsif slimes dam if allowed to dry would pose such threat).

As at March 2015 we note that vast areas of the old HMS fine tailings dump have ben armoured and that further armouring of the newer northwest slimes dam is a priority project. Furthermore, the fine tailings dump on the edge of the beach immediately north of the OHMS which was the main source of windblown dust impacting on the wetland salt marsh, has been totally removed. The mine management remains in liaison with the relevant authorities managing the Orange River Estuary.

V Vegetation V3 (2014 revegetation Class level refinement)

V3.1 V3. 2014 Fully expanded and updated Revegetation Methods and Levels This overall method is based on a synthesis of what was contained in the EMP analysis and proposed V-2 Method, subsequent observations since 2008 and the AAR-P specialist botanist findings of 2013/2014 and an overall reconsideration of that total review. The V-3-2014 overall revegetation Method is comprised of the following:

(i) Pre-shaping must be in accordance with the method specified for the disturbance under consideration regarding sloping and rounding (but specifically to note that smoothing must not be excessive in order to provide undulations favouring seed and normal levels of wind-blown sand entrapment) in order to provide best pre-condition for seed capture, retention and germination.

(ii) Topsoil management The vegetation and revegetation assessments have shown that the presence of a suitable growing medium “topsoil” is absolutely critical in revegetation, and accordingly the following two elements are fundamental in the topsoil/revegetation consideration:

Prior to disturbing natural areas for implementation of mining or rehabilitation, the planned removal and temporary stockpiling of topsoil for later use is fundamental

Prior to revegetating the surface, soils must be assessed for their suitability to serve as growing medium “topsoil” for the planned revegetation, and if not suitable to rectify the situation by growing medium replacement to a target level of 100mm of loose sandy soil (which is not phytotoxic), and to conduct such “top-soiling” with due regard to the natural revegetation classification on scale 1 – 5 against the principle of minimal disturbance of naturally revegetated areas.

Critical Elements in Topsoil management must include

a. Where larger shrubs occur in an area where topsoil is to be removed, such larger shrubs are to be “transplanted” to a current re-topsoiling area prior to topsoil removal.

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b. Ensure that no use of any previously undisturbed area or previously re-topsoiled area takes place prior to the suitable removal and stockpiling of topsoil with its seed bank.

c. In the removal of topsoil it is critical that the upper aeolian topsoil, which forms the root zone, is identified and separately removed, and stockpiled separately from any subsoil.

d. Ensure that where layering in the soil is observed at depths below 300mm prior to removal, that only the sandy aeolian topsoil of as little as 100-150mm which is readily recognizable by eye and is not silty/clayey is removed as topsoil (this simple assessment will ensure the avoidance of mixing phytotoxic silty/clayey subsoils into the topsoil stockpile.

e. Preferably re-use the topsoil and its seed bank either directly as highest priority or stockpile in low stockpiles not exceeding 1m in height for a maximum of 3 month period and definitely re-use topsoil prior to the first rainy season following removal.

f. After re-placement of topsoil, rake the surface to 20mm deep to create surface undulations as seed traps, hand sow seed in raked areas and lightly cover with back of rake to max 20mm. Ensure not to rake deep i.e. not through the re-placed topsoil layer as such deep raking could mix underlying phytotoxic material into the good topsoil, and deep burial of the seed will also not promote its germination.

(iii) If shaping is satisfactory and suitable growing medium is present but natural

revegetation has not progressed as expected: o Check for phytotoxicity: o If present conduct full remediation for phytotoxic dumps including:

reshaping where required. Deep scarification to provide a key for growing medium cover. Placement of growing medium to 100mm over phytotoxic

material. Conduct full revegetation intervention by seeding and raking

and consider implementation of wind-break netting. o If not phytotoxic:

Hand rake un-vegetated/patchy areas with minimal disturbance of existing vegetation.

Seed and rake. Provide wind-break netting if appropriate.

(iv) Seeding

o Collection of seed in natural veld areas by vacuum and drying and storage of seed until suitable planting opportunity.

o During and following a rain episode, seed by hand broadcasting of seed with simultaneous raking to provide undulating surface for thin sand cover and further seed entrapment of in-blown seed.

o Seed to be hand broadcasted at a rate of 5-10 kg/ha which rate will vary from south to north (and be specified in the final specification in the tenders).

o Seed collection should contain as broad a range of species as possible from the species list in Annexure F).

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The suggested seed collection areas for use in seeding and supplementary seeding are the veld areas typically showing the following species: The first species (pioneers) to participate in colonizing sand traps are observed as: Cladoraphis cyperoides Seeriet Lebeckia multiflora Fluitjiesbos Psilocaulon dinterii Asbos Didelta carnosa var tomentosa Vaal perdebos Othonna sedifolia Karoorapuis Mesembryanthemum cristalinum Ice plant Galenia sarcophylla Beslyn, Vanwyksbrak Onchosiphon grandiflorum Grootstinkkruid Lycium tetrandum Kraaldoring These species could be considered for seeding of most bare areas to be revegetated and supported with: Stoeberia beetzii Pteronia onobromoides Atriplex cinerea Manochlamys albicans

(v) Transplant of selected species; mature shrubs and bulbs

During and the two days immediately following a rain episode conduct direct transplant of selected representative specimens.

Conduct watering of such transplanted specimens every 2nd day for the following week to reduce the risk of fatality.

Selected species shall focus on hardy pioneer species generally as per the list above. Select larger mature specimens.

The transplanted shrub which is placed between shade net wind protections fulfils the following supplementary functions:

a. The transplanted plant may survive, which, as a mature plant will serve as a seed generating core to further re-vegetation.

b. The transplanted plant even if it does not survive, will serve the following roles:

1. It will shed its own seed. 2. It will reduce wind speed in its immediate surroundings. 3. It will act as an aeolian sand trap as well as seed trap. 4. It will offer shade and possible increased condensation,

creating an improved germination microclimate for the trapped seed.

Given the uniformity of veld type throughout most of the mining area, such larger shrubs can be harvested in source areas even distant from the rehabilitation area if needed, but the closer the better as the transplant shock will be reduced given local microclimate and soil similarity. The above revegetation method represents the full revegetation intervention described as specification V-3-14 representing 100% intervention as the basis for reflecting on partial intervention contemplated below where the

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intensity of revegetation is not reduced but the application is only applied to the reduced percentage of the disturbance within Classes 1-5 percentages, with maximum retention of existing natural revegetation on the disturbance also in accordance with the classification.

(vi) Netting The reader must note that the management of windblown dust, as dealt with in the dust plume study dd 13 February 2014, is not repeated in this Stage 11 document of the Implementation Plan, but that as wind reduction netting in revegetation is relevant here the following netting prescription forms part of the Specification for treatment of areas disturbed in the implementation of other rehabilitation methods specified herein. Wind impact reduction by shade-net fencing and proper profiling (a) By shade-net fencing

To supplement the re-use of topsoil with its seed bank, re-topsoiled areas must be provided with shade netting fences as the contribution of such fencing to re-vegetation rate and success is well established on the west coast. Shade netting should be installed over a re-topsoiled area to the following general system design:

3m

15m

5m

5m

Area re-topsoiled and re-vegetating

Wind Direction

Shade net fences

a. Place first up-wind shade netting row 5m into the adjacent

upwind natural re-vegetation area, with the shade net row direction at right angles to the wind direction.

b. Ensure that the shade net rows extend at least 15m past the each end of the re-topsoiled areas.

c. Place the second and subsequent row of shade net fencing also at right angles to the wind direction and extending 15m beyond the ends of re-topsoiled area and at a row spacing of 5m and height of fence of 0.75 or 1.0m

d. All shade netting to be 0.75 or 1.0m high and of the self-sleeved type to pull over posts with posts placed at 2.5m spacing.

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As the 2014 specialist botanist’s review of the vegetation trial areas conducted by others where netting was applied to vast areas showed that multiple rows of netting preclude the ingress of windblown seed into the downwind portions of such netted areas, wind break netting as a supporting element of revegetation should not be applied wider than 4 Rows. Additionally, staggered gaps should be provided in the netting rows. The 2014 assessment also revealed that long term retention of netting has a negative impact on revegetation (again related to the limitation on windblown seed ingress and in fact on the limitation of windblown sand ingress, as the vegetation of the mining area and conditions for seed germination are reliant on a limited level of in-blown sand and seed. (evidenced by significant germination in un-netted areas as compared to immediately adjacent netted areas.) Accordingly, netting should not be retained for longer than two wet seasons ( as opposed to the minimum 3 years considered in the 2008 EMP) NOTE: the shade netting specification above is designed for areas, which are not subject to significant dust plume attack. Where such dust plume attack is evident, additional netting upwind of the rehabilitation area described above should be provided as sand-trap netting systems as discussed below.

V3.2 Dust Cut-off Netting: Construction of dust trap system, where possible adjacent to existing roads or trenches which already serve a partial barrier function and serve as access avoiding additional veld disturbance. The design entails the erection of shade cloth netting in 3 or 4 rows each 7m apart (allowing the dump truck to pass the excavator or loader). Netting rows to be parallel to the chosen existing barrier where possible, with the purpose of the trap system being that the sand which will accumulate between such netting rows will be removed periodically by excavator/dump-truck combination for deposition as backfill in a proximate excavation. As the excavator/dump-truck combination will run between the net rows, staggered gaps of 7m wide must be provided ± every 150m in each fence to provide exit for the dump trucks to the roadway serving the barrier. The nets are to be provided as 1.2-1.5m high netting using 1.8-2.1m long posts driven at least 0,5m into the ground. Once the sand has heaped to minimum 400mm and maximum 800mm high between the netting fences, the accumulated sand is to be removed by either front end loader to articulated dump trucks for transport to the nearest suitable excavation for dust backfill, where appropriate control measures are to be put in place in accordance with the applicable Method such as TR5 “total back-fill of trenches” or LEM specifications/ prescriptions from Part F of the EMP October 2012 revision to avoid such backfilled areas becoming secondary dust sources. The positions of such netting barriers, their lengths and the number of fences per barrier are to be specified in accordance with the nature and intensity of the plume to which they are applied as intervention method.

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Diagrammatic representation of dust cut-off trap to be installed as dust/sand removal mechanism

Detail of the levels of revegetation and shaping intervention required based on the 2014 natural revegetation and shaping ground truthed classes 1 – 5 to be applied to the respective methods. This paragraph deals with minimising the disturbance/maximising the retention of existing natural revegetation in the further rehabilitation intervention of mining earthworks disturbances, within the context of the relevant earthworks reshaping parameters The specialist botanist findings of both 2004/2008 and 2013/2014 regarding existing natural revegetation levels were that:

reaching significant natural revegetation levels as observed in the field visits takes many years; and

accordingly, wherever natural revegetation has occurred on a disturbed area, all attempts must be made to retain (not disturb) such vegetation and on this basis it is concluded as the point of departure in this chapter that:

“MAXIMUM RETENTION OF NATURAL REVEGETATION IS A FUNDAMENTAL PRINCIPLE IN THE REHABILITATION PROGRAMME”

V3.3 Vegetation status classification (i) Accordingly, the 2014 ground truthing of mining earthworks disturbances in

accordance with the 2008 EMP vision has now classified the level of natural revegetation which occurs in each of the historic disturbances as an input to the level of further rehabilitation intervention for that disturbance.

(ii) As a determinant of the intensity of rehabilitation of mining earthworks disturbances the 2014 ground truthing classification has classified each disturbance in terms of both:

Current status of shaping of the disturbance, assessing the percentage of inadequate shaping contributing to retarded natural revegetation with the recorded percentage then determining the percentage shaping intervention required for the disturbance.

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Indicated suitability of growing medium (loose aeolian sand by preference as opposed to a hard pan “dorbank” or observed phytotoxic dispersive soils (both unsuitable as growing medium).

Status of natural revegetation in/on the disturbance as a percentage of the observed undisturbed natural vegetation of the surrounding area.

(iii) The method of classification of each disturbance is based on a modification of the Braun-Blanquet Scale to record cover-abundance of vegetation as published in “Aims and Methods of Vegetation Ecology” by Dieter Mueller-Dombois and Heinz-Ellenberg; published by John Wiley.

(iv) As in the Braun-Blanquet Scale, a 1-5 classification is used on the principle of the scale, that in the Alexander Bay case, the following sample field classification, sample cases could further serve the classification of all disturbances by percentage comparative recordal per disturbance comparing observed image vegetation cover on the disturbance to that of natural adjacent veld.

Accordingly the following cover categories and percentage interventions were linked to the respective classes as per table 5.3.3.1 below.

Characteristics for vegetation status for the respective classifications 1- 5 Class 1: Very bare appearance (<20%) little to no vegetation established and not

requiring any retention of existing vegetation thus classifying for full remedial intervention to be applied.

Class 2: Vegetation established but either at very low levels or with large bare

patches mainly ascribed to the result of poor growing medium conditions (but not phytotoxic nor dispersive) or observed to be in aerial photography to be related to high wind conditions (erosional eddies) nor showing high dust impact smothering revegetation. These factors if present would be further evaluated in a site inspection during tender preparation in order that the description of works can be as accurately defined as possible at the time of the tender.

The remediation measure to be applied involves full top-soiling but with due regard to the retention of existing vegetation on suitable growing medium or the removal and immediate re-use of such vegetated patches with their growing medium. An assumed 60% effort.

Class 3: 60 – 80% classification where such revegetation occurs widespread

(uniformly) over the disturbance or when the non-vegetated area can be related to a specific cause which can be treated by local reshaping (for

Class Percentage Cover-Abundance Intervention Required

1 <20% Full Intervention

2 20 – 60% 60% revegetation

3 60 – 80% 30% Intervention

4 80 – 95% No Intervention

5 95 – 100% No Intervention

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example local hard-pan edge over a limited length of a v-shaped trench in which case the trench would classify both in terms of shaping requirement and in terms of vegetation requirement over the identified percentage of the un-revegetated trench length. An assumed 30% intervention. Revegetation remediation will entail:

hand raking,

hand seeding, and

appropriate wind-break netting if required. Class 4: High level of revegetation (but not quite comparable to the surrounding

natural veld) but requiring no assistance; only time to naturally progress to reach class 5.

Class 5: Vegetation cover largely indistinguishable from surrounding vegetation

requiring no intervention.

V3.4 Classification for level of shaping intervention (with due regard for prioritised natural revegetation preservation) As shaping is a definite determinant of natural revegetation success, a similar percentage classification of current shaping (again as a percentage of full specification shaping for the particular disturbance type has been captured in the 2014 GIS Ground Truthing Update file). Such shaping classification of each disturbance was done simultaneously with the natural revegetation status of the disturbance and accordingly the appropriate interfaces between shaping and vegetation status were established in the Ground Truthing classification.

(a) Reshaping classification for trenches

The above classification recorded in the 2014 GIS Ground Truthing Update in respect of the following V-shaped trench methods.

o Trenches (V-shaped) as TR1 – 14 and TR2 – 14 o Trenches (U-shaped) as TR3 – 14 classify for 100% shaping

(b) Reshaping classification for Overburden Dumps OB

Rounding status Reshaping Intervention Required

Yes None

Partial 50% re-shaping

No 100% re-shaping

Flat Top Follow specification method in OB Dumps

The above will apply to the following overburden dump methods

Overburden dumps

Percentage shaping of total shaping specification required

100%

60%

30%

0%

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OD1$ - 14

Shoulder rounding of dumps (OD2)

Complete (tortoise shell) rounding of overburden dumps OD3$ - 14

OD5 full scarification of rounded/topsoiled dumps read together with OD6 broad based scarification of partially revegetated dumps and OD7 revegetation/seeding of shaped over burden dumps all to be referenced as ODx-14.

(c) Excavations (mine floors)

Excavations are not classified in terms of revegetation rating as the standard methods adequately deal with the various excavation types and their respective methods of rehabilitation. The 2014 Ground Truthing of excavations adapted the measured perimeters and areas to the February 2014 Lidar imagery eliminating all duplications by mapping the overlaps between dumps and mine floors. In respect of Excavation edges (perimeters) the perimeters requiring shaping intervention were specifically recorded during groundtruthing and reflected in the Baseline Table for “Mined areas – Edges”, with the depth of excavation and length of the recorded edge determining the extent of reshaping intervention to 1:3.5 slope, while the revegetation intervention required is 100% in respect of such reshaped slopes. (Effectively a Class 1 revegetation Intervention in respect of all reshaped excavation edges.)

Given the high status afforded by the specialist botanist to natural revegetation occurrence, where there is a percentage conflict between:

Revegetation percentage intervention (class); and

Reshaping percentage, the status of level of natural revegetation intervention shall be afforded the primary consideration to avoid unwanted disturbance of natural revegetated areas for the sake of doing unnecessary shaping.

V-3$ Revegetation in post-mining land use nodes In respect of the distinction which the EMP draws between the elevated level of rehabilitation within Post Mining Land Use nodes and corridors and the lower rehabilitation level of making safe and non-polluting, the re-vegetation specifications for this distinction merely emphasise the repetition of supplementary seeding, together with an additional emphasis on topsoiling. If topsoil is becoming available at the same time as there is an identified post mining area requiring elevated level of rehabilitation in proximity which is ready to accept it, then such topsoil 150mm deep together with its vegetation , seed and bulb bank shall be directly transferred to the identified receipt area and supplementary seeding, with appropriate netting provided

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RS ROADS RS1. Tracks (<3m wide) Specification: Suggested NO action on tracks themselves as any activity will lead to further dust generation on veld. Actions to be taken with respect to tracks:

Identify superfluous tracks

Signpost them as closed

Barrier their entrance to draw attention to closure

RS2. Roads without layer works Specification: Assume road width average 3 – 5m wide.

a) Blade limited windrowed topsoil from immediate edge of road verge ridge only (first 0.5m strip) into roadway by single pass of a small grader along each side of road (or suitably bladed tractor) prior to scarifying road surface.

b) Scarify road surface with two passes of a 5-tanged Grader - Depth to scarify 100mm.

RS3. Layer constructed gravel roads (5 – 8m wide ave. 7m)

Specification: a) Cover roadway with designated material (topsoil) from a source between 1 –5km

from the task, by: loading at source hauling and tipping on roadway spreading by bladed tractor or small grader to depth of 50mm

b) Rip at ±0,6 – 0,8m spacing after topsoiling. (Such layered roads may require ripping by a heavy Grader or Dozer) as a tractor may be too light). Such ripping to be to depth of 200mm.

RS4. Compacted maneuvering areas (For instance at mobile plant parking areas, manoeuvring areas of terrestrial plant nodes outside of the areas to be covered In coarse tailings, and equipment storage areas, etc.). These areas generally consist of in-situ compacted soils with or without some concretised imported soils, but are not layer constructed hard-stand areas. Specification: Scarify with 5-7 tang Grader. Apply no further treatment, allowing the scarification undulations to accumulate windblown sand and seed. Only apply Topsoil and revegetation to Specification V3 in areas where such rehabilitation forms part of a post-mining land use node calling for elevated levels of rehabilitation.