Eagle Environmental SUMMARY AUDIT REPORT th · PDF fileAddress: (Physical) KDC East Gold Mine, Farm Rietfontein, District Westonaria, 1779 (Postal) KDC East Gold Mine, P.O. Box 190,

Eagle Environmental SUMMARY AUDIT REPORTGold Fields KDC East Gold Plants, South Africa 18th – 22th June 2012_______________________________________________________________________

KDC East Gold Plants Signature of Lead Auditor 12th December 2012

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INTERNATIONAL CYANIDEMANAGEMENT INSTITUTE

Cyanide Code Compliance AuditGold Mining Operations

Recertification Summary Audit Report

Gold FieldsKDC East (previously

Kloof Gold Minewith Gold Plants 1 and 2)

South Africa

18th – 22nd June 2012



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Name of Operation: Gold Fields KDC East Gold Mine (FormerlyKloof Gold Mine incorporating Gold Plants1 &2)

Name of Operation Owner: GFI Mining South Africa (Pty) Ltd (“GFIMSA”)

Name of Operation Operator: GFI Mining South Africa (Pty) Ltd

Name of Responsible Manager: Mr Dieter Bester, Metallurgical ManagerGold Plant No 1 – Jan du Toit (Acting PlantManager)Gold Plant No 2 –Sipho Matuwane (PlantManager)

Address: (Physical) KDC East Gold Mine, FarmRietfontein, District Westonaria, 1779

(Postal) KDC East Gold Mine, P.O. Box 190,Westonaria, 1780

State/Province Gauteng

Country: South Africa

Telephone: Metallurgical Manager – +27 11 278 9705Gold Plant 1– +27 11 411 8501/2Gold Plant 2– +27 11 278 1171/4

Fax: Metallurgical Manager – +27 86 627 2897Gold Plant 1– +27 11 411 8517 / 752 3213Gold Plant 2– +27 11 751 5211

E-Mail: Metallurgical Manager [email protected] Plant 1– [email protected] Plant 2–[email protected]

Location detail and description of operation:

Kloof Gold Mine, now known as KDC East Gold Mine, is located 70 kilometers west ofJohannesburg, near Westonaria in the Gauteng province of South Africa and has producedmore than 100 million ounces of gold during its 50-year life. The mine is accessed via the



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N12 highway between Johannesburg and Potchefstroom. Geologically it is located in theWest Wits Line Goldfield of the Witwatersrand Basin.

The mine is a large, well-established intermediate to ultra-deep level gold mine to 45 level(the lowest working level) some 3,347 metres below surface and consists of five shaftsystems and three gold plants. Two plants KP1 (KDC East No.1) and Python 1 processsurface (waste) rock dump material and KP2 (KDC East No.2) Plant processes mainlyunderground ore. KP1 and KP2 are the only two plants currently using cyanide for goldextraction.

Kloof-Driefontein Complex

Gold Fields’ objective of introducing a new business blueprint, together with an

appropriate organisational structure, was to support sustainable gold output at a targeted

NCE margin. As a first step in the review of the operations in the South Africa region, a

Business Process Re-engineering (BPR) programme has been implemented at

Driefontein and Kloof, where the senior management structures have been merged into

a single entity with the objective to improve operational and financial efficiencies and

ensure long-term sustainability. The details of the new Kloof-Driefontein Complex (KDC)

restructuring include:

Kloof and Driefontein shafts including metallurgical plants have been clustered into six

business units (BU) each with its own Senior Manager responsible for safe production as

well as ensuring an appropriate cost and manpower base for each operating unit. This

will reduce the layers of management and increase the span of control. The new

business units are:-

BU 1 – Driefontein 1 and 5 shafts

BU 2 – Driefontein 2 and 4 shafts KDC-West

BU 3 – Driefontein 6, 7, 8 and 10 shafts

BU 4 – Kloof 3 and 4 shafts

BU 5 – Kloof Main, 7, 8 and 10 shafts, KDC-East

BU 6 – Reef and waste (surface) plants.

One of the key benefits of the new structure is that accountability, responsibility and line

of sight is devolved to a lower level. The business units are supported by site operations

that provide common services across the units. In addition, a strategic management

office has been established and will identify and implement cost reductions and revenue

enhancing opportunities. The aim is to reduce the rate of cost increases and improve the

NCE margin.



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KDC East No 1 Gold Plant

Gold Fields KDC East No 1 Plant has 152 permanent employees and is subdivided in threemain sections: Screening, Milling and Cyanide leaching, Carbon in Pulp and ResidueDisposal.

The Plant operates a conventional two stage milling process using rods and pebbles mills inopen circuit with a double stage cyclonage (open circuit rod mill and a closed circuit pebblemilling and cyclones). The section is divided into two units made up of a primary rod mill andtwo secondary pebble mills. The secondary cyclone overflows from the milling section (68 -72% passing 75 microns) passes over a linear screen to remove woodchips, and otherforeign material and joins the thickener. The thickener underflow is then pumped to theLeaching section with a pulp density and flow rate monitored at the Control room.

Gold is dissolved over 32 hours by a conventional cyanide leaching section using airagitation in 10 conical bottomed tanks. The pH of the slurry is raised to pH 10.8 - 11 using alime product that emanates from the acetylene manufacturing process, at the thickener andLeach to ensure that when cyanide is added, toxic hydrogen cyanide gas is not generatedand the cyanide is kept in solution to dissolve the gold. Two stage cyanide addition isemployed in the head brown and middle brown leaching tanks. The leaching of gold inaerated cyanide solutions can be represented by ELSNER reaction:

4Au+8CN-+O2+2H2O4Au(CN)2-+4OH-

After leaching, the slurry, with most of the gold in solution, is sent to the Carbon-in-Pulpadsorption section, which consists of eight carousel pump cells in series with a carboninventory of about 32 tons, each cell having a carbon concentration of about 40g/l. The goldcontent in the loaded carbon depends on the pumping cycle and is transported to KDC EastNo.2 gold plant for elution and stripping purposes, nevertheless, the carbon loadingaverages 1500 g/t of gold and a level of calcium that should not be more than 1.2%. Theoverall gold recovery of the plant is closer to 92%.

KDC East No 2 Gold Plant

Gold Fields KDC East No 2 Plant has 136 permanent employees and consists of thefollowing unit operations: Primary Crushing, Milling, Thickening, Cyanide Leaching,Carbon in Pulp Adsorption, Carbon Treatment and Residue Disposal.

Underground Ore hoisted through No.7 Shaft barrel is transported through a crushersection to reduce the Plant feed to smaller than 150 mm. In addition ore from 1#, 3#, 4#and 8# are trucked to a stockpile outside the plant and fed into the plant by means of anoutside conveyor belt after crushing using a jaw crusher. All this material is stored on aplant stockpile facility before it is fed to the Milling section. This material is thentransported on surface conveyor belts to a surge facility before it is transported to theMills. The primary function of this facility is to smooth the feed to the Mills and ensureplanned Mill stops do not influence Shaft hoisting capacity.



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The ore is then transported to two SAG Mills for further reduction in particle size from150 mm to 80% passing 75m. This is done to ensure the metal is sufficiently liberatedfor cyanide dissolution and to increase surface area of the ore for effective dissolution.Steel balls are added to the Mills to assist in the grinding process at a rate determinedby throughput and size requirements as measured on a continuous basis.

Thickeners are utilized between the Mill circuit and the leach circuit to reduce the volumeof the mill product for effective reagent utilization and to act as a surge facility betweenthe circuits. The thickeners also play an important role in effective water reticulation inthe processing facility.

The Leach circuit consists of 10 leach tanks, in series, depending on the volumetric flowrate of pulp, and provides a fixed residence, or contact time, between the pulp streamand reagents, for effective gold dissolution. Cyanide and Lime are added to the pulpstream in the leach circuit that dissolve the gold and transfer 97.5 % of the “solid” goldinto the aqueous state. The tail of the leach stream reports to the Carbon in Pulp sectionfor the final extraction and gold concentration step. The carbon in pulp section consistsof eight tanks in series equipped with screens to retain the carbon in the tank. Pulpgravitates through the circuit whilst carbon is pumped in a counter current fashion. Thegranular activated carbon absorbs the gold and concentrates the gold on carbon.

The loaded carbon is removed from the tanks and separated from the pulp usingscreens with spray water to wash the carbon. The washed loaded carbon is thentransferred to the Elution columns for further processing. In the Elution column the goldis removed from the carbon via a hot caustic soda wash to yield the carbon ready for re-use and to transfer all the gold into an electrolyte to be used for the electro-winningprocess. During electro-winning an electric current is passed through the solution thatforces the gold and other base metals present in the solution to plate onto stainless steelmesh. The mesh is cleaned with high-pressure water to recover the gold sludgeconcentrate to be smelted. The concentrate is dried and then smelted in electricinduction furnaces to produce gold bullion at a purity of around 93% fine gold per bullionbar. The barren pulp stream from the carbon in-pulp section is pumped to the tailingsstorage facility.

Eagle EnvironmentalGold Fields KDC East Gold Plants, South Africa

SUMMARY AUDIT REPORT18fl'- 22th June2012

Auditor's Finding

This operation is

X in full compliance

I in substantial compliance

n not in compliance

with the International Cyanide Management Code.

This operation has not experienced compliance problems during the previous three yearaudit cycle.

Audit Company: Eagle Environmental

Audit Team Leader: Arend Hoogervorst

E-mail: [email protected]

Names and Signatures of Other Auditors:

Name : Dawid M. L Viljoen Signature

Dates of Audit: 18th - 22th lrne2012

KDC East Gold Plants

Facility

I attest that I meet the criteria for knowledge, experience and conflict of interest for Code VerificationAudit Team Leader, established by the International Cyanide Management Institute and that all members ofthe audit team meet the applicable criteria established by the International Cyanide Management Institutefor Code Verification Auditors.

I attest that this Summary Audit Report accurately describes the findings of the verification audit. I further

attest that the verification audit was conducted in a professional manner in accordance with the

International Cyanide Management Code Verification Protocol for Gold Mine Operations and usingstandard and accepted practices for health, safety and environmental audits.

ts[ t.l \rot2- r

t t| ( l r z - lz ,o t t

Date

Sisnature of Lead AuditorKDC East Gold PlantsPage 6 of25

12ft Decemb er 2012



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Auditor’s Findings

1. PRODUCTION: Encourage responsible cyanide manufacturing by purchasing frommanufacturers who operate in a safe and environmentallyprotective manner.

Standard of Practice1.1: Purchase cyanide from manufacturers employing appropriatepractices and procedures to limit exposure of their workforceto cyanide, and to prevent releases of cyanide to theenvironment.

X in full compliance with

The operation is � in substantial compliance with Standard of Practice 1.1

� not in compliance with

Basis for this Finding/Deficiencies Identified:There is a Gold Fields cyanide supply contract, covering Gold Fields Gold Plants,includingthe two KDC East Plants, in place with Sasol Polymers, as the sole supplier ofliquid Sodium Cyanide, delivered by bulk tanker. The contract requires that the produceror supplier of cyanide must be a signatory to the ICMI Code and the producer or suppliermust be ICMI certified. Sasol Polymers is a signatory to the Cyanide Code and was re-certified as a fully compliant Production Facility with the ICMI Cyanide Code on 2March 2010.

2. TRANSPORTATION: Protect communities and the environment during cyanidetransport.

Standard of Practice 2.1: Establish clear lines of responsibility for safety, security,release prevention, training and emergency response inwritten agreements with producers, distributors andtransporters.




Basis for this Finding/Deficiencies Identified:There is a signed Memorandum for transportation and offloading of sodium cyanidesolution, for Sasol Polymers at Gold Fields sites, in place. The supply contract between



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Gold Fields Shared Services on behalf of all Gold Fields South African Mines and SasolPolymers specifically covers the responsibilities and requirements for transport, safety,security, unloading, emergency response (spills prevention and clean-up), route planningand risk assessments, community liaison, emergency response resource access andavailability, training, and communication.

Standard of Practice 2.2: Require that cyanide transporters implement appropriateemergency response plans and capabilities and employadequate measures for cyanide management.




Basis for this Finding/Deficiencies Identified:The Gold Fields supply contract requires that the producer/supplier of cyanide must be asignatory to the ICMI Code and the producer supplier and transporter must be ICMIcertified. SASOL Infrachem SiLog was re-certified on 13 January 2010 as a fully ICMICode compliant transporter, thus meeting all the requirements for appropriate emergencyresponse planning and cyanide management. Sasol Polymers changed its transporter fromSiLog to Tanker Services and deliveries of cyanide by Tanker Services commenced fromJuly 2011. Tanker Services is an ICMI Signatory and was audited by an accredited ICMILead Auditor and Transport Auditor and became a certified ICMI transporter on 13December 2011.Thus there was a break in deliveries of cyanide to site by an ICMIcertified cyanide transporter between July and December 2011 until Tanker Serviceswere certified as transporters. The auditors deem the break to be acceptable for CyanideCode mine compliance purposes for the following reasons:-1) The change of transporters was beyond the control of the mine,2) There was only one ICMI certified transporter and one ICMI certified liquid cyanidesupplier in South Africa and the mines were bound to the producer/transporter conditions,3) Finding a replacement/alternate supplier/transporter in the short term was not feasiblebecause the mine can only handle liquid cyanide on site and does not have the facilities tomix their own cyanide from briquettes,4) The mine applied pressure upon the supplier to organise ICMI certification for thereplacement transporter as soon as possible, and5) The interim cyanide risk was minimal because the new transporter took over all of thetransporter resources of ICMI transport certified SiLog (dedicated bulk cyanide liquidtankers, trained and experienced owner-drivers and contract drivers, assessed route riskassessments, cyanide documentation and systems) and was, and still is, covered in termsof Sasol's Product Stewardship and Responsible Care policies by the Sasol cyanideemergency response system (24 hour emergency control room, network of cyanidetrained, emergency response spill and medical response service providers), dedicatedcyanide tanker storage area and cyanide tanker decontamination facilities.



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3. HANDLING AND STORAGE: Protect workers and the environment during cyanidehandling and storage.

Standard of Practice 3.1: Design and construct unloading, storage and mixing facilitiesconsistent with sound, accepted engineering practices, qualitycontrol/quality assurance procedures, spill prevention andspill containment measures.




Basis for this Finding/Deficiencies Identified:Both KDC East 1 and 2 plants only use liquid cyanide, delivered by bulk tanker, and nomixing or storage of solid cyanide takes place on site. The design and constructiondocumentation of KDC East 1 and 2 was reviewed and audited during the originalcertification audit and found acceptable. Both sets of offloading and storage facilitieswere designed and built, in accordance with sound and accepted engineering practices,with materials appropriate for use with cyanide and are located in concrete bunds awayfrom people and surface waters. Subsequent inspections by the Producer’s technical staffin 2010 and 2012 have found both sets of facilities of a high standard, warranting specialawards. The bulk cyanide storage tanks are also located away from incompatiblematerials. Drainage flows from the offloading areas into the main bund areas.Both sets of reagent cyanide storage tanks have ultrasonic level detectors, linked to theirrespective control room SCADAs and visual displays at the storage areas. The procedurescovering cyanide unloading and transfer were reviewed and found to be effective.Cyanide areas are within the access controlled plant security areas which is securelyfenced.

Standard of Practice 3.2: Operate unloading, storage and mixing facilities usinginspections, preventive maintenance and contingency plans toprevent or contain releases and control and respond to workerexposures.






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Basis for this Finding/Deficiencies Identified:At KDC East 1 and 2, only liquid cyanide is used and is delivered via bulk tanker tostorage tanks and no mixing or storage of solid cyanide takes place on site. The cyanideoffloading and transfer procedures are detailed, spelling out PPE requirements, use of abuddy in the process, and clearly sequenced to prevent spillages and accidental releasesduring off-loading.

4. OPERATIONS: Manage cyanide process solutions and waste streams to protecthuman health and the environment.

Standard of Practice 4.1: Implement management and operating systems designed toprotect human health and the environment utilizingcontingency planning and inspection and preventivemaintenance procedures.




Basis for this Finding/Deficiencies Identified:KDC East 1 and 2 are “sister” plants which use very similar sets of operationalprocedures which vary only slightly according to site specific requirements. KDC East 1has 64 operational cyanide procedures, 4 cyanide engineering procedures and 7 cyanideenvironmental procedures. KDC East 2 has 70 operational cyanide procedures, 4 cyanideengineering procedures and 7 cyanide environmental procedures. Both plants make use ofthe electronic “Intelli-permit”™ system for the generation of clearance certificates andpermits to work. The TSFs linked to the two plants are operated by the same operationalcontractor but have their own sets of operating procedures, tailings dam operationalmanuals and a common Code of Practice. Routine daily, weekly, monthly and quarterlyinspections (operational and planned maintenance and breakdown), legal inspections, andchecklists for proactive and reactive management were sampled to check theeffectiveness of systems. These inspections cover tanks, pipes, pumps, valves, secondarycontainments, ponds and impoundments located in the plant and the TSFs. There is aGOLDSIM probabilistic water balance in place, and no scenario has been identifiedwhere the need has been highlighted to shut down the plant to prevent overtopping.An electronic PRAGMA PM (Planned Maintenance) system has been in place and usedat both Plants since 2008. Operational inspections on both plants include: Shiftlyinspections, daily shift supervisors inspections, Safety officer 45 day workplaceinspections, and planned general inspection. Job cards are issued through the PM systemon faults recorded during inspections. Tank thickness testing is done on a planned basisfor all high and low strength cyanide tanks. A change management procedure covering



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health, safety and environment is in place and operational and examples of major andminor change management exercises indicated that the process is used effectively.

Standard of Practice 4.2: Introduce management and operating systems to minimizecyanide use, thereby limiting concentrations of cyanide in milltailings.




� not subject to

Basis for this Finding/Deficiencies Identified:Both plants are governed by a Managerial Directive entitled “Optimisation Plan –Sodium Cyanide”. The scope of the Directive covers the characterisation of the surfacerock dump and underground reef ore mineralogy in terms of cyanide consumptionoptimisation, recovery, pH and free and WAD cyanide in leach, adsorption, residuedisposal, TSF and return water. The document includes an optimisation action plan, aswell as a control strategy plan. Two stage cyanide addition was tested with on line WADmeasurement in the tails and both strategies implemented on both plants. Both plants alsocommissioned a TAC 1000 system as a primary cyanide addition control and used WAD1000 analysers on the tails.

Standard of Practice 4.3: Implement a comprehensive water management program toprotect against unintentional releases.




Basis for this Finding/Deficiencies Identified:There is a comprehensive, site wide, GoldSim, computerised, probabilistic water balancemodel in place on both plants, covering the plants and the TSFs. The models include thecatchment areas, catchment and emergency/solution dam volumes and pump capacities.The models also make provision for inter plant return water dam pumping. The 1: 50 yearspill frequency, as per the South African Water Act requirements, is used as analternative to the design storm duration. The model calculates the probability ofovertopping of the return dams. It is TSF operating practice not to store any water on theTSF, thus all precipitation is recovered to the return water dams, making provision for



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infiltration into the beach areas. Rainfall data is collected daily and 40 years of actualdata was used in the model.

Standard of Practice 4.4: Implement measures to protect birds, other wildlife andlivestock from adverse effects of cyanide process solutions.




Basis for this Finding/Deficiencies Identified:Management systems specify that the KDC East 1 plant will be operated at less than 35ppm, KDC East 2 plant at less than 45 ppm and the SCADAs are programmed to respondwith pop ups to WAD cyanide trigger points as per the management procedure. Theanalyser is calibrated using MINTEK Standards on a weekly basis and results arerecorded in REMIS (environmental database). On line WAD CN records from the finalresidue tank (compliance point) for 2009 to date show that for KDC East 1, the twoisolated exceedances were traced to pipe leaks on the plant with an average 21 ppmWAD CN and the two exceedances were 62 and 52 ppm WAD CN. For KDC East 2, theaverage WAD CN value was 22.10 ppm, the highest value being 74.38ppm with 9exceedances between 50 and 74.38 ppm for the period under review. Investigationsshowed the cause to be the combined impact of acid treatment of carbon from KP1 andKP2 plants. Return water dam samples for KDC East 1 showed no exceedances of 50ppmWAD cyanide with levels averaging 2.24ppm and for KDC East 2, also no exceedancesof the 50ppm WAD cyanide limit and levels averaging 3ppm WAD cyanide.No wildlife mortalities have been recorded on either plants to date. Baseline wildlifestudies on both TSFs have been completed and additional studies are planned. Monthlyinspections are done as per wildlife procedure for monitoring wildlife at and aroundcyanide facilities.

Standard of Practice 4.5: Implement measures to protect fish and wildlife from direct andindirect discharges of cyanide process solutions to surfacewater.




Basis for this Finding/Deficiencies Identified:For KDC East 1, no direct discharges from the plant or TSF exist. Discharges to surfacewater from sewerage water and mine water, not containing any cyanide, exist, to the



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Leeuw Spruit. Potential risks include the TSF return water ponds which could overtop toLeeuw Spruit, or in case of the Residue line, failure next to the Main maturation plantdams, which discharge into the Loopspruit. Potential contamination could come from theplant to the Leeuw Spruit via the Rheeders dam. Residue column failure including theTSF ring feed in certain areas could potentially contaminate the Leeuw Spruit. In case ofreturn water pipe or TSF ring main failure, contamination of the Davonia river ispossible. For KDC East 2, no direct discharges from the plant or TSF exist. Potentialdischarges include: Overflow from the plant settling ponds which will report to thecatchment dam; and overflow from the catchment dam which will report to the TSFreturn water dams via the TSF solution trenches. The return water dams overflow willcontaminate the Loopspruit but water management procedures are in place to managewater usage and storage, preventing overtopping of return water dams.For KDC East 1, no official mixing zone has been identified. Samples up anddownstream in the Leeuw Spruit are taken and analysed for WAD. The CN WAD andCN free levels in the KDC East surface water downstream from June 2009 to Nov 2010show all values are below 0.022mg/l. Upstream data values vary from 0 to 0.02 mg/lWAD CN. In 2012, values range between 0.003 and 0.007mg/l WAD cyanide with oneoutlier of 0.036. Similarly, for KDC East 2, no official mixing zone has been identified.Samples downstream in the Loopspruit are taken and analysed for WAD. CN WADcyanide from June 2009 to 17 Nov 2010, showed all values below 0.022. Values for 2011vary between 0.001 and 0.006 mg/l WAD cyanide. In 2012 values ranged between 0.001and 0.005mg/l WAD cyanide. Neither plants have identified any indirect discharges.

Standard of Practice 4.6: Implement measures designed to manage seepage from cyanidefacilities to protect the beneficial uses of ground water.




Basis for this Finding/Deficiencies IdentifiedFor KDC East 1, the dams are equipped with under drains and catchment paddocks whichwill contain any run off from the sides of the dams, as well as reducing seepage. Frenchdrains are installed to collect seepage and Eucalyptus trees are planted to reduce seepage.The TSF's are unlined. A full borehole monitoring program is in place, and WADcyanide is included in the analytical scope. The No 1 return water dam is lined. For KDCEast 2, dams are equipped with under drains, and catchment paddocks contain any run offfrom the sides of dam, as well as reducing seepage. The TSF's are unlined. A fullborehole monitoring program is in place, and WAD cyanide is included in the analyticalscope.The applicable jurisdiction does not identify any beneficial uses or down gradientcompliance points. Deemed uses include the use of borehole water for drinking water forboth human and animal uses. No reference in the water permit is made to WAD, and



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consultants proposed the use of the drinking water standard: < 0.03 free cyanide as ppmCN and recoverable CN total <1.070 ppm. Borehole samples are taken and analysed forWAD CN. For KDC East 1, quarterly samples taken from May 2009 to Nov 2010 rangefrom 0 to 0.003 mg/l WAD CN, and the Doornpoort boreholes (downstream of KDCEast) for 2011 ranged from 0.001 to 0.008 mg/l WAD cyanide. For KDC East 2,quarterly samples from May 2009 to Nov 2010 range in value from 0 to 0.005 mg/l WADCN. Values for 2011 ranged from 0.001 to 0.008 mg/l WAD cyanide. There are also nojurisdictional numerical standards contained in any relevant legislation. There are nobackfill operations conducted or linked to either plants.

Practice 4.7: Provide spill prevention or containment measures for process tanks andpipelines.




Basis for this Finding/Deficiencies Identified:For KDC East 1, all cyanide tanks are installed inside bund areas and the tanks are of aconical type installed on plinths. All other tanks are placed inside secondarycontainments. For KDC East 2, all unloading, storage and process solution tanks areplaced on concrete bunded areas. Both plants are designed with bunds and sump pumpsreturning all spillages back to the process. For KDC East 1, the cement and brick damsare pumped back to process, or mechanically cleaned. Reagent strength cyanide sumppump delivers to the leach, the sump is equipped with a level detector, but need to bestarted manually. For KDC East 2, A settling pond / catchment dam system is used forstorm water containment and emergency spillages. The reagent strength cyanide sumppump delivers into the leach only, and the sump is equipped with a level detector, whichneeds to be started manually. For KDC East 1 plant, all reagent solution pipelines areinstalled inside a closed launder draining back to the cyanide storage bund, all reagentsolution pipelines for KDC East 2 run across concrete bund areas and the leach andoperational inspections are conducted shiftly. Cyanide strength pipes are on thePRAGMA maintenance system which includes inspections and thickness testing. TheKDC East 1 TSF pipeline passes close to human activities and the a Security contractorconducts after hours inspections to supplement morning shift pipe patrols with 12monthly pipe thickness testing carried out. Secondary containment to contain pipe leakswas observed. Special protection measures include all pipeline replacements must be asper original specification or better, the installation of secondary containment aroundslimes dam piping using berms drains or paddocks and waste rock containment aroundresidue pipelines. The KDC East 2 TSF line from the plant to the TSF is placed insidecontainment berms. Ring main pipelines are also placed inside the slimes dam solutiontrenches catchment area. Sweep T pieces are used to minimise risk of pipe failure. Allpipes, valves and pumps are on the PRAGMA system and pipe inspections are conducteddaily and after hours. Pipe thickness tests are conducted 12 monthly. Special measures



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include: Storm water trench being bunded off, preventing contamination in case of a TSFline failure, a water monitoring program which includes sampling of 7# maturation plantpond and the Loopspruit, and the fitting of a reinforced sweep T-piece at the slimes dampipe. Expansion joints and pump maintenance is on the PRAGMA system and TSFpipelines thickness testing done 12 monthly. The residue operational procedure includesthe stopping of pumps when the residue pipes fail, and daily and after hours inspectionsare conducted. High pressure Core Flex pinch valves are used (16 Bar SWP) on valvestations where risk to surface water exist.Cyanide tanks and pipelines are manufactured from materials compatible with cyanideand high pH conditions.

Standard of Practice 4.8: Implement quality control/quality assurance procedures toconfirm that cyanide facilities are constructed according to accepted engineeringstandards and specifications.




Basis for this Finding/Deficiencies Identified:No new cyanide facilities or modifications to existing facilities have been carried outsince certification. On KDC East 1, a plant structural audit covering concrete structures,bund areas and plinths, steel structures and tanks concluded that the equipment is in goodcondition. The annual reports for the TSF concluded that the TSF was satisfactorilymanaged. A similar structural audit was conducted on KDC East 2 and the annual auditconcluded that the TSF was managed satisfactorily.

Standard of Practice 4.9: Implement monitoring programs to evaluate the effects ofcyanide use on wildlife, surface and ground water quality.




Basis for this Finding/Deficiencies Identified:Procedures for environmental monitoring (including sample preservation and chain ofcustody procedures) of surface water and borehole water, developed by competentpersons, were sighted and checked. Boreholes are placed and sampled upstream anddownstream of the plant. Wildlife inspections are conducted daily. Surface water issampled monthly, and boreholes are sampled quarterly.



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5. DECOMMISSIONING: Protect communities and the environment from cyanidethrough development and implementation ofdecommissioning plans for cyanide facilities

Standard of Practice 5.1: Plan and implement procedures for effective decommissioningof cyanide facilities to protect human health, wildlife andlivestock.




Basis for this Finding/Deficiencies Identified:A procedure for decommissioning cyanide facilities with implementation schedules is inplace for both KDC East 1 and KDC East 2. The procedures are reviewed annually.

Standard of Practice 5.2: Establish an assurance mechanism capable of fully fundingcyanide related decommissioning activities.




Basis for this Finding/Deficiencies Identified:The current Environmental Trust Fund Contribution by KDC East Gold Mine wasacknowledged by the Department of Mineral Resources on the 9 Feb 2012. Evidence ofpast contributions was also sighted. These figures are reviewed annually. The Trust Fundis required by law.

6. WORKER SAFETY: Protect workers’ health and safety from exposure to cyanide.

Standard of Practice 6.1: Identify potential cyanide exposure scenarios and takemeasures as necessary to eliminate, reduce or control them.






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Basis for this Finding/Deficiencies Identified:KDC East 1 and 2 are “sister” plants which use very similar sets of operationalprocedures which vary only slightly according to site specific requirements. KDC East 1has 64 operational cyanide procedures, 4 cyanide engineering procedures and 7 cyanideenvironmental procedures. KDC East 2 has 70 operational cyanide procedures, 4 cyanideengineering procedures and 7 cyanide environmental procedures. All procedures includePPE requirements and specify appropriate pre-work inspections. A change managementprocedure covering health, safety and environment is in place and operational andexamples of major and minor change management exercises indicated that the process isused effectively. Both plants make use of the electronic “Intelli-permit”™ system for thegeneration of clearance certificates and permits to work. The TSFs linked to the twoplants are operated by the same operational contractor but have their own sets ofoperating procedures, tailings dam operational manuals and a common Code of Practice.Routine daily, weekly, monthly and quarterly inspections (operational and plannedmaintenance and breakdown), legal inspections, and checklists for proactive and reactivemanagement were sampled to check the effectiveness of systems. These inspectionscover tanks, pipes, pumps, valves, secondary containments, ponds and impoundmentslocated in the plant and the TSFs. There is a GOLDSIM probabilistic water balance inplace, and no scenario has been identified where the need has been highlighted to shutdown the plant to prevent overtoppingWorker input is considered in Health and Safety meetings, Workplace Safety Repsmeetings, daily toolbox talks, HAZOPs and risk assessments, TSF Health & Safetymeetings, and TSF Safety Reps meetings.

Standard of Practice 6.2: Operate and monitor cyanide facilities to protect worker healthand safety and periodically evaluate the effectiveness of healthand safety measures.




Basis for this Finding/Deficiencies Identified:At KDC East 1, pH control from the TAC 1000 regulates lime addition to thickeners andpH is measured in leach tank 1 and 5 ( TAC 1000) and the final residue (WAD 1000). Aninterlock of the pH with cyanide dosing pumps exists at pH 10, with the pH alarming at10.2 (Low), and at 10 (LowLow) on the SCADA where the cyanide shut off will beactivated, and the audio visual alarm at 10.2, which will reset at 10.5 only. Pop up alarmsat SCADA for lime ring feed pump trips and when the lime tank level is low. At KDCEast 2, pH is measured at the thickener with lime addition at the thickener at a set pointof 10.5, the Low alarm is at 10.4, LowLow alarm at 10.3 the High alarm at 10.7 whichalso alarms at the SCADA. The Leach pH is measured at tank 1, and the separate lime



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feed to leach tank 1 is controlled at 11.2, with a Low alarm at 11.1,a LowLow alarm at11.0, a High alarm at 11.3, where lime dosing will stop. Interlocks with cyanide pumpsare in place stopping the pumps at 10. There is pH Indication at tanks 2 and 5 (TAC1000)and at the residue (WAD 1000). SMS message systems to cell phones alarm at 10.5 at theleach. KDC East 1 utilises fixed HCN gas monitors at the cyanide cage and at the top ofthe leach at no 1 and 5 Browns, and at the CIP. There are 5 portable HCN gas monitors inuse. KDC East 2 is equipped with four fixed gas monitors: 2 at the top of the leach and 1at offloading and 1 at residue. 3 portable MSA units are in use with 8 in for service. Allmonitors are calibrated appropriately. Hotspot surveys carried out on the plants weresampled and reviewed.On-going inspections and checks are also used to monitor and check facilities andemergency response equipment functioning and checklists covering three years sincecertification were sampled. Safety equipment such as safety showers, low pressure eyewash stations, and fire extinguishers are numerous and adequately signposted. MSDS andfirst aid information is available in English.Slurry pipelines are labelled. Reagent strength cyanide tank pipes are colour coded andlabels also indicate directional flows. The Plants use a colour coding standard andemployees are trained in the standard. This was verified during workforce interviews.Eating and drinking is only allowed in dedicated areas. Formal employee interviews wereused to check awareness and sensitivity to health and safety measures and the responsefrom employees and contractors alike, was found to be appropriate and acceptable.Accident and incident reporting and investigation procedures, based upon the site safetyreporting requirements, were found to be in place and effective.

Standard of Practice 6.3: Develop and implement emergency response plans andprocedures to respond to worker exposure to cyanide.




Basis for this Finding/Deficiencies Identified:It was confirmed that two-way radios and telephones were used to communicateemergencies. Oxygen, SCBA (self-contained breathing apparatus) sets, water, life buoysat the leach and thickener, TriPac antidote kits, alarms on showers reporting on SCADA,are in place. Emergency equipment is placed in the plant emergency room, offloadingcontrol office, leach first aid room, and control room, and reagent strength cyanidestorage area. Inspection lists for the antidotes, oxygen BA sets, safety showers, oxygencylinders, and first aid boxes were checked, confirmed for both plants, and sampled forthe three years since certification. All Antidote kits are stored in fridges as specified bythe manufacturer and re-ordered using a schedule on a PRAGMA PMS pop-up reminder.The plants’ cyanide emergency rooms are fully equipped to handle cyanide emergencies.All plant personnel are trained in cyanide emergencies. An emergency response team



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fully trained in BA and confined rescue training is available and 2 advanced life supportparamedics with 8 intermediate life support training paramedics are also available. (2available 24/7 on station) The main EMS (medical) station is at Libanon and 3 satellitecyanide response station bases at Libanon, KDC West and South Deep are within a 20minutes response time. Primary response is from the plant ERT, with the cyanideresponse team providing advanced support. Exposed workers are transported from thesite by the Gold Fields ambulance services and cyanide emergency response team toLeslie Williams Hospital, 35 km away. The Leslie Williams Hospital is the captive minehospital providing medical assistance for cyanide emergencies to the two KDC Eastplants and other Gold Fields plants in the area. Hospital staff are specifically trained tohandle cyanide emergencies. There is a medical procedure (including flowchart) in placefor transportation of patients. Cyanide equipment is regularly checked and tested andmock drills are held regularly on site. Man down drills are used to assure that the medicalfacility is competent and equipped to handle emergencies.

7. EMERGENCY RESPONSE Protect communities and the environment through thedevelopment of emergency response strategies andcapabilities.

Standard of Practice 7.1: Prepare detailed emergency response plans for potentialcyanide releases.




Basis for this Finding/Deficiencies Identified:Both Plants have detailed cyanide emergency response plans and the TSFs are covered byappropriate emergency plans. The emergency response plans are linked to specificemergency situations and the appropriate procedures and responses within the site'ssystems. The scenarios responses were guided by risk assessments which identified majorrisks.

Standard of Practice 7.2: Involve site personnel and stakeholders in the planningprocess.






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Basis for this Finding/Deficiencies Identified:For both Plants, stakeholders and emergency response stakeholders were identified, aswell as those who would be affected. Plant Foremen and Area Supervisors were includedin the risk assessments, and emergency response was noted for discussion in the weeklyplant safety meetings. The workforce is also involved in the development of the ERP bypartaking in mock drills and training drills. The Gold Fields captive hospital is equippedto treat 10 decontaminated cyanide patients and all trauma staff and Emergency Servicesstaff received cyanide awareness training. The hospital and Emergency services staff areinvolved in mock drills. Due to the lack of skills, capacity and the availability of localresponse agencies and the availability of well equipped mine response teams andhospitals, no local agencies are involved in the ERP. However they are kept informed.

Standard of Practice 7.3: Designate appropriate personnel and commit necessaryequipment and resources for emergency response.




Basis for this Finding/Deficiencies Identified:The Emergency Response Plan details clear duties, roles and responsibilities for thevarious emergency scenarios. The Metallurgical Manager has the authority to commit thenecessary resources and his alternate is the Plant Manager. The Plant EmergencyResponse Team is listed and a team is available on each shift with an additional day shiftteam. The EMS (medical) team details are posted in the plants.The emergency equipmentinventory was checked and site inspections confirmed availability and readiness. ThePlan includes contact references (telephone, cell phone, etc) of internal and externalresources for the various scenarios, particularly with detail where external resources andskills might be needed. Periodic drills involving internal and external stakeholders ensurethat roles and responsibilities are understood and clearly implemented.

Standard of Practice 7.4: Develop procedures for internal and external emergencynotification and reporting.






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Basis for this Finding/Deficiencies Identified:The Emergency Response Plan includes details for appropriate emergency notificationand reporting (internal and external) and the call-out procedure and contact informationlists which are updated regularly. Internal and external communication (including theMedia) is dealt with in the Plan.

Standard of Practice 7.5: Incorporate into response plans and remediation measuresmonitoring elements that account for the additional hazards ofusing cyanide treatment chemicals.




Basis for this Finding/Deficiencies Identified:The Emergency Response Plan covers this in the Environmental Procedures, referring tothe Environmental Incident Response Procedure, which includes detailed and specialisedprocedures which cover clean-up and remediation, as appropriate to the site-specificidentified scenarios. Use of neutralization processes and materials is clearly covered, as isdisposal of contaminated materials and the use of treatment chemicals, such as ferroussulphate in surface water, which is prohibited. Availability of alternate drinking watersupplies are also included.

Standard of Practice 7.6: Periodically evaluate response procedures and capabilities andrevise them as needed.




Basis for this Finding/Deficiencies Identified:The Plan includes the requirement for review and revision on an annual basis or after anactual cyanide emergency or a mock drill which identified deficiencies in the plan. Drillsincorporate identification of problems, action and follow up on completion. Feedbacksessions are also held.

8. TRAINING: Train workers and emergency response personnel to manage cyanidein a safe and environmentally protective manner.



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Standard of Practice 8.1: Train workers to understand the hazards associated withcyanide use.




Basis for this Finding/Deficiencies Identified:All plant, EMS, Asset protection and contractor staff are trained in module A cyanideawareness and cyanide first aid with a 100% pass mark being required. Annual refreshertraining is conducted. Training of all new employees and refresher training is scheduledusing the manual "Tracker" System which is linked to the access control clocking systemat the plants. Training records are kept for two years and archived for the life of the plant.

Standard of Practice 8.2: Train appropriate personnel to operate the facility accordingto systems and procedures that protect human health, thecommunity and the environment.




Basis for this Finding/Deficiencies Identified:All Plant on the job training is based on the plants procedures and risk assessments.Procedures include reference to PPE, pre-work inspections, job hazards and abnormalworking situations and conditions. Key risk areas were trained first. Theoretical trainingtakes place on site. A training matrix and occupational task inventory is used to specifytraining needs per job position. Training of all employees and refresher training isscheduled using the "Tracker" System which is linked to the access control clockingsystem at the plants. Refresher training of all tasks is conducted with the frequency basedon risk of the task. Planned Task Observations (PTOs) are conducted according to acritical task list. The Training Officer is a qualified training assessor and most supervisorswere also trained as Workplace Assessors. Training records are kept for two years andarchived for the life of the plant.

Standard of Practice 8.3: Train appropriate workers and personnel to respond to workerexposures and environmental releases of cyanide.




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Basis for this Finding/Deficiencies Identified:All plant workers receive training in cyanide awareness and cyanide first aid. Thecyanide emergency response team (ERT) reacts to spills and receives mock cyanide spilldemonstration training. The ERT is trained in the emergency response plan throughspecial training mock drills including spill drills, as well as man down cyanide exposuredrills. Medical responders and the Emergency Response team are made aware of the ERPusing mock drills. TSF contractor and the teams from plant are involved with the Riskassessments for the ERP. Mock drills are evaluated by the training department andlearning points noted and debriefed. The Procedure for refresher training is contained inthe KDC cyanide emergency response plan. Training records are kept for two years andarchived for the life of the plant.

9. DIALOGUE: Engage in public consultation and disclosure.

Standard of Practice 9.1: Provide stakeholders the opportunity to communicate issues ofconcern.




Basis for this Finding/Deficiencies Identified:Dialogue meetings are two-way dialogue sessions involving both dissemination ofinformation and the answering of questions on cyanide. Stakeholders were identifiedusing a stakeholder map database which included:- Department of Water Affairs andGauteng Department of Agriculture and Rural Development, local schools, towncouncils, Trade Unions, farmers, informal settlements, neighbouring mines, fire brigades,SA Police Service, and the Traffic Department. The data base of key people around themine was also updated. The returned stakeholder engagement forms gave notes on issuesstarting October 2011. The survey included the issuing of a leaflet entitled "Cyanideinformation bulletin" as well as the emergency response information and site contactdetails. Meetings were also held with cattle owners around the mine. Cyanide wasincluded in the community meeting agenda, at least annually. Presentations to thesurrounding water forums were given using the cyanide awareness video. A stand wasincluded at an Exhibition being held at the Randfontein Show in 2012. A Dialoguesession was held with 1st year medical students after they stumbled on a mock drill at thehospital. A Meeting with the Western Area Fire Protection Association discussedemergency evacuation with neighbouring communities and confirmed they cannot assist



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with cyanide treatment. A schedule of cyanide public awareness sessions for 2012 formajor stake holders was sighted which included meetings with the Libanon Communityand the Glenharvie farming community.

Standard of Practice 9.2: Initiate dialogue describing cyanide management proceduresand responsively address identified concerns.




Basis for this Finding/Deficiencies Identified:Dialogue meetings are two-way dialogue sessions involving both dissemination ofinformation and the answering of questions on cyanide. Stakeholders were identifiedusing a stakeholder map database which included:- Department of Water Affairs andGauteng Department of Agriculture and Rural Development, local schools, towncouncils, Trade Unions, farmers, informal settlements, neighbouring mines, fire brigades,SA Police Service, and the Traffic Department. The data base of key people around themine was also updated. The returned stakeholder engagement forms gave notes on issuesstarting October 2011. The survey included the issuing of a leaflet entitled "Cyanideinformation bulletin" as well as the emergency response information and site contactdetails. Meetings were also held with cattle owners around the mine. Cyanide wasincluded in the community meeting agenda, at least annually. Presentations to thesurrounding water forums were given using the cyanide awareness video. A stand wasincluded at an Exhibition being held at the Randfontein Show in 2012. A Dialoguesession was held with 1st year medical students after they stumbled on a mock drill at thehospital. A Meeting with the Western Area Fire Protection Association discussedemergency evacuation with neighbouring communities and confirmed they cannot assistwith cyanide treatment. A schedule of cyanide public awareness sessions for 2012 formajor stake holders was sighted which included meetings with the Libanon Communityand the Glenharvie farming community.

Standard of Practice 9.3: Make appropriate operational and environmental informationregarding cyanide available to stakeholders.






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Basis for this Finding/Deficiencies Identified:The land survey included the issuing of leaflets entitled "Cyanide information bulletin" aswell as the emergency response information and site contact details. Community materialwas distributed during the community meetings. Sasol Polymers (the cyanidemanufacturer) is doing product awareness sessions to selected department and plant mineemployees using English, Xhosa and Sotho. Verbal presentations to the communitieswere also given in the language of the communities, including Zulu, Xhosa and Pedi. Insupport, pictures of warning signs, HAZCHEM, cyanide trucks are also used.All environmental incidents are classified as Levels 1, 2 or 3, depending upon theirseverity. All water-related level 3 incidents and above are reported to the nationalDepartment of Water Affairs. There is a monthly dashboard report and quarterlyDirectors review of all incidents of level 2 and above with detailed descriptions. Thewater forums receive reports on level 3 and above incidents and water quality reports.Environmental statistics (including cyanide) will be reported in the corporate annualreport with level 3 incidents and above, including a description. In terms of safety andhealth, there is a legal requirement for the reporting to the Department of MineralResources of all lost time injuries and fatalities, and serious accidents e.g. TSF failures,gassing incidents, loss of consciousness, via SAMRASS (South African MinesReportable Accidents Statistical System). All SHE statistics are included in the corporateannual report, available in hard copy and on the web site. All significant cyanideincidents are reported to the ICMI.The Gold Fields Corporate website includes the annual report which includesEnvironmental incidents levels 2 and 3, and injuries. No cyanide exposures,hospitalisation or fatalities occurred or were reported during the period since certification.

Documents

Eagle Environmental SUMMARY AUDIT REPORT th · PDF fileAddress: (Physical) KDC East Gold Mine, Farm Rietfontein, District Westonaria, 1779 (Postal) KDC East Gold Mine, P.O. Box 190,